Environmental Labeling: a Challenging Solution

On December 30, 2021, was published in the Official Gazette the Decree-Law n. 228, which provides for the suspension of the obligation of Environmental Labeling for all packaging in Italy until June 30, 2022, expected to come into force on January 1 of the same year by Legislative Decree 116/2020.

There was talk of Environmental Labeling as early as 1997 when the European Commission established with Decision 129/97/EC the first coding system for materials used to produce packaging, which, although voluntary, was adopted by most companies.

Subsequently, in 2018, the four European Directives of the “circular economy package” came into force:

• Directive (EU) 2018/851, on waste;
• Directive (EU) 2018/852, on the packaging;
• Directive (EU) 2018/849, on end-of-life vehicles, batteries, and waste electrical and electronic equipment;
• Directive (EU) 2018/850, on landfills.

Targets included recycling by 2025 for at least 55% of municipal waste (60% by 2030 and 65% by 2035) and reducing landfilling (to a maximum of 10% by 2035).

Community objectives relating to waste have been implemented and transposed into our legal system through Legislative Decree 116/2020 with the obligation of Environmental Labeling.

How Will Environmental Labels Change?

Environmental indication on the packaging of a food product
It is essential that all packaging intended for consumers be labeled to collect waste. This is an example of the environmental indications we will get used to consulting.

But let’s see in detail what the information on the subject is:

1. The identification coding of the packaging material according to Decision 129/97/EC;
2. The collection indications. There is no standard rule on the formula to be adopted to indicate the type of collection. For example, if paper packaging is considered, it could be marked “Paper collection” or simply “Paper. Separate collection. It is important to remember that separate collection is managed locally by the municipalities so that indications may vary from city to city. In this regard, it is helpful to insert a formula such as “Separate collection. Check your municipality’s regulations”.
3. Any information regarding the type of packaging that can support the consumer in a separate quality collection.

• The issue may seem simple on the surface, but in reality, it is very complex, as are all the rules applied in the food sector.
• First of all, it is necessary to distinguish the circuit of destination of the packaging: B2B (business to business) or B2C (business to consumer), for which the structure of the minimum contents of Environmental Labeling is different. In addition, packaging can be single-component or multi-component; the latter can be distinguished in components that cannot be separated by hand from components that are.

CONAI and Environmental Labeling Guidelines

The new standard has left room for many interpretative doubts, which is why CONAI (Consorzio Nazionale Imballaggi), in collaboration with the Istituto Italiano Imballaggio, has promoted a work table involving UNI (Italian National Unification Body), Confindustria, and Federdistribuzione, to provide a shared interpretation key, elaborated within the Guidelines for Environmental Labeling, published on December 16, 2020.

In addition, CONAI has made an online, operational tool, E-tichetta, to view the information to be included in the labels of its packaging, helping companies in the redefinition of labels.

To avoid unnecessary waste, until December 31, 2021, companies could use the stocks in their warehouses (purchased by 31/12/2021) until they were exhausted, while with the extension, the deadline for the exhaustion of supplies non-compliant packaging has been postponed to July 1, 2022.

Is Environmental Labeling the Solution?

How many of us don’t know how to dispose of packaging correctly?
In this sense, Environmental Labeling is an excellent solution to make consumers aware of how to dispose of waste. Moreover, companies, having no limits of design or fixed dimensions, can give free rein to ideas and images easily understandable to all.

However, what is not taken into account is the large amount of “non-compliant” packaging that will have to be disposed of this year by complying with the Decree. Until a few days ago, it should have come into force on January 1 of this year, which is why many companies have already adopted the Environmental Labeling.

Finally, the regulation that introduced the obligation of Environmental Labeling refers exclusively to packaging placed in the Italian territory; therefore, packaging exported abroad is not subject to this requirement.

Would it perhaps have been helpful to standardize this law, at least at the European level? How can we protect our companies and our consumers, as well as the planet?