Giulia Corsi -

In September 2020, Legislative Decree No. 116 of 3 September 2020 was published in the Italian Official Journal (IOJ), in relation to the labelling of packaging, which transposes EU Directive 851/2018 on waste and EU Directive 852/2018 on packaging and packaging waste and amended Article 219(5) of Legislative Decree 152/2006.

Effective from January 1st, 2023, environmental labelling decree obliges cosmetics manufacturers, packaging material suppliers, processors and importers of empty packaging and packaging materials that each bottle, jar and container be labelled with its material, so as to facilitate its disposal by the consumer.

In particular, it is mandatory to state on the label:

  • the alphanumeric coding identifying the material (as per Decision 129/97/EC) even for all manually separable components of the packaging system;
  • information to support the consumer in the correct collection of packaging (e.g. “Separate collection, Family of material, Check your municipality’s regulations”).

On a voluntary basis, it is advisable to include additional information to increase the quality of the separate collection (e.g.: empty the packaging before placing it in the collection).

The decree does not specify which graphic style to use; it recommends that the packaging be appropriately labelled, so it leaves freedom of choice as to the graphic style, form, font height and colours of the environmental labelling. Obviously, it is assumed that, in addition to being clear, not misleading and easily understood by any consumer, the labelling must be clearly legible.

On this basis, the use of digital tools is allowed (e.g. Apps, QR codes, websites), consistent with the process of technological innovation and simplification, a fundamental aspect envisaged within the Italian National Plan for Recovery and Resilience Plan.

Regulatory Pharma Net (RPN) is available to provide your company with any updates on the cosmetics regulatory framework and to assist on all regulatory needs.

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