EU legal guidelines on packaging labeling: let’s try to make things clear



Since September 2020, in Italy, Legislative Decree 116/2020 has come into force, amending Legislative Decree 152/2006 and implementing the European directive on waste (EU 2018/851) as well as the one on packaging and packaging waste (2018/852 ). This decree has a great impact on all manufacturers because it establishes the environmental labeling on each packaging as mandatory. The law says:

All packaging must be appropriately labeled in accordance with the procedures established by the applicable UNI technical standards and in compliance with the decisions adopted by the European Union Commission, to facilitate the collection, reuse, recovery and recycling of packaging, as well as to provide correct information to consumers on the final destination of packaging. Producers are also obliged to indicate, for the purposes of identification and classification of the packaging, the nature of the packaging materials used, based on Commission Decision 97/129 / EC.

Please note: this is an European legislation, we suggest you refer to your local laws for any specifics. If you are not in the European Union, these laws may not apply to you.

So, what needs to be done?

The alphanumeric code identifying the material represented by the Möbius cycle symbol must be affixed to the packaging of each product destinated to the final consumer.
These are the main materials used for Induplast Packaging Group products.

The decree states that the parts of the packaging that the consumer can separate manually without using tools must be labelled.

Let's put this into practice by making examples of packaging composed of several components that can be separated manually.
If you have a PET bottle with a PP screw cap you can consider the two components as easily separable. The label must indicate both material symbols of the Möbius cycle.

Another example with HDPE bottle and PP cap.

Let's make another practical example with a lip balm container composed of a bottom, an interior, an ABS cap and POM piston. We can consider to manually separate only the cap and the bottom (the later includes a piston and an interior mechanism) so both will be labeled as "07 OTHER".

What should be done in cases where the packaging has different non-separable materials components such as liner or internal mechanisms?

Let's take as an example a PET jar with a PP cap equipped with a Tri-seal liner. The liner cannot be separated by hand; we would need a tool to help us lift it and separate it from the cap.

In the case of parts that cannot be separated manually, made up of different materials, the law states:

- If the weight of the minor component is less than 5% of the total weight, it can be considered MONO MATERIAL and therefore must be labeled according to the composition of the major component

- If the weight of the minor component is greater than 5% of the total weight, it can be considered MULTI MATERIAL and must be labeled with the symbol "07 OTH"

Let's contextualize these indications by using the example of the PET jar with PP lid and a Tri-seal liner.
If the weight of the Tri-seal liner is less than 5% of the total weight of the cap, the cap must be considered as a single material and therefore labeled with the Möbius "05 PP" symbol.
If, on the other hand, the weight of the Tri-seal liner is more than 5% of the total weight of the cap, the cap is considered to be multi material and must be labeled with the Möbius "07 OTH" symbol.

The decree also provides for the guidelines of information for the end user to correctly dispose of packaging. 
Therefore, according to the material, the end-of-life destination of the packaging and its components must be indicated.  

i.e: “Recycling + Family of material. Check your local requirements".

The commencement date of this obligation to adhere to this decree has been extended until the 31st of December 2021, by the Milleproroghe 2021, Decree, published in the Official Italian Gazette on December 31st, 2020.
However, the obligation to indicate, for the purposes of identification and classification of the packaging, the nature of the packaging materials used remains in force, on the basis of the Commission Decision 97/29 / EC.

We at Induplast Packaging Group, as a manufacturer, will support our customers in this legislative adjustment by providing the technical drawings of the products and the materials of the products that compose them.

For any information do not hesitate to contact your Vexel, Verve and Induplast sales representative or contact us here.

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