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Depending on the country in which companies place packaging on the market, different labelling requirements apply to packaging. Many EU member states have recently made adjustments. Keeping track of these can be quite a challenge for many manufacturers. We have summarised the main changes for you below.
Rules at EU level
The rules for packaging labelling are based on the EU Packaging Directive 94/62/EC, amended by (EU) 2018/852. This European regulation is intended to contribute to the harmonisation of national disposal measures and to prevent and reduce the environmental impact of packaging materials. For example, packaging materials can be clearly identified and classified on a voluntary basis with the aim of optimising the collection, reuse and recycling of packaging waste.
However, there are countries that go one step further and already make this voluntary labelling mandatory. Furthermore, in some countries (including France and Italy), disposal instructions or sorting information must be provided. The aim of the measure is to help consumers to separate the waste correctly. This applies in particular to packaging that is mainly generated in private households. The initial distributor must ensure that their packaging is labelled accordingly.
Particularly strict obligations in France and Italy
In France, particularly strict requirements have been in force since 1 January 2022 as part of extended producer responsibility. The packaging affected must be marked with the Triman logo. Based on the circular economy law Loi AGEC, additional sorting information must be provided for the packaging that accumulates as waste with private final consumers. There are exceptions and special provisions (for small packaging, for example) as well as transitional periods that allow the placing on the market of unlabelled stock or goods that have already been imported (until 9 March 2023).
In Italy, the new labelling requirements have been in force since 1 January 2021. The labelling requirement for packaging has been suspended several times; most recently until 31 December 2022. All types of packaging must bear the material classification label. In addition, packaging that accumulates as waste at the private final consumer must bear mandatory disposal instructions. There are no exemptions; only a differentiation with regard to the source of the packaging waste. A transitional period has been granted: Packaged products without environmental labelling that were already on the market in Italy on 1 January 2023 may be marketed until stocks are exhausted.
The number of requirements and regulations is increasingVorgaben und Regelungen nehmen zu
In addition to France and Italy, other European countries have their own specific labelling requirements. In Bulgaria, for example, the Tidyman symbol must be displayed in addition to the material classification. In other countries, however, the introduction of further mandatory labels is planned (e.g. disposal instructions in Spain). In addition, a general trend can be observed towards stricter requirements for general environmentally relevant statements and symbols, e.g. a ban on claims such as ‘environmentally friendly’ and even criminal penalties for misleading symbols.
Update: A decree (No. 419) that came into force on 20 December 2022 amended the existing labelling requirements. According to this, in future packaging will only have to be labelled with the material identification (abbreviation and code) according to Appendix No. 2 (271/2012). The three-arrow symbol and the Tidyman will no longer be mandatory (however, if the three-arrow symbol is used voluntarily, certain requirements must be met).
The desire for harmonisation and standardisation of the mandatory symbols and labels at EU level is understandable. Measures in this direction are expected as part of the amendment of the EU Packaging Directive, which is expected to be published at the end of the year.
Update: On 30 November 2022, the EU officially published a draft regulation on packaging and packaging waste. Article 11 of this regulation contains harmonised labelling, marking and information requirements that stipulate that packaging must be provided with a label containing information on material composition to help consumers sort it. The same labels are to be affixed to waste containers so that consumers can easily identify the appropriate disposal route. The harmonised labelling requirements and formats for packaging and waste containers (including information on material composition) will be laid down by means of implementing acts.
About us
At RecycleMe, our mission is to support manufacturers and distributors of packaging in fulfilling their obligations. Our experts deal with all topics related to extended producer responsibility on a daily basis. Together, we can assess the situation for your company and determine any obligations.
As part of our advice on the subject of packaging labelling, we will be happy to evaluate your individual obligations, provide you with detailed information on country-specific requirements and regulations, and then make recommendations for action based on analyses of your packaging range.
