Environmental labeling for packaging: the new regulations and market scenarios

New year, new rules: on January 1, 2023, environmental labeling of packaging officially became mandatory in Italy as well. A change that opens new interesting scenarios for the packaging sector and those who work in it, but also for all the realities of large-scale retail trade. 

Let’s try to better analyze what it is about and understand what its market repercussions could be.

Environmental labeling of packaging: what is it?

It consists, concretely, in the obligation to apply a label to all packaging bearing useful information to understand its environmental impact and facilitate its collection, reuse, recovery or recycling. The label covers all packaging, so even so-called secondary packaging-for example, cardboxes of creams or toothpastes-and tertiary packaging (in other words, shipping packaging, a detail not to be overlooked, especially for large e-commerce companies). 

There is more: if a single product is composed of several separate parts, each with its own packaging (think about furniture to be assembled at home or a box of packaged snacks) the information will have to refer to each component. By “label,” however, we do not necessarily mean a physical medium attached to the product, but an appropriate information space that can also be included on the main packaging. Precisely with a view to providing all the necessary information, the law also allows the use for the purpose of a mobile-scannable code, such as a QRCode, which links to a source of digital insights. This is also to avoid the “hieroglyphic effect” of laundry labels. Let’s face it: have you ever really consulted them before putting a T-shirt in the washing machine?

Environmental labeling of packaging: examples

Let’s take a practical example: a hand cream contained in an aluminum tube, stored in a cardbox. We will need to inform the consumer about its different packaging: the aluminum tube and the cardbox. The “environmental label” (even in its virtual version) will need to contain the following information: 

  • 1- Identification of the material: it is not enough to indicate it in a generic way (e.g., plastic, glass or aluminum) it must be classified according to a precise alphanumeric code (as in Decision 97/129/EC) integrable UNI EN ISO 1043-1:2002 standards for plastic packaging or CEN/CR 14311:2002 covering both plastic and aluminum and steel packaging). The different plastics in circulation vary widely in recyclability and impact on the environment-so be specific. The use of icons is also recommended, especially if the recipient of the product is the end consumer. This point is mandatory for all types of packaging and all their intended uses. 
  • 2 – Packaging disposal instructions: if the packaging is intended for the end consumer, the label should describe all the necessary information about its disposal, such as where it should be thrown away (wet bin? plastic? paper?) or where it should be disposed of. In the case of multicomponent materials (e.g., laminate tubes) all materials used should be indicated. In case it is possible for the final consumer to separate them (e.g., food packaging with cardboard and plastic components) instructions on how to separate them and where to throw each component, should be included. It is also possible to associate these with graphic symbols suitable for more effectively conveying information (e.g., the recycling arrow triangle, the ok compost symbol, and others). Be careful, however: they should not be chosen “creatively,” you should refer to symbols developed by International Organizations for Standardization (ISO) or even European (CEN) or national (such as the Italian UNI, German DIN or French AFNOR).

Environmental labeling: B2B packaging

In point 2 we highlighted that the label must contain disposal instructions “if the packaging is intended for the end consumer.” 

What if it is not? What happens in the case of B2B markets? Suppose a manufacturer of aluminum tubes, like us, needs to send a batch of empty tubes to a customer company. In this case, the label needs to indicate only the information in item 1, that is, the information about the materials of which the packaging is made. All other information is on a voluntary basis (although the regulations still encourage providing as much information as possible). As for tertiary packaging (i.e., the cardboard boxes that contain the tubes and the plastic wrapping that protects them) in B2B, the indication of the material may be confined to the transport documents of the goods. 

One knot remains to be unraveled, however: that same tube that leaves our factories empty, once filled, is still destined to arrive in the hands of the end consumer. So, it is required to add information about the proper packaging disposal. Who is responsible for doing this? The packaging manufacturer or the company? Fortunately, the legislation is very clear on this point: it is up to the product company to properly inform the end consumer. This is because the contents can decisively affect the proper disposal of the packaging. Consider, for example, the well-known “food contact paperboard”, which cannot be recycled in the paper bin. 

However, clear and transparent communication with the client company is essential, which is why, even before the regulations came into effect, we decided to integrate our shipping  documents with all the information about the materials used.

Environmental labeling of packaging: the legislation

Let’s take a look to a few legislative references, useful for possible further study. 

Underlying the new environmental labeling of packaging in Europe is, of course, the European Union, which has put the world of packaging under its magnifying glass in recent years. The European Commission’s website states that The current Directive on packaging and packaging waste introduced in 1994 did not succeed in reducing the negative environmental impacts of packaging. These include wasteful overpackaging; increasing amounts of non-recyclable packaging within the packaging mix; confusing labelling that makes it difficult for consumers to sort; and very low uptake of recycled content in plastic packaging which means huge loss of valuable resources.”

With this in mind, EU Directive 2018/851 on waste and EU Directive 2018/852 on packaging and packaging waste were born. 

In Italy, the text of reference is that of Legislative Decree 116/2020 (D.Lgs 116/2020), by which amendments are made to the Environmental Code and the Consolidated Environmental Act (D.L.vo 152/2006 – in particular paragraph 5 of Article 219) regarding the “criteria informing the management activity of packaging waste.” 

Italy is not the first to adopt the European legislation; in fact, France implemented the directives in September 2022. This means that all products distributed in France (and now, in Italy) must already follow the new regulations, which will be gradually introduced in all EU countries. 

Environmental labeling: but was it really necessary?

The impact of packaging on the environment (particularly plastic packaging) is not a problem to be underestimated: according to the European Commission, waste generation in the EU area has increased by more than 20 percent in 10 years, despite growing numbers of recycling practices. Single-use packaging is mostly “to blame.” If nothing changes, estimates outline a 46 percent increase in plastic waste by 2030 and 31 percent by 2040. 

With the new Directives, the Legislature is confident of a positive turnaround that would lead to a 37 percent reduction by 2040; it would equate to about 15 percent less waste per inhabitant of the EU. Utopia or reality? 

Environmental labeling, the market fallout.

At the heart of the Directives is a changed consumer focus on environmental issues: market research shows that consumers prefer products that use environmentally friendly packaging and demonstrate real “green” attitude. Consequently, adequate information on the ecological impact of packaging should decisively guide product choice, coming to stand as a real and valid reason for purchase. 

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