What are the labelling requirements in Italy and what do I need to do?

The legislative Decree No.116 of 3 September 2020 imposed a strict obligation of environmental labelling standards on participants along the supply chain, making environmental labelling mandatory on all packaging in Italy (all primary, secondary and tertiary packaging that is put on the Italian market). The aim of the law is to reduce the impact of packaging and its waste on the environment, by (i) using identification codes, to facilitate the reuse, recovery and recycling of packaging whilst (ii) providing consumers with information on the correct end-of-life treatment of the waste.

The decree stipulates that producers are obliged to label the packaging accordingly. The decree defines producers as “suppliers of packaging materials, manufacturers, processors and importers of empty packaging and packaging materials”. 

Thus, the manufacturers of packaging have the primary obligation to implement the requirements. However, the decree states that the "user of the packaging" and the distributor/supplier are also subject to further obligations along the supply chain. Italian law therefore assumes a shared responsibility, whereby the fines for a breach of the regulations affect the distributor in particular as the last in the chain. Zalando's suppliers must therefore ensure the respective labelling, as is also laid down in the Quality Assurance Manual.

The new obligations apply to all B2C-packaging, thus all primary (product) packaging and all secondary (shipping) packaging. The obligation to indicate the material of the packaging by way of an alphanumeric code applies as well to all B2B-packaging.

There are two specific obligations for environmental labelling in Italy: (1) applies to all packaging, (2) that only applies to B2C-packaging.

1. It must be ensured that the material of the packaging is indicated. The alphanumeric code according to Decision 97/129/EC shall be used for this purpose. It is possible and recommended to use the “Möbius Loop” (three arrows), if applicable*:

 *The Möbius loop indicates that packaging is recyclable or that it is made from secondary raw material.

2. Packaging intended for end consumers (B2C-Packaging) must be clearly labelled with appropriate instructions for disposal. The notes must be written in Italian. The Italian Consortium of Packaging Materials (CONAI) makes the following suggestions for labelling:

“Separate waste collection. Check your local municipal guidelines” (“Raccolta differenziata. Verifica le disposizioni del tuo Comune”) 

OR

Information on packaging collection according to the format “[Material] Collection” (e.g. “Plastic Collection” = “raccolta plastica“; “Paper/Cardboard Collection“ = “raccolta carta”)

Please find further information in this Guidance from the Italian Ministry  as well as from the Italian packaging consortium (plus an FAQ here).

The Italian packaging law recommends (it is not mandatory) to add further information to the label. This may include:

• For multi-component packaging, indication of the type of packaging to help the end user to separate and dispose of individual parts. Whether this is done by using a graphic or a short text is optional. In this case, too, the text must be written in Italian.

• Information on the correct separation of waste, such as “Empty the packaging” = “Svuotare l’imballaggio“.

Please find further information in this Guidance from the Italian Ministry  as well as from the Italian packaging consortium (plus an FAQ here).

Yes, please see for further information the Guidance from the Italian Ministry  as well as from from the Italian packaging consortium (an additional FAQ can be found here). To highlight a few specifications:

• If packagings consist of several materials but the secondary material is less than 5% of their weight, they are classified as single-material packagings. Then they are labelled according to the predominant material by weight. The 5% rule is relevant when using printing ink or glue, for example.

• A packaging system that provides for a main body and other additional components that are not manually separable must be marked with the identification code of the material of the main body and the instructions for disposal in relation to the material of the main body.

• There is a need for labelling of all components that can be separated by hand. If this is not possible, then either on the main part of the packaging or on a separate label; otherwise on another component that makes the information easily visible to the consumer. 

• If, due to lack of space or other technical reasons, it is not possible to place the label on the packaging, it is permissible to place the contents of the label on a separate medium (e.g. package insert) or via digital channels (QR-code).

Yes. The original deadline of 1 January 2022 was extended by 12 months to 1 January 2023. Since that date, packaging must be marked with the alphanumeric code so that the material can be identified. Information on correct disposal must also be provided on packaging.

Packaging that is already in circulation (thus, packaging that is already produced) may continue to be distributed without the new labelling. However, this exemption only applies until this already existing stock is used up.

High-quality recycling can only succeed if there are waste streams that are as well sorted as possible. In the first step, it is up to the consumer to put the specific waste into the right recycling path. This is where the sorting instructions are intended to help the customer/consumer. Italy thus wants to increase its recycling rate and support the circular economy.

Yes; the process outlined above is specifically for the Italian market. However, please note that there are labelling requirements as well for the French market.

Anyone who puts packaging on the market that is not properly labelled can be held accountable. In the case of incorrect or missing labelling, fines of 5,200 – 40,000€ can be imposed. The obligation is directed not only at manufacturers but also at traders, distributors,  fillers, users of packaging and importers of filled packaging.

Moreover, it is part of your contractual obligation with Zalando as laid down in the Quality Assurance manual to ensure that your products are correctly labelled in accordance with applicable law. The absence of the labelling is therefore to be considered as a breach of contract and can lead to corresponding sanctions by Zalando. As a consequence none of your packaged products can be and should be offered for the Italian market.