New environmental labelling: implementation requirement extended until 1 July 2022

Italian Legislative Decree No. 116 of 3 September 2020 ("D.Lgs. 116/2020"), implementing (EU) Directive 2018/851 on waste and EU Directive 2018/852 on packaging and packaging waste, amended inter alia Article 219, para 5, of the Italian Legislative Decree No. 152 of 3 April 2006 (the "Italian Environmental Code"), which provides for certain environmental labelling requirements and obligations for packaging.

New eco-labeling requirements will be mandatory from 1 July 2022.

The Italian Decree Law No. 228 of 30 December 2021 ("DL 228/2021") extended the period of suspension of the obligation of environmental labelling (initially until 31 December 2021) to 30 June 2022, with the possibility for companies to sell products without the new environmental labelling requirements while stocks last, provided they have already been put on the market or labelled as of 1 July 2022.

Consequently, packaging - even if empty - which has been labelled (i.e. already printed, or for which a label has already been produced/applied) before 1 July 2022, or packaging which has been purchased by the packaging users from their suppliers before the same deadline, may continue to be marketed.

The DL 228/2021 has also provided for the issue of a non-regulatory decree by the Minister for Ecological Transition, containing technical guidelines on the correct labelling of packaging.

Pending the guidelines being issued, we summarize below the main conditions for the correct implementation of the labelling requirements by your company.

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