Packaging Management

When we talk about packaging, we refer to products, composed of materials of any kind, used to contain certain goods, to protect them, to allow their handling and delivery from the producer to the consumer or user, and to ensure their presentation, as well as disposable items used for the same purpose. The principles underlying the legislation governing the management of packaging and packaging waste are essentially two:

• the "shared responsibility principle"
• and the Community principle according to which "the polluter pays".

These principles give rise to obligations for businesses, public administrations, and citizens.

Legislative Decree 116/2020 has introduced important obligations regarding the labeling of packaging, in particular Article 219 paragraph 5, as currently in force, states:

"All packaging must be appropriately labeled according to the methods established by the applicable UNI technical standards and in accordance with the decisions adopted by the European Commission, to facilitate the collection, reuse, recovery and recycling of packaging, and to provide consumers with correct information on the final destinations of packaging. For the purposes of identification and classification of packaging[CR1] , producers are also obliged to indicate the nature of the packaging materials used, on the basis of Commission Decision 97/129/EC".

The Ministry of Environment and Energy Security (MASE) has adopted, as an annex to Ministerial Decree 28/09/2022, n.360, the technical guidelines that define the requirements for the environmental labeling of packaging. The guidelines have been in force since 1 January 2023.

Normachem, through its specialized technicians in the sector, provides support to companies in complying with the standard, through:

• ad hoc consulting on the correct methods of labeling packaging according to the provisions of the ministerial guidelines;
• training of company personnel.

Extended Producer Responsibility (EPR) is a principle that assigns producers responsibility for the entire life cycle of their products, including the phase in which they become waste. This principle aims to promote a more sustainable and circular economy, shifting the burden of waste management from public administrations to producers of goods, encouraging the design of more recyclable, reusable, and repairable goods.

In Italy, the legislation governing EPR was updated with Legislative Decree 116/2020, which amended Legislative Decree 152/2006, in line with European Directive 851/2018. Producers must therefore take charge of the management of waste originating from goods placed on the market, both from a financial and managerial perspective.

CONAI, the National Packaging Consortium, is a private, non-profit consortium in Italy that is the reference point through which producers and users of packaging guarantee compliance with the extended producer responsibility principle and the achievement of the recycling and recovery objectives of packaging waste as provided by law.

Companies that produce or use packaging must join CONAI and contribute financially (through the payment of fees) to support the collection and recycling activities.

In addition, all subjects obliged to apply the Environmental Contribution are required to declare to CONAI the quantities of packaging transferred/imported into italian territory. The frequency of communications may be annual, quarterly or monthly depending on the total amount of the Environmental Contribution declared, per material, in the previous year.

Normachem supports companies in managing CONAI obligations, providing assistance for:

• assessing the company's obligations, based on the role it plays in the packaging supply chain;
• supporting the company in the registration procedures to CONAI;
• submitting periodic declarations to CONAI or, if applicable, exemption requests.