Introduction

Recent regulatory changes (Legislative Decree No. 116 of 3 September 2020) that introduced mandatory environmental labelling of packaging have prompted many companies to integrate, modify or affix from scratch the minimum environmental information on their packaging.

CONAI took this opportunity to draw up the Guidelines on environmental labelling of packaging which are intended to be a support for companies in interpreting and understanding the text of the law, as well as an opportunity to clarify aspects and definitions that very often cause confusion.

In this context, many companies are approaching this innovation as an opportunity to review the set of environmental information that can be conveyed through packaging. In addition to the information they are required to put on their packaging, companies are asking themselves how they can clearly, correctly and reliably promote and convey additional environmental characteristics of their packaging.

This is why CONAI has decided to support them in this process with a new work tool that aims to provide an overview of the main environmental declarations and labels that can be voluntarily affixed to packaging, and to explain their objectives and meaning.

The Guidelines for voluntary environmental labelling of packaging therefore aim to guide companies in providing additional environmental information in an unambiguous and proper manner.

 

Which information?

The document consists of two sections: a descriptive one and one that contains the answers to the most frequently asked questions we have gathered to date from companies and associations.

The descriptive part presents an overview of the main voluntary environmental labels envisaged for packaging, broken down by label type. In this case, the following is provided:

• the information for high-quality separate waste collection, that the company can voluntarily add to the mandatory indications referring to separate collection of waste packaging intended for end consumers;
• the “Made Green in Italy” national voluntary scheme;
• the product environmental labels, which are those that are part of the ISO 14020 standard, and are divided into 3 types (Environmental labelling types I, II and III);
• the environmental certifications: the main ones concern the certification of compostability, recycled material content and proper forest management linked to the supply of raw material for goods produced in wood and paper;
• Other specific environmental labels for material supply chains, in particular for paper and cardboard packaging in relation to its recyclability, and for metal packaging in relation to communication of the ability of these materials to be permanently recycled;
• Participation in an EPR system, where a trademark is envisaged, in particular for the CONAI, COMIECO and CiAl consortia.

The second part of the document envisages a series of FAQs and practical examples that aim to show which packaging environmental information can be voluntarily included on the label and for what purposes.

The table below summarises the environmental labellings and trademarks described in these Guidelines, classified by purpose and type of material to which they may refer.

 

NOTE 1
General Rules On Using The Conai Trademark

NOTE 2
Rules regarding the COMIECO trademark

 

Additional information for efficient separate waste collection

Since 26 September 2020, packaging intended for the B2C channel, in addition to the alphanumeric coding identifying the material, must also provide indications for the end consumer on proper separate waste collection. This obligation underlines the importance and strategic nature of communication through packaging, which has once again proved to be an ambassador of virtuous values and responsibility towards the environment.

Citizens are thus supported in recognising the materials the packaging is made of in order to identify its destination in separate waste collection, according to the procedures in force in their municipality.

Indeed, in Italy, it is the Municipalities that organise and manage separate collection, depending on the morphology, organisation, logistics and availability of plants in the area. Therefore, these Municipalities adopt different separate collection systems (e.g. street, door-to-door, mixed), according to specific needs, with different collection methods (multi-light, multi-heavy, glass-metal).

Local authorities thus perform their duties within the recycling chain, but responsibility is shared with other parties, without which the cycle would be incomplete. In this regard, citizens play a key role by applying separate collection in their homes, a crucial commitment without which the circular economy would not be possible. Over the years, the results obtained in terms of the quantity of waste collected have been very satisfactory, facilitating a steady increase in recycling performance. In order to be able to do more and do better and to strive further towards even better recycling results that generate valuable secondary raw materials that can be efficiently reintroduced into new production cycles, it is essential that separate waste collection also improves in terms of quality. Citizens can play a substantial role in this, as too can companies, by conveying “instructions” for quality separate waste collection through the packaging they put on the shelves, as well as virtuous messages that effectively raise consumer awareness.

For these reasons, communicating this kind of message to end consumers can help increase their awareness and responsibility, so that they perform simple gestures that can make a difference in terms of the quality of separate waste collection.

For example, given the wide variety of separate waste collection systems and procedures throughout the country, together with proper instruction on where to put the packaging, it is important to recommend that consumers check the regulations provided by the municipality in which they are located so as not to make mistakes.

It is also useful to recommend that consumers empty the packaging of its residual content (unless it is food refuse present in compostable packaging intended for the household food waste collection circuit), although it is not necessary to wash it.

In order to improve and optimise the collection and subsequent phases performed by the operators, it is good practice to ask the consumer to reduce the volume of packaging, especially when it comes to bulky packaging.

If the packaging system consists of several manually separable components made of different materials, it is of absolute importance to clearly instruct the end consumer to separate the components and put them in the right place. Especially when the instructions are all on the packaging or presentation component, it is highly recommended to support the consumer in properly understanding the information, specifying the different packaging components and, for each one, clear information about its composition and proper separate collection.

The Guidelines for environmental labelling include several examples of environmental labelling of packaging which, in addition to the mandatory information, also includes optional instructions for the end consumer for quality separate waste collection.

Moreover, the e-label tool available at http://e-tichetta.conai.org, depending on the packaging selected, proposes certain additional specific information that can be optionally communicated to the consumer for quality separate waste collection.

By way of example, the table below provides a number of indications that can be put on the packaging to aid the consumer in quality separate waste collection.

 

“Made Green in Italy” national voluntary scheme

Decree no. 56/2018, which came into force on 13 June 2018, established the regulation of the national voluntary scheme for the assessment and communication of the environmental footprint of products, called “Made Green in Italy”, and which aims to promote products (including packaging) with high environmental qualification through granting the use of the “Made Green in Italy” logo.

The implementation of the scheme involves two phases:

• Phase one: Development of Product Category Rules (PCR)

These are documents containing methodological guidelines that define mandatory and optional rules and requirements necessary to conduct environmental footprint studies for that specific product category. In order for a company to join the scheme, it is essential that PCRs exist for the products for which it intends to join.

Therefore, if a Product Environmental Footprint Category Rule – PEFCR has already been defined at the European level for that product category, this will be transposed in the PCRs; on the contrary, a PCR will be calculated at the national level, following a request to the Ministry of Ecological Transition, according to the foreseen procedures.

• Second phase: joining the “Made Green in Italy” scheme

Products for which there is a valid PCR and which are “Made in Italy” can apply to join the “Made Green in Italy” scheme, by submitting the documentation required in the Regulations.

The product environmental footprint study involves calculating the environmental indicators identified by the related PCR, and an aggregate value of the three main impact indicators, which is then compared with the benchmark defined by the relevant PCR. This comparison allows products to be classified into three possible classes:

• class A, excellent products that perform better than the average product (benchmark);
• class B, products with performance equal to the benchmark;
• class C, products with performance worse than the benchmark.

Class A and B products will be eligible for granted use of the “Made Green in Italy” logo, but those belonging to class B must include an improvement plan to be implemented over the three-year period of validity of such use.

 

Product environmental labels

The ISO 14020 standard is part of the 14000 series of standards that cover management tools for organisations to track and assess their environmental impact and improve their performance.

In particular, the 14020 standard addresses the communication of environmental characteristics and performance of products, classifying voluntary environmental labelling into three categories: Type I, Type II, and Type III environmental labels.

Environmental labelling aims to inform end consumers and in general the public or private customers on the environmental characteristics and qualities of the products offered. For the packaging sector, environmental labelling is always voluntary.

Type I environmental labels – externally certified environmental labels

These are voluntary labels based on the life cycle approach and require compliance with certain standards in order to be issued. The product/service for which it is requested is subject to third-party certification. The reference standard is UNI EN ISO 14024:2001 (Environmental Labels and Declarations – Type I Environmental Labelling – Principles and Procedures).

These types of labels include, for example, the European ECOLABEL ecological quality label.

Type II environmental labels – Self-declared environmental claims

Environmental self-declarations, also called Type II environmental labels, are declarations through which the producer communicates the environmental characteristics of the packaging to the market.

UNI EN ISO 14021 regulates the environmental claims self-declared by companies on their products, and concerns not only the information that in this case is provided through the pack itself, but also that communicated through other channels, such as the Internet or advertising in general.

The standard is useful to packaging producers and users that want to communicate the environmental characteristics of their packaging in a clear, transparent, and non-misleading manner, defining a set of requirements and indicating commonly used terms for voluntary communication of environmental information.

The Type II Environmental Declaration is prepared directly by the company and does not require verification of the information contained. Nevertheless, to demonstrate greater credibility of the declarations, the company may choose to require validation by a third-party body through appropriate verification.

Some examples of communication of self-declared packaging environmental characteristics by the producer may include recyclability, use of recycled material, reduction in resource use, reusability, waste reduction, design for long-term use or disassembly, etc.

 

Declaration of recyclability and recycled material content

The standard allows the optional use of symbols to make environmental claims. The standard does not define any specific symbol with the exception of the Mobius Loop, which is used for claims relating to packaging recyclability and recycled material content.

The symbol, without percentage share, indicates the recyclability of the packaging, while with the percentage share it provides information about the amount of recycled material contained in the packaging compared to the total composition.

The reference standard for the methodology of monitoring the recycled material content in packaging is CEN CR 13504:2000.

 

In order for packaging to be declared recyclable, it must comply with EN 13430 and, therefore, it must meet the criteria for suitability for existing recycling technologies, namely:

• existence of an efficient recycling technology for the type of packaging;
• existence of a critical mass so that an efficient recycling process may be managed;
• existence of a market for recycled materials.

These criteria must be assessed via specific surveys and studies.

 

Self-declared claims may be verified and certified by an accredited certification body to ensure greater reliability of such declarations. On the Accredia website it is possible to consult a database in which the accredited bodies and laboratories are listed.

To support companies that wish to communicate the recyclability of packaging and, to this end, to find out information on the existence of consolidated sorting and recycling supply chains throughout the country or those under development, CONAI provides three main tools:

• Design for Recycling. Packaging Design for Recycling Guidelines, available at progettarericiclo.com
  
  
• CONAI EcoD Tool. This is the packaging eco-design tool made available to consortium member companies by CONAI. The tool, based on the simplified LCA analysis, suggests possible improvement actions for the user on the different phases of the packaging life cycle in order to improve its environmental profile. In particular, based on the characteristics and design of the packaging, the tool generates an assessment of the recyclability of the packaging and suggests certain actions for the user to improve the packaging in order to make it more recyclable.
  
  
• Lists of the contribution levels of the CONAI diversified Environmental Contribution for plastic packaging.
  CONAI has envisaged diversification of the Environmental Contribution according to packaging recyclability. To this end, four packaging recyclability categories have been created, for each of which the value of the CONAI Environmental Contribution has been defined, which is lower for more recyclable packaging.

The lists are available at the following link and are useful to verify which packaging there is a sorting and recycling chain for, and which can therefore be defined as recyclable.

 

Type III environmental labels – Environmental labels with established parameters that are independently controlled

Type III environmental declarations describe the environmental impact characteristics of a product based on its entire life cycle, through the LCA (Life Cycle Analysis) approach based on rules established for the specific product category.

Products for which these labels are required are subject to third-party verification by an accredited certification body. These include, for example, “Environmental Product Declarations” or EPDs.

The reference standard is UNI EN ISO 14025: 2010 (Environmental Labels and Declarations – Type III Environmental Declarations – Principles and Procedures).

Environmental certifications

Product certifications are issued by accredited third-party bodies. The accreditation of these bodies takes the form of a procedure that certifies their independence and impartiality by the Single National Accreditation Body, which in Italy is Accredia. On the Accredia website it is possible to consult a database in which the accredited bodies and laboratories are listed.

Biodegradability and compostability certifications and labels

Compostability certification of is issued by accredited third-party bodies pursuant to the harmonised European standard EN 13432 and certifies that which the packaging directive 94/62 defines as packaging recoverable in the form of compost, i.e. organically recyclable (in composting/anaerobic digestion) together with organic household waste.

In order to be able to also put the biodegradable and compostable packaging waste (and other items) into organic waste collection, Legislative Decree 116/2020 amended Article 182-ter of Legislative Decree 152/2006 (organic waste): in particular, paragraph 6 of the aforementioned article establishes that waste, including packaging waste, having similar biodegradability and compostability properties to organic waste, must be collected and recycled together with the latter if:

a) it is certified by accredited bodies as compliant with European standard EN 13432 for packaging recoverable through composting or biodegradation, or with European standard EN 14995 for other non-packaging items;

b) it is appropriately labelled and states:

- mention of compliance with the above European standards,

- identification details of the producer and certifier,

• appropriate instructions enabling consumers to put such waste in the organic waste separate collection and recycling circuit.

 

 

Certain certifiers operating in Italy, together with the biodegradability and compostability certification, also issue specific labels that can be affixed to the packaging certified.

1. The Italian Composters Consortium which, together with Certiquality, certifies biodegradable and compostable products with its “CIC Compostable” label.
   
2. The TUV Austria group which issues the “OK Compost” label
   
3. DIN Certco which issues the “DIN Geprüft Industrial Compostable” label
   
4. The European Bioplastics Association which is certifiable by both Vinçotte and DIN Certco.
   

 

Renewable raw material content certification

For biobased products, the content of renewable material can be measured by the radiocarbon method according to EN 16640 which defines test methods for determining the biobased carbon content of products. 

Certification by an accredited body of compliance with the standard is mandatory for producers of biodegradable and compostable bags made of ultra-light material.

 

Recycled material content certifications

In addition, there are also certifications on the recycled material content, in accordance with which the use of certain labels can be granted. The most common are Remade in Italy®, Second Life Plastic, FSC Recycled®, PEFC® Recycled.

For all packaging materials

Remade in Italy® is an accredited certification in Italy for verifying the content of recycled material in a product. It certifies the traceability of production within the supply chain, starting from verification of the origin of incoming raw materials, up to the finished product.

Further information is available at: www.remadeinitaly.it

 

For plastic packaging

The “Second Life Plastic” label is an environmental product certification system dedicated to materials and products obtained from the exploitation of plastic waste.

Further information is available at: www.ippr.it

 

For paper or wood packaging

The FSC Recycled® label states that the wood or paper of which the product is made comes from recycled material.

Further information is available at: it.fsc.org

The PEFC® Recycled label states that at least 70% of the paper or wood in the product comes from recycled sources. The remaining material must be PEFC certified or from PEFC controlled sources.

Further information is available at: www.pefc.it

 

Proper forest management certifications

 

 

• FSC certification guarantees that the product comes from a responsibly managed forest and supply chain; therefore, to obtain it, the essential rules of responsible forest management must be complied with.

FSC issues three types of certification:

• Forest Management: issued to forest managers and owners whose management practices meet the requirements of the FSC Principles and Criteria.
• Chain of Custody: guarantees FSC-certified material and derived products throughout the supply chain, from the forest to the store.
• Controlled wood: In order to meet the growing demand for certified material, the FSC system has an input category which, while not certified, can provide sufficient guarantees to companies and consumers that they meet certain minimum criteria established by the Forest Stewardship Council.

Further information is available at: it.fsc.org.

 

• PEFC certification provides a guarantee on origin from sustainably managed forests of the forest or tree origin material contained in a product, through traceability of the certified raw material throughout the supply chain up to the finished product. It is issued by an independent third-party certification body.

There are different types of PEFC Chain of Custody certification:

• individual PEFC certification;
• group PEFC certification, in which several independent companies join together to streamline the paperwork for individual certification;
• PEFC project certification, useful for construction companies to demonstrate their choice to build with PEFC certified timber.

Further information is available at: www.pefc.it

 

Other specific environmental labels for material chains

For paper and cardboard packaging

 

Technical standard UNI EN 11743:2019 and the Aticelca 501/2019 Recyclability Evaluation System.

Companies wishing to assess the recyclability of their paper packaging may ask a laboratory to perform a recyclability test, which simulates the main steps of the industrial paper recycling process, in accordance with the procedure defined by UNI 11743:2019.

The outcome of the test allows the recyclability level of the packaging to be identified according to the Aticelca 501/2019 recyclability evaluation system.

The system also makes it possible to communicate the level of recyclability obtained through the use of the special “Recyclable with paper – Aticelca® 501” label.

Further information is available at: aticelca.it

 

For steel or aluminium packaging

 

Metal Recycles Forever

With the aim of raising awareness among end consumers of the importance of properly managing metal packaging so that it can be recycled an infinite number of times and become raw material for new production processes, the Metal Recycles Forever logo was created in 2015.

The logo, issued by Metal Packaging Europe and distributed in Italy by Anfima, Ricrea and Cial, has been translated into several languages and disseminated throughout Europe, unambiguously communicating the benefits and importance of proper separate collection of metal packaging.

Further information is available at: https://www.metalrecyclesforever.eu/.

 

Participation in an EPR system

 

CONAI trademark

Companies producing and using packaging can communicate their membership in CONAI - Consorzio Nazionale Imballaggi (National Packaging Consortium) by placing the CONAI trademark on their packaging.

The right to use the trademark is given, free of charge and upon request, to companies producing or using packaging, as defined in articles 35, paragraph 1, letters q) and r) of Decree 22/97, who have joined CONAI and have complied with the Consortium’s statutory and regulatory requirements.

The application procedure includes:

1. submission to CONAI of a special application form signed by the legal representative of the member company concerned;
2. evaluation by CONAI of the member company’s eligibility;
3. signing the license agreement;
4. registration of the agreement in the register of licensees held by CONAI.
   
   

COMIECO trademark

Click here to read the Consortium Regulations, inclusive of the rules regarding the Comieco trademark.

CiAl trademark              

The right to use the trademark is given to CiAl consortium member companies upon request.

 

 

What to include and how

 

How do I declare the recyclability of my packaging?

It is possible to declare the recyclability of packaging when it complies with the UNI EN 13430 technical standard.

This is a self-claim of the packaging producer, which is therefore responsible for what is declared, and must do so in the manner provided by UNI EN ISO 14021 regulating environmental self-declarations.

This standard also envisages a symbol to communicate the recyclability of the packaging: the Mobius Loop.

 

 

Self-declared claims may be verified and certified by an accredited certification body to ensure greater reliability of such declarations.

Example

If the packaging is a mainly paper-based composite material, its recyclability can be assessed by a recyclability test, which simulates the main steps of the industrial paper recycling process, in accordance with the procedure defined by UNI 11743:2019. The outcome of the test allows the recyclability level of the packaging to be identified according to the Aticelca 501/2019 recyclability evaluation system.

The system also makes it possible to communicate the level of recyclability obtained through the use of the special “Recyclable with paper – Aticelca® 501” label.

Example

How can I declare that my packaging is made from secondary raw material (recycled material)?

The claim of recycled material content in the packaging can be declared by the pack producer pursuant to the UNI EN ISO 14021 technical standard that regulates environmental self-declarations.

This standard envisages the use of the Mobius Loop symbol accompanied by a percentage that defines the amount of secondary raw material constituting the weight of the pack.

 

 

Self-declared claims may be verified and certified by an accredited certification body to ensure greater reliability of such declarations. 

Example

If, on the other hand, the intention is to communicate the presence of recycled material in the composition of the packaging through certification by an accredited third party and the respective label, there are several possibilities:

 

• For packaging of all materials: Remade in Italy®
  

  

   

• For plastic packaging: Plastica Seconda Vita ("Second Life Plastic")
  

  

   

• For paper or wood packaging: FSC Recycled® and PEFC Recycled®
  

  

  

How can I declare that my packaging is compostable?

Packaging can be declared to be compostable when it is certified by certification bodies as complying with the UNI EN 13432 technical standard.

Together with the certification of compostability, the third-party accredited body also grants the use of the special label that attests to achievement of the certification.

Below are the main label-logos of the certification bodies:

• The Italian Composters Consortium which, together with Certiquality, certifies biodegradable and compostable products with its “CIC Compostable” label.
  

  

   

• The TUV Austria group which issues the “OK Compost” label
  

  

   

• DIN Certco which issues the “DIN Geprüft Industrial Compostable” label
  

  

   

• The European Bioplastics Association which is certifiable by both Vinçotte and DIN Certco.