Labelling obligation for packaging in Italy comes into force on 01 January 2023


Labelling obligation for packaging in Italy comes into force on 01 January 2023
For EPAL pallets and other transport packaging, the indication of the recycling code FOR 50 in the transport documents is sufficient.

On 01.01.2023, the law on the labelling of packaging will come into force in Italy. To simplify and improve recycling, the packaging material must be identified on all packaging by indicating the recycling code. This also applies in principle to EPAL pallets and other wooden load carriers, which must be marked with the recycling code FOR 50.

However, an exemption applies to transport packaging such as EPAL pallets.
The Italian Ministry of Environment and Energy Safety has confirmed in a decree dated 21.11.2022 that transport packaging that is predominantly used in business-to-business (B2B) transactions does not have to be marked with the recycling code if the recycling code is instead indicated in the transport documents. This regulation also applies to digital transport documents.

For the delivery of EPAL pallets to Italy and also for the transport of goods on EPAL pallets to Italy, the obligation to either indicate the recycling code FOR 50 in the transport documents or to use EPAL pallets marked with the recycling code FOR 50 will therefore apply from 01 January 2023.
This obligation does not apply to those EPAL pallets that have been marked or sold before 01.01.2023. Violations of the labelling obligation can be punished with a fine. It is currently not known that a comparable labelling obligation exists or is planned in other European countries. Should this change, we will inform you.

EPAL has already amended the Technical Regulations for EPAL pallets in March 2021 and allowed the marking of EPAL pallets with the recycling code "FOR 50" applicable to wood. The marking can be on the centre block of the long side, on the blocks of the short side or on the top of the EPAL pallets.
Users of EPAL pallets are therefore free to choose whether to use pallets marked with the recycling code FOR 50 or to indicate the recycling code FOR 50 alone in the transport documents instead of marking the pallets.

It is recommended by EPAL to always indicate the recycling code FOR 50 in the transport documents when delivering or using EPAL pallets in Italy or when transporting goods to Italy.
Especially when using and delivering used EPAL pallets, it is difficult to ensure that all pallets are marked with the recycling code FOR 50. With the standardised indication of the recycling code in the transport documents, problems with the contract partners and the Italian supervisory authorities can be avoided. It can therefore be assumed that the routine indication of the recycling code FOR 50 in the transport documents when using EPAL pallets and other transport packaging made of wood will become established in the movement of goods in and to Italy.

Various industry associations recommend that their member companies use only pallets marked with the FOR 50 recycling code. This is also intended to avoid problems arising in the relationship between supplier and customer, as many companies are currently not yet aware of the exemption to state the FOR 50 recycling code in the transport documents. Many manufacturers of EPAL pallets therefore already mark the newly produced EPAL pallets with the recycling code FOR 50.
Further information on the mandatory labelling of packaging in Italy can be found in a guideline issued by the Ministry of the Environment and Energy Safety, which can be accessed via the following weblink:

www.mite.gov.it/sites/default/files/archivio/normativa/rifiuti/GUIDELINES_for_the_environmental_labelling_of_packaging_27.09.2022.pdf

For questions regarding the labelling of EPAL pallets with the recycling code "FOR 50", users of EPAL pallets can contact EPAL International or directly the EPAL National Committees and Representatives in the different countries.