Italy packaging labelling for non-EU sellers (etichettatura ambientale)

Every pack placed on the Italian market carries the material code of Commission Decision 97/129/EC, such as 1 PET or 41 ALU. A pack sold to a consumer also carries a collection instruction, which you write in Italian (Codice del consumo art. 9(1)). That is the etichettatura ambientale of D.Lgs. 152/2006 art. 219(5), with the collection instruction taken from the Ministry’s guidelines below. A pack for a business needs only the code. You can print the information or give it through an app, a QR code or a web page. Placing unlabelled packaging on the Italian market is fined EUR 5,000 to 25,000 (art. 261(3)). Since 12 August 2026 PPWR Art. 4(3) bars Italy from restricting PPWR-compliant packaging because it lacks additional national information, and the Commission reads it as barring fines for such requirements. What that means for the fine is under If you do nothing. The rule has no register, no fee and no representative.

The EU rule, the marks each country asks for and the sorting label that comes later are in packaging recycling symbols in the EU. This page is only what Italy adds. The other Italian rules are on the selling to Italy from the USA page. Registering and paying for packaging is on Italy packaging EPR.

The law is art. 219(5) of the Environmental Code, as D.Lgs. 116/2020 art. 3(3)(c) rewrote it. It says all packaging (“tutti gli imballaggi”) must be labelled under the applicable UNI technical standards and the Commission’s determinations, so that collection, reuse, recovery and recycling are easier and consumers know where the packaging ends up. Producers must also state the nature of the packaging material, on the basis of Decision 97/129/EC. The duties apply from 1 January 2023 (art. 219(5.2), inserted by D.Lgs. 213/2022, which also reworded the second sentence of art. 219(5) in art. 6(2)).

The environment ministry (MASE) set out how to meet it. Art. 219(5.1) told the minister to adopt technical guidelines by a decree that is not a regulation, and decree no. 360 of 28 September 2022 adopted them, replacing the first version of 16 March 2022. The guidelines apply from 1 January 2023 (MASE press release). They are guidance, not a statute. The rest of this page follows them where the statute is silent.

Do this, in this order

1. List every pack in the shipment. The product pack, each part the buyer can remove completely by hand and without tools (a cap, a sleeve, an inner bag), and the outer carton and fillers (guidelines).
2. Give each pack its material code from Decision 97/129/EC. The code table is in packaging recycling symbols. The Decision makes the code voluntary (Art. 3); Italy makes it a duty for every pack, packs for businesses included. The statute puts the duty to state the code on producers, and the next section says who that is. Label every pack you send yourself. Where the Decision has no code, use the Ministry’s fallbacks below.
3. On packs sold to consumers, add the collection instruction. The Ministry’s guidelines suggest two forms: the word “Raccolta” with the material family that weighs most, or that family with “Raccolta differenziata”. Both invite the buyer to check the municipality’s rules. Its example for paper: “Carta. Raccolta differenziata. Verifica le disposizioni del tuo Comune.” The wording is a suggestion and the statute fixes none. Write it in Italian: Codice del consumo art. 9(1) requires all consumer information at least in Italian, and art. 219(5) names no language and no collection wording.
4. Choose print or digital for the whole information. A digital channel is always allowed. Put the instruction on how to reach it on the pack, or on the product page of your shop.
5. Compostable plastic: add the compostability marks. Compostable and biodegradable packaging is collected with organic waste only if an accredited body certifies it to EN 13432 and it carries the mention of that standard, the producer, the certifier and instructions for the organic collection (art. 182-ter(6)).
6. Old stock: packaging bought or labelled before 31 December 2022 may be used up. Everything after that date carries the label. See the dates below.

What each pack carries

Source: guidelines. If a part has no room for its information, you may put it on the main body or the outer pack. Then you list each separable part, its code and its collection instruction. A composite pack, whose materials cannot be separated by hand, takes its code from Annex VII of the Decision, and its collection instruction follows the material that weighs most. One exception: a composite pack that is mostly paper but has less than 60% cellulosic material by weight cannot be recycled with paper, and the guidelines invite the business to suggest on the label the undifferentiated collection (“raccolta indifferenziata”). A secondary material under 5% of the pack’s weight is ignored, and the pack is labelled as a single material.

The guidelines do not say whether the carton of an online order sent to a consumer is a consumer pack or a business pack. That is a genuine gap. Print the code and the collection line on it: that meets either reading.

Where the Decision is silent, the Ministry suggests the next free number (guidelines):

You can give the information digitally

A digital channel (an app, a QR code or a website) is always allowed. It can replace the printed information or add to it. For a pack sold to a consumer, you show on the pack or at the point of sale, physical or virtual, how the buyer reaches the information. The page behind the code must be specific to that pack and easy to reach (guidelines). The decree itself says the mandatory information is given by technical means, digital ones included (DM 360 art. 1(3)).

Two cases have their own route in the guidelines:

• A pack with real physical limits, such as a largest surface under 25 cm2 or a capacity of 125 ml or less. The information goes through a digital channel, and where that cannot work, on the website of the company or the retailer.
• A pack for a business. The code can travel on the transport document or the papers that come with the goods.

No volume, turnover or size threshold exempts a pack (art. 219(5)).

Who must label a pack that comes from outside Italy

The duty to state the material code is the producers’: art. 219(5) says “i produttori” must state it, and the Ministry’s guidelines say that for the code the duty rests expressly on producers. Art. 218 counts suppliers of packaging material, makers, converters and importers of empty packaging and of packaging material as producers. A seller who buys packs and fills them is a user, as is an importer of filled packaging (art. 218(1)(r), (s)). The general duty to label (“tutti gli imballaggi”) names no addressee, and art. 261(3) fines anyone who places on the domestic market packaging without the art. 219(5) requirements. It treats a person who imports packaged goods for own use, outside a trade, as a consumer (art. 218(1)(v)). It has no definition of a distance seller, and no Italian text read says who the importer is when a business outside the EU ships a parcel straight to a consumer in Italy.

CONAI, the packaging consortium, reads the rule wider. Its FAQ says all packaging placed on consumption in Italy is subject, with no exclusion for imports (CONAI), and that packaging sold abroad and resold in Italy through e-commerce is subject too (CONAI). That is CONAI’s reading, not the statute. Label the packaging you send to Italian buyers as if the duty were yours, because art. 261(3) fines anyone who places it on the market, and no text read exempts a seller abroad.

Who is the producer for registration and fees is a different question, answered on Italy packaging EPR and, for the whole EU, in packaging EPR in the EU.

Dates and stock

Packaging that lacks the requirements and was already placed on the market, or already labelled, on 1 January 2023 may be sold until stock runs out. The text sets no end date. The Ministry reads “products” as the packaging, not the packed goods, and tests it by documents (guidelines):

• Packaging you bought from a supplier before 31 December 2022 qualifies by the date of the purchase document, even if it arrived later or sits in another country.
• Packaging you made or labelled yourself qualifies by the production lot of the pack or the label.
• A supplier’s unlabelled neutral packaging needs papers that carry the material information.

Packaging bought or labelled after that date gets no relief.

If you do nothing

The fine is EUR 5,000 to 25,000 for anyone who places packaging without the art. 219(5) requirements on the domestic market (art. 261(3)). D.Lgs. 196/2021 art. 15(3) replaced this sentence from 14 January 2022. Before, the earlier text of art. 261(3) applied to this duty the same EUR 5,200 to 40,000 range as the art. 226 bans. The Ministry’s decree recites the new sentence (DM 360). The province where the violation happened imposes it, and you challenge the order to pay in court (art. 262).

The text sets one range. It does not say whether each pack counts. CONAI’s FAQ presumes the fine is not added up pack by pack, and that many packs can justify a fine nearer the maximum (CONAI). That is CONAI’s presumption, not law.

Art. 261(3) says the fine is EUR 5,000 to 25,000. Since 12 August 2026 (Art. 71), PPWR Art. 4(3) bars Italy from restricting PPWR-compliant packaging because it lacks additional national information: Member States “shall not prohibit, restrict or impede the placing on the market of packaging that complies with this Regulation for reasons of non-compliance with those national requirements”. The Commission reads this as barring fines for such requirements (Commission FAQ, section XV, question 13: “fines are not allowed”). The FAQ names no country, and it is guidance, not law. Art. 261(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationThe whole regulationClick opens the law on the EU Publications Office. has not been amended since D.Lgs. 196/2021, and whether the fine falls under that reading is open. The same point for France and Spain is in packaging recycling symbols.

The EU label replaces this rule later

PPWR Art. 12(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 1Click opens the article on EUR-Lex. puts one harmonised label, based on pictograms, on the material composition of packaging other than transport packaging (e-commerce packaging stays in) and deposit-return packaging, from 12 August 2028 or 24 months after the entry into force of the Commission’s implementing act, whichever is later. The act was due on 12 August 2026 (Art. 12(6)). The Commission’s FAQ of August 2026 still describes it as an act to be adopted (Commission FAQ). A query of the Publications Office register of Official Journal acts on 6 October 2026 found, among the acts based on Regulation (EU) 2025/40Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationThe whole regulationClick opens the law on the EU Publications Office., no implementing act under Art. 12(6)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationThe whole regulationClick opens the law on the EU Publications Office.: the latest is the Commission’s own Notice C/2026/3084 of 10 June 2026. The register can lag the Official Journal. The Ministry’s own PPWR timeline gives the same rule: 12 August 2028 or 24 months after the act, if later (MASE). The date therefore falls after 12 August 2028.

What changes for you in Italy when it applies:

• The collection line. The Italian collection instruction is a national sorting instruction. The Commission reads Art. 12Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12Click opens the article on EUR-Lex. as fully harmonised: national rules that add sorting instructions are not allowed, and national labels may not stay next to the EU label. National measures on sorting instructions that might be judged disproportionate “should be repealed as soon as possible”, whatever the date of the EU label. Member States “are not allowed to adopt other national mandatory packaging labelling requirements” (Commission Notice, point 13; guidance, not law). The Notice names no country. The consolidated text of art. 219, with the act updated to 25 September 2026, holds no amendment since 16 June 2023.
• The material code. Decision 97/129/EC is repealed from 12 August 2028 (Art. 70(2)), and the Commission says its abbreviations are then no longer allowed (Commission Notice, point 13). Art. 8(2) of Directive 94/62/EC, which art. 219(5) builds on (guidelines), stays in force until 30 months after the label act (Art. 70(1)(a)).

The EU label’s online-sales rule, its language rule and its stock period are in packaging recycling symbols and PPWR.

CONAI’s notice says the current Italian labelling may be kept until 11 August 2028 and will then be replaced by the EU label (CONAI). That is CONAI’s reading. Until the act is published, no date is fixed. The full calendar of PPWR duties is in PPWR.

What the texts leave open

• When the Italian rule ends. No Italian text read sets an end date for art. 219(5). CONAI says 11 August 2028, and the PPWR text puts the EU label later while the act is missing. Meanwhile: label to the Italian rule, and plan to replace the code and the collection line when the EU label applies.
• Whether PPWR Art. 4(3) stops the art. 261(3) fine. The Commission FAQ says fines for additional national requirements are not allowed and names no country. Art. 261(3) has not been amended. Meanwhile: label to the Italian rule, because the fine is still written into the statute.
• Who the obliged business is for a parcel sent from outside the EU to an Italian consumer. No text names it. Meanwhile: label the packaging yourself.
• Whether the carton of an online order is a consumer pack. The guidelines do not say. Meanwhile: print both the code and the collection line.
• Whether Codice del consumo art. 9(1) governs the wording of the collection line. No official text says so in terms. Meanwhile: write it in Italian.
• How a province enforces the fine against a business with no Italian presence. No text read covers it. Meanwhile: the duty and the fine are written without that exception.

What does not apply

• A register, a fee or a representative. Art. 219(5) sets none for labelling. The representative clause of art. 178-ter(8) concerns a producer with its legal seat in another EU state and its entry in the national register of producers. It is on Italy packaging EPR.
• A fixed wording or layout. The Ministry says the business chooses form and way, as long as they serve the aim of art. 219(5) (guidelines).
• A mandatory symbol. Claims such as the Moebius loop for recyclability are voluntary self-declarations under UNI EN ISO 14021 (guidelines).
• Medicines and medical devices. The Ministry says the guidelines do not apply to them, because sector law already sets their duties (MASE press release).
• The product label. Art. 219(5) concerns the labelling of packaging for waste management and is separate from any labelling of the product inside (guidelines).