Since September in Italy the 116/2020 legislative decree has been applicable and modifies the 152/2006 decree as well as the european waste legislation (UE 2018/851) and (UE 2018/852). 

The new legal obligations about sustainable labels

This decree has a major impact on all producers since cosmetic packaging must contain environmental labels. The law establishes:

All packages must be correctly labeled according to the precedents established by the applicable UNI technical laws and obeying all laws adopted by the European Union in order to facilitate and agilize the recycling, reusing and waste management. Furthermore, to offer the appropriate information to consumers regarding their circular approach, so they can recycle items correctly and don’t end up in landfills. 

So, what do we have to do?

The alphanumeric code that identifies material and represented by the circle Möbius symbol must be adherent to the package of each product for the end consumer. 

These are the main materials used for products from Molpack:

The new decree expects that the labelling of the different packaging parts that the consumer can manually separate with no tools needed. 

For example, if the consumer has a PET bottle with a PP cap, we can consider both components as easy to separate, therefore, both components must have a label with the Möbius circle.

Another example would be with an HDPE bottle and a PP cap. Or if we have lipstick with different components such as a background and ABS cap.

What do we have to do when packaging has different components from different materials that cannot be separated such as plastic seals, internal mechanisms and similar?

For instance, a PET bottle with PP cap equipped with a Tri-seal gasket. The gasket can’t be manually separated, we need a tool that allows us to elevate it and seperate it from the cap. 

If the pieces cannot be separated manually and they are made of different materials, the law states that:

If the weight of the component is less than 5% of the total weight, it can be considered MONO material and therefore it may be labeled according to the composition of the major component. 

If the components’ weight is superior than 5% of the total weight, it can be considered MULTIMATERIAL and must be classified with the 07 OTH symbol. 

Going back to the inital example of the PET jar with PP cap and Tri-seal gasket:

If the weight of the Tri-seal gasket is inferior to the 5% weight of the CAP, the Cap must be cosidered as a unique material and therefore, be labeled with the 05 PP Möbius symbol. 

If on the contrary, the weight of the Tri-seal gasket is superior to the 5% of the total weight of the cap, the cap is considered multimaterial and must be labelled with the Möbius 07 OTH symbol. 

The decree also promotes the supply of information to the end consumer about the correct elimination of packages. 

Example: Separate collection + family material. Consult the recyclers of your city. 

This obligation was extented to the 31st of december of 2021 by the Milleproroghe Decree. Nevertheless, the obligation to indicate, identify and classify the packages and its materials is currently applicable.