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Italy: a mandatory material code, and destination in words
Legislative Decree 152/2006, Article 219(5), requires all packaging to be labelled to Union technical determinations and obliges producers to identify packaging materials under Decision 97/129/EC. Packaging intended for consumers must also give collection information. Digital and documentary delivery is a flexibility, not an exemption. The alphanumeric code is mandatory in Italy and voluntary in Spain. The Decision is repealed at Union level from 12 August 2028.
The question this report answers
Article 219(5) of the Environmental Code (Testo Unico Ambientale), as substituted by Legislative Decree 116/2020, has two sentences that must not be collapsed. The first requires all packaging to be labelled according to applicable UNI technical standards and Commission determinations, so as to facilitate collection, reuse, recovery and recycling and to give consumers correct information on final destinations. The second requires producers, for identification and classification, to indicate the nature of the packaging materials used on the basis of Decision 97/129/EC. Article 219(5.2) deferred the duties to 1 January 2023. Stocks already labelled or placed on the market by that date may be exhausted.
Ministerial Decree No. 360 of 28 September 2022 adopted the technical guidelines required by Article 219(5.1), built on CONAI’s proposal. Those guidelines are the operational specification: alphanumeric codes on every pack, including business-to-business formats; consumer packs additionally carry collection-fraction information, commonly “Raccolta plastica”, “Raccolta carta”, “Raccolta vetro”, “Raccolta organica” or “Raccolta indifferenziata”, often with the municipal-variation formula “Raccolta differenziata. Verifica le disposizioni del tuo Comune.” There is no unique government pictogram. The Italian duty is composition coding plus, for consumers, a destination in words — the inverse of Spain’s Royal Decree 1055/2022 Article 13, which makes the destination mandatory and the 97/129 code voluntary.
Legal status at a glance
| Requirement | Status | What it is |
|---|---|---|
| Decision 97/129/EC material code | mandatory | All packaging, including B2B. PET 1, HDPE 2, PAP 20/21/22, GL 70, FE 40, ALU 41, C/PAP 81 and the rest of the Decision’s list. Manually separable components are coded separately. |
| Consumer collection information | mandatory for consumers | Name the collection fraction and, where collection varies, direct the consumer to municipal rules. Not required on industrial or commercial packaging. |
| B2B / small-pack delivery | mandatory; flexible form | Guidelines accept transport documents, technical sheets or digital channels where physical marking is not feasible. The information duty remains. |
| Triman or Spanish bin pictogram | not an Italian duty | A yellow-bin pictogram without a 97/129 code does not satisfy Article 219(5). |
| PPWR / 97/129 repeal | adopted | Decision 97/129/EC is repealed from 12 August 2028. Italy’s identification duty cannot rest on that Decision after that date. |
The alphanumeric code as the core of the Italian duty
The code identifies composition for waste operators and for the consumer’s destination information. It does not prove recyclability, local acceptance or recycled content. Each manually separable component should be assessed. A code on the main body does not describe a cap, sleeve, label or barrier layer of a different material. Composite packaging follows the family and predominant material in the Decision and the guidelines. Secondary and tertiary packaging and other B2B formats are inside the identification duty even when they never reach a household. UNI standards are referenced in the first sentence of Article 219(5). They are operationalised by the 2022 guidelines rather than by a separate UNI-number obligation printed on every pack. CONAI examples are illustrative. They are not a statutory artwork file in the Citeo sense. Language on consumer packs is Italian.
Article 219(5), second sentence, names producers for the 97/129 identification. Article 218 defines producers as suppliers of packaging materials, manufacturers, converters and importers of empty packaging, and utenti as fillers, users, traders, distributors and importers of filled packaging. CONAI’s FAQ treats composition information as a producer output that must travel down the chain, with physical affixing a shared producer/user duty allocatable by contract. Article 261(3) sanctions “chiunque immette nel mercato interno” packaging lacking the Article 219(5) requirements. Cite the article rather than a single euro figure: published consolidations and CONAI FAQs currently state different ranges, and the live Normattiva text of Article 261 should be checked before a penalty quantum is used.
Collection information in words, not a bin pictogram
Packaging supplied to final consumers must support separate collection. Ministry and CONAI guidance commonly pair the material code with “Raccolta” and the waste fraction. Because collection is organised municipally, the formula directing the consumer to local rules is the legally cautious companion to a named fraction. The Italian mark is still a composition-plus-fraction system, not a bin-colour system. Putting only a coloured container pictogram on an Italian household pack, without the alphanumeric code, does not discharge Article 219(5).
The guidelines treat physical marking as the default. Digital carriers, accompanying documents and outer-transport marks are accepted for neutral packaging, very small packs, pre-packed variable-weight goods and B2B formats where physical marking is not feasible. Practical notes sometimes mention thresholds in the region of 25 cm² or 125 ml; those figures are guideline practice, not a statutory pair comparable to France’s 10/20 cm² rule. A QR code is not a general opt-out from Article 219(5).
Spain as the inverse rule, and the 2028 sunset
A pack sold in both Italy and Spain often carries both the 97/129 code (needed in Italy, harmless in Spain) and a destination instruction (needed in Spain for household packs, and needed in Italy in words for consumers). The legal characterisation still differs. In Italy the code is the mandatory core; in Spain it is voluntary until Union law provides otherwise. After 12 August 2028 the Decision disappears. Commission Notice C/2026/3084 treats extra national sorting text as something that must yield to the Article 12 pictogram once that pictogram applies. From 12 February 2027, Article 12(9) confines identification of EPR participation to a digital carrier. That digital-carrier rule is about EPR identification, not about the Italian alphanumeric code. A 2026 Italian pack still has to carry the code. It also has to be planned against a 2028 identification sunset.
Primary sources and verification
Italy. Legislative Decree 152/2006, Article 219. Normattiva
Italy. Article 219 consolidation. Brocardi
MASE. Linee guida sull’etichettatura ambientale, adopted by DM 360/2022. Guidelines PDF
CONAI. Environmental labelling documents and obligated-party FAQ. CONAI
European Union. Commission Decision 97/129/EC. EUR-Lex
European Union. Regulation (EU) 2025/40, Article 70(2). PPWR
Italian-language legislation and the MASE guidelines control. Last verified: 21 August 2026.