🇮🇹 Italy: CONAI labelling deep dive

Italy CONAI labelling guide: legal anchor + practical implementation

Italy requires environmental labelling on all packaging placed on its market. This guide separates what the law requires (Art. 219(5) of D.Lgs. 152/2006, implemented by DM 360/2022) from what CONAI provides as implementation tools.

Legal anchor: Art. 219(5) D.Lgs. 152/2006 + DM 360/2022 guidelines.
B2C vs B2B: different labelling rules for consumer and trade packaging.
PPWR transition: current Italian format valid until 11 August 2028.

Last checked: 29 March 2026 • Guidance only • Always verify final artwork with counsel/PRO.

Legal requirement vs industry convention

Many packaging "rules" online are actually PRO templates or industry conventions. This page separates what the law requires from what is commonly recommended.

Required by law

Obligations explicitly set in legislation or binding implementing acts.

Common convention

Widely-used templates and pictograms that may help compliance, but are not always mandated as a format.

What PPWR Copilot outputs

A practical draft aligned to the law, with conventions clearly labelled.

What the Law Requires Today

Legal anchor: Art. 219(5) of D.Lgs. 152/2006. DM 360 of 28 September 2022 adopted the official guidelines.

Consumer-facing packaging (B2C)

→ Material identification code (per Decision 97/129/EC) + collection/disposal instructions in Italian are required.

B2B packaging

→ Material identification code is required. Disposal instructions can be in accompanying documentation.

Space-constrained packaging

→ CONAI acknowledges digital channels (QR code, URL) as acceptable when physical space is insufficient. Material code should still appear on-pack where feasible.

Safe claim: The formal legal anchor is Art. 219(5) of D.Lgs. 152/2006, with DM 360/2022 adopting the official guidelines. CONAI states that these official guidelines substantially reflect the CONAI guidance businesses had already been using.

What CONAI Helps You Implement

CONAI’s support materials are implementation tools, not the law. CONAI states that the official DM 360/2022 guidelines substantially reflect the CONAI guidance businesses had already been using.

CONAI says companies can use digital channels to transmit mandatory information.
Etichetta CONAI platform — online labelling tool
CONAI FAQs — practical answers for common scenarios
e-tichetta tool — digital labelling channel support

B2C vs B2B: Different Rules

B2C (consumer-facing)

Material code + disposal instructions on-pack.

B2B (trade/industrial)

Material code required. Disposal instructions can be in accompanying documentation.

Material-Code Examples by Component

Component	Material Code
Cardboard box	PAP 21
Corrugated board	PAP 20
PET bottle	PET 1
HDPE cap	HDPE 2
PP tray	PP 5
Glass jar	GL 70
Steel can	FE 40
Aluminium tube	ALU 41

Is "Verifica le disposizioni del tuo Comune" Mandatory?

CONAI confirms this phrase is optional. It is common practice, not a statutory requirement.

What Changes Under PPWR / 12 August 2028

CONAI’s PPWR FAQ states that the current Italian format can remain until 11 August 2028, or for collection indications until the relevant implementing acts take effect. After that, the harmonised EU label framework under PPWR takes over.

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Worked Example: Italian Pasta Producer

A practical example showing how the rules apply to real packaging.

An Italian pasta producer packs spaghetti in a cardboard box (PAP 21) with a plastic window film (PP 5, making up 3% of total packaging weight). Because the plastic component is below the 5% threshold, the packaging is classified as PAP 21 (cardboard), not composite. The label shows: "PAP 21 — Raccolta Carta" with optional "Verifica le disposizioni del tuo Comune." The producer could also add a QR code linking to digital disposal instructions, particularly useful for export variants where physical label space is shared across multiple markets.

Designed for real packaging

Component-aware guidance (bottle + cap + label, boxes with inserts, films, cartons) — not generic "one icon fits all".

Built for audit trails

Outputs include clear assumptions and a "verify before printing" stance. You keep final legal sign-off.

Save hours per SKU

Stop copy-pasting between spreadsheets, slide decks, and outdated guidance PDFs. One tool, one output.

FAQs

Short answers for teams who just need clarity, not a 200-page briefing.

Is CONAI’s labelling format legally required?

The information content (material code + disposal instructions) is legally required under DM 360/2022. CONAI’s specific format and templates are implementation tools, not the legally mandated format.

Can I use a QR code instead of printing disposal text?

CONAI acknowledges digital channels as acceptable for transmitting mandatory information. A QR code can supplement the label when physical space is insufficient. The material identification code should still appear on-pack where feasible.

Does "Verifica le disposizioni del tuo Comune" need to appear on my packaging?

No. CONAI confirms it is optional. It is widely used as good practice but is not a legal requirement.

When can I stop using the Italian labelling format?

The current Italian format can remain until 11 August 2028 per CONAI’s PPWR FAQ, or for collection indications until the relevant EU implementing acts take effect. After that, the harmonised EU label applies.

How does the CONAI 5% threshold work for composite packaging?

When a secondary material makes up less than 5% of the total packaging weight, CONAI/MASE guidance treats the packaging as the primary material type. Above 5%, the packaging is classified as composite.

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