Environmental Labelling of Cosmetic Products in Italy and France
Although the European Cosmetics Regulation is applicable to every cosmetic product made available in the European Union market, some national legislations may also apply. Environmental regulations in Italy and France specify mandatory labelling requirements applicable to products marketed in these countries.

ITALY – LEGISLATIVE DECREE Nº 116

The Italian Legislative Decree nº152 of April 2006 has been amended by the Legislative Decree nº 116 of 3 September 2020. This Decree has presented new requirements concerning disposal information that must be reported on the labelling of products (including cosmetic and personal care products, medical devices and food supplements). (see previous publication)

The Legislative Decree nº 116 states that is mandatory to clearly indicate on the labelling the following information:

  • The nature of the packaging materials used, indicating the alphanumeric code according to Decision 97/129/EC
    • Applicable to packaging intended for professional activity (B2B circuit) and for the end consumer (B2C circuit)
  • Indications concerning the separate collection, reuse, recovery and recycling and correct information to consumers on the final destination of packaging.
    • Applicable to packaging provided to the end consumer (B2C circuit)

This information must be displayed in Italian.

The national packaging private consortium CONAI and the Italian Packaging Institute have issued Guidelines on environmental labelling. These Guidelines suggest some examples of environmental labelling in order to help companies to comply with the Decree.

Source: CONAI and Italian Institute of Packaging Guidelines

The environmental labelling obligation has been suspended until December 31st 2022.

Packaging already placed on the market or labelled before 1 January 2023 may be marketed until stocks last.

FRANCE – ANTI-WASTE LAW

The French Anti-Waste Law, also called, AGEC law (Loi relative à la lute contre le gaspillage et a l’économie circulaire), contains about 50 measures that include new obligations (requirement of transparency), new prohibitions (control of irreversible ecological ambitions) and new tools to better control and sanction offences against the environment. (see previous post)

Cosmetic and personal care products that are made available on the French market also need to comply with Anti-Waste law.

The French packaging take-back scheme (CITEO) released their Guideline regarding sorting information. The aim is to help producers to adjust the packaging labelling in order to be compliant with French regulation.

Since January 2022, the Triman Logo is mandatory and shall be indicated on the product, its packaging or on the documentation provided with the product. This legal obligation also applies to products sold online to France. It needs to be accompanied by the information on the sorting process for each type of product. Any other signs that might confuse consumers regarding the sorting rules should be removed. (see previous post)

Source: CITEO

The Triman Logo should be printed in black and white, with a minimum size of 6 mm, and it can not be superimposed by other visual elements or be smaller than symbols printed alongside it. The information regarding the material and the sorting process needs to be in French (including on e-commerce), as this is a specific obligation for the French market.

A transition period was granted until 9 March 2023, for packaging produced or imported before 9 September 2022.

For more information on environmental labelling, do not hesitate to contact us at info@criticalcatalyst.com.

References:

  1. Decreto Legislativo 3 settembre 2020, n. 116. Attuazione della direttiva (UE) 2018/851 che modifica la direttiva 2008/98/CE relativa ai rifiuti e attuazione della direttiva (UE) 2018/852 che modifica la direttiva 1994/62/CE sugli imballaggi e i rifiuti di imballaggio. (20G00135) (GU Serie Generale n.226 del 11-09-2020)
  2. CONAI and Italian Institute of Packaging Guidelines. Available at: http://www.progettarericiclo.com/en/docs/environmental-labeling-packaging
  3. LOI nº 2020-105 du 10 février 2020 relative à la lutte contre le gaspillage et à l’économie circulaire. Journal Officiel de La République Française. 11 février 2020 – https://www.legifrance.gouv.fr/download/pdf?id=tIvlngK1-pPYKGFzbZJvgnB0La5rYk6ys5dm_FwTPZs=
  4. Ministére de la Tansition Écologique Et Solidaire – The Anti-Waste Law in the Daily Lives of the French People, What Does That Mean in Practice? – https://circulareconomy.europa.eu/platform/sites/default/files/anti-waste_law_in_the_daily_lives_of_french_people.pdf

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