Italy and France – Environmental Labelling of Cosmetic Products
PACKAGING WASTE MANAGEMENT

Date of application:01/01/2023

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 packaged 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). (further reading in 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) and for the end consumer (B2C)

– 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)

This information must be displayed in Italian.

The Italian Packaging Private Consortium CONAI and the Italian Institute of Packaging have issued Guidelines on environmental labelling. These Guidelines provide some examples of environmental labelling in order to help companies to comply with the Decree.

Source: CONAI and Italian Institute of Packaging Guidelines

The Italian environmental labelling obligation is applicable as of January 1, 2023. Packaging already placed on the Italian market or labelled before 1 January 2023 may be marketed until stocks last.

FRANCE – ANTI-WASTE LAW

The French Anti-Waste Law, also known as 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. (further reading in previous publication)

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

The French packaging take-back scheme (CITEO) released a Guideline regarding sorting information aiming to help producers to adjust the packaging labelling in order to be compliant with French requirements.

Since January 2022, the Triman Logo is mandatory and shall be included 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 instructions for each type of product. Any other signs that might confuse consumers regarding the sorting rules should be removed. (further reading in previous publication)

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.

The French environmental labelling obligation is applicable as of January 1, 2023. A transition period was granted until 9 March 2023, for packaging produced or imported before 9 September 2022.

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

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?

further
reading

news & updates

EU Ecolabel adoption and recognition are on the rise

The Ecolabel certification is a comprehensive program focused on fostering sustainable practices. It evaluates products based on life cycle assessments, where every phase of said life cycle must abide by strict standards to attain the Ecolabel certification. The overarching objective of this certification is minimizing environmental harm from production or consumption activities.

Read More »
news & updates

SCCS preliminary opinion on Citral sensitization endpoint

Ingredients: CITRAL

Date of publication: 27/03/2024

On March 27 2024, the Scientific Committee on Consumer Safety (SCCS) published the Preliminary Opinion on the safety of Citral in cosmetic products. The deadline for comments is set to June 2, 2024.

Read More »
cosmetic products

UK proposes ban of wet wipes containing plastic 

The UK has proposed, on April 24, 2024, a regulation titled The Environmental Protection (Wet Wipes Containing Plastic) (England) Regulations 2024, to the World Trade Organization (WTO). The regulation aims to eliminate the supply and sale of plastic-containing wet wipes, including cosmetic ones. The public can offer comments on the draft until June 23, 2024, with adoption expected in September of the same year.

Read More »
medical devices

Safety Reporting in Clinical Investigations: a Gap Analysis of Guidance Documents 

Safety reporting in clinical investigations of medical devices shall be performed in line with Article 80(2) of the EU MDR. On May 2020, it was published the MDCG 2020-10/1, outlining the procedures for safety reporting in clinical investigations of medical devices under the EU MDR. However, on October 2022 the Medical Device Coordination Group (MDCG) published an updated version of the MDCG 2020-10/1, the MDCG 2020-10/1 Rev 1. This article highlights the updates included in the new revision, analysing the gaps between both documents.

Read More »
medical devices

Roles and Responsibilities of an Authorised Representative under EU MDR and IVDR 

If a medical device manufacturer is not established in a Member State, the devices can only be placed on the Union market if the manufacturer designates an authorised representative. The authorised representative plays a pivotal role in ensuring the compliance of the devices with EU regulation, serving as point of contact. The obligations and responsibilities of authorised representative are outlined on Article 11 of both MDR and IVDR, but clarification of relevant requirements is described in MDCG 2022-16 of October 2022.

Read More »
medical devices

Understanding the ISO Standards Lifecycle

ISO Standards cover a huge range of activities, representing the distilled wisdom of people with expertise in their subject matter and providing the regulators with a sound basis to develop better legislation. ISO Standards are diverse, addressing from the shoe size we wear to the quality of air we breathe. The medical device sector is no exception. ISO has many International Standards and guidance documents aimed at helping the sector ensure safe and effective medical devices while meeting the multitude of national, regional and international regulatory requirements. But how exactly is a Standard developed, reviewed and withdraw?

Read More »
medical devices

Amendments to the Transitional Provisions of the European Union MDR and IVDR

The proposed amendments aim to maintain patients’ access to a wide range of medical devices while ensuring the transition to the new framework. The ammendments proposal aims to extend the current transition period (Article 120 of the MDR), and it also deletes the ‘sell-off’ deadlines of both MDR and IVDR. The extension is staggered depending on the risk class of the device – until December 2027 for high-risk devices and December 2028 for medium and lower-risk devices.

Read More »
medical devices

EU MDR – Proposal for Extension of Transition Period

The transition to MDR has been slower than anticipated by the European Commission. Insufficient capacity of notified bodies and the low level of preparedness of manufacturers led to a proposal for extension of current MDR transition period with deadlines depending on the risk class of the devices.

Read More »
medical devices

MDCG 2022-18 – EU MDR Article 97

EU MDR Article 97 may be a temporary solution to avoid disruption of supply of Medical Devices on the EU Market. The MDCG 2022-18 presents a uniform approach for application of MDR Article 97 on non-compliant legacy devices under the conditions set by the competent authorities, while limiting the impact on the supply of safe and effective devices.

Read More »