What is Packaging

Regulatory references – Legislative Decree No 152/06

European Directive 2004/12/EC on packaging and packaging waste (which amended and supplemented Directive 94/62/EC) was transposed into Italian law under Legislative Decree No 152/06 (pursuant to Legislative Decree No 22/97). Article 218 (definitions), paragraph 1, states that: “The following definitions shall apply for the purposes of this Title: a. packaging: all products made of any materials to be used for the containment, protection, handling, delivery and presentation of goods, from raw materials to finished products, from the producer to the user or the consumer, including non-returnable items used for the same purposes; b. sales packaging or primary packaging: packaging conceived so as to constitute a sales unit to the final user or consumer at the point of purchase; c. grouped packaging or secondary packaging: packaging conceived so as to constitute at the point of purchase a grouping of a certain number of sales units whether the latter is sold as such to the final user or consumer or whether it serves only as a means to replenish the shelves at the point of sale, and which can be removed from the product without affecting its characteristics; d. transport packaging or tertiary packaging: packaging conceived so as to facilitate handling and transport of goods, from raw materials to finished products, or of a certain number of sales units or grouped packaging to prevent physical handling and transport damage, excluding containers for road, rail, sea and air transport”. Moreover, Annex E, point 2, of Legislative Decree No 152/06 states that the definition of “packaging” shall be based on the following criteria: i)items shall be considered to be packaging if they fulfil the definition above without prejudice to other functions which the packaging might also perform, unless the item is an integral part of a product and it is necessary to contain, support or preserve that product throughout its lifetime and all elements are intended to be used, consumed or disposed of together; ii) items designed and intended to be filled at the point of sale and disposable items sold, filled or designed and intended to be filled at the point of sale shall be considered to be packaging provided they fulfil a packaging function; iii) packaging components and ancillary elements integrated into packaging shall be considered to be part of the packaging into which they are integrated. Ancillary elements hung directly on, or attached to, a product and which perform a packaging function shall be considered to be packaging unless they are an integral part of this product and all elements are intended to be consumed or disposed of together. The Ministerial Decree of 22 April 2014 (which transposed European Directive 2013/2/EU in Italy), published in the Official Gazette on 14/06/2014, updated the illustrative examples for the interpretative criteria set out in this annex.

 Many judgements have recognised Conai’s competence over contested items.

There are two reference lists below, by way of example but not limited thereto, of “packaging” or “non-packaging” items.

NB:

  • every item on these lists could also be made from different materials to the item potentially shown in the image;
  • explicit reference is made to any items which are covered by a flat rate or exempt from the Environmental Contribution or have special exclusions approved by consortium bodies.

Conai-Liste-Imballaggi – What is packaging

Conai-Liste-Non-Imballaggi – What is not packaging

 

 

“General Line” containers

“General Line” containers

Latte cilindriche e rettangolari, secchielli tronco-conici e cilindrici, bidoni, fustini, ecc.
“Open top” containers

“Open top” containers

Boxes/Jars.
“surprise” cases

“surprise” cases

Boxes for chocolate eggs and other containers that have the same function
Accessories bag

Accessories bag

Unless they are intended to contain the product/merchandise throughout its life cycle.
Adhesive tape - gummed paper used for packing

Adhesive tape - gummed paper used for packing

See specific procedure of declaration of the Conai environmental contribution, to be applied on 50% of the weight (Chapter 8, Conai Guide).
Aerosol cans

Aerosol cans

Bags - inflatable bags - “Air bags”

Bags - inflatable bags - “Air bags”

Bags for comforters, blankets, duvets, rugs, tablecloths and sheets

Bags for comforters, blankets, duvets, rugs, tablecloths and sheets

Beverage cans

Beverage cans

Big bags

Big bags

Bottles

Bottles

See facilitated procedure of application/declaration of the Conai environmental contribution as regards glass bottles, reserved for special cases (Chapter 8, Conai Guide)
Boxes and cartons

Boxes and cartons

Cable ties for packaging

Cable ties for packaging

Cake doilies sold with a cake

Cake doilies sold with a cake

Canned goods

Canned goods

Capsules

Capsules

Capsules for beverage systems (coffee, hot chocolate and milk) that are left empty after use, and capsules for beverage systems designed to be emptied manually by the consumer

Capsules for beverage systems (coffee, hot chocolate and milk) that are left empty after use, and capsules for beverage systems designed to be emptied manually by the consumer

In this latter case see Chapter 8, Conai Guide
Cigarette packs

Cigarette packs

Clothes hangers (sold with a garment)

Clothes hangers (sold with a garment)

For effective contribution7th October 2013.
Cocktail sticks/ice cream sticks

Cocktail sticks/ice cream sticks

Corks, stoppers, lids and miscelleneous coverings

Corks, stoppers, lids and miscelleneous coverings

For corks, see specific flat-rate procedure for the environmental contribution relating to corks (Form 6.17 and the accompanying instructions, Conai Guide).
Cosmetics case/powder compact/lipstick tube

Cosmetics case/powder compact/lipstick tube

Crates - boxes - chests/bins - cages

Crates - boxes - chests/bins - cages

See facilitated procedure of application/declaration of the Conai environmental contribution as regards plastic crates, reserved for special cases (Chapter 8, Conai Guide)
Cream tubes

Cream tubes

Depilatory wax container

Depilatory wax container

Detergent bottles

Detergent bottles

Device for measuring dosage, which forms part of the stopper of the pack for detergents

Device for measuring dosage, which forms part of the stopper of the pack for detergents

Dispensers

Dispensers

See specific procedure of declaration of the Conai environmental contribution as regards dispensers (Chapter 8, Conai Guide).
Dropper

Dropper

Drums

Drums

For drums made of plastic or regenerated steel, see simplified procedure for Conai application/declaration of environmental contribution (Chapter 8, Conai Guide)
Envelopes for coins/change

Envelopes for coins/change

Unless they are intended to contain the product/merchandise throughout its life cycle.
Flower pots intended to be used only for the selling and transportation of plants, and not intended to stay with the plant throughout its life time

Flower pots intended to be used only for the selling and transportation of plants, and not intended to stay with the plant throughout its life time

Garment bags in non-woven cloth

Garment bags in non-woven cloth

Glass bottles for injection solutions

Glass bottles for injection solutions

Graffette - Punti metallici, quando integrati nell’imballaggio

Graffette - Punti metallici, quando integrati nell’imballaggio

Hangers

Hangers

Generic and personalized - for shoes, scarves, socks, ties and bags
Hangers made from “iron wire”

Hangers made from “iron wire”

Generally used by laundries/ironing facilities
Isothermal bags for frozen foods

Isothermal bags for frozen foods

Jars - pots

Jars - pots

Jerry cans

Jerry cans

Labels

Labels

See specific flat-rate procedure for the environmental contribution relating to labels (Chapter 8, Conai Guide).
Lollipop sticks

Lollipop sticks

Mailing pouches for catalogues and magazines (with a magazine inside)

Mailing pouches for catalogues and magazines (with a magazine inside)

Mascara brush which forms part of the container closure

Mascara brush which forms part of the container closure

Match boxes

Match boxes

Mechanical grinders (non-refillable receptacles, e.g. pepper mills containing pepper)

Mechanical grinders (non-refillable receptacles, e.g. pepper mills containing pepper)

Multi-material canisters

Multi-material canisters

For regenerated multi-material canisters, see simplified procedure for Conai application/declaration of environmental contribution (Chapter 8, Conai Guide)
Octabins

Octabins

Packaging film

Packaging film

E.g.: stretch film, stretch, tubular, flat, shrink wrap etc.
Pallet cover

Pallet cover

E.g. net, hoods, sheets of film, etc.
Pallets

Pallets

See facilitated procedures of application/declaration of the Conai environmental contribution as regards wooden pallets, reserved for special cases (Chapter 8, Conai Guide)
Pans/trays used for packaging (not domestic)

Pans/trays used for packaging (not domestic)

Paper discs for the bottoms of pots/pans

Paper discs for the bottoms of pots/pans

Perfume bottles

Perfume bottles

Plastic disposable tableware (plates and cups) in packs, for professional (not domestic) use

Plastic disposable tableware (plates and cups) in packs, for professional (not domestic) use

Plates and cups in packs, for professional (not domestic) use. View list n° 2 of "non-packing" articles, for packages intended for domestic use.
Plastic film for garments cleaned in laundries

Plastic film for garments cleaned in laundries

Release paper of self-adhesive labels

Release paper of self-adhesive labels

This is a particular type of “packaging”, excluded from the Conai environmental Contribution.
Reusable bags (cabas)

Reusable bags (cabas)

This is a particular type of packaging, excluded from the Conai environmental Contribution.
Rolls of aluminium foil (packaged and not packaged) for professional (non-domestic) use

Rolls of aluminium foil (packaged and not packaged) for professional (non-domestic) use

View list n° 2 of "non-packing" articles, for packages intended for domestic use.
Rolls, tubes and cylinders around which flexible material (e.g. plastic film, aluminium, paper) is wound, except rolls, tubes and cylinders intended as parts of production machinery and not used to present a product as a sales unit

Rolls, tubes and cylinders around which flexible material (e.g. plastic film, aluminium, paper) is wound, except rolls, tubes and cylinders intended as parts of production machinery and not used to present a product as a sales unit

For effective contribution obligation and details, see Conai circular dated 29th March 2013
Sacks in general (valve sacks, open-mouth sacks, etc.)

Sacks in general (valve sacks, open-mouth sacks, etc.)

Sandwich bags

Sandwich bags

Seed tray

Seed tray

Shoppers (shopping bags) – bags

Shoppers (shopping bags) – bags

Spine di contenimento per CD - spindle (vendute con i CD, non destinate ad essere usate per riporli)

Spine di contenimento per CD - spindle (vendute con i CD, non destinate ad essere usate per riporli)

Sterile barrier systems (wrappers, trays and materials necessary to preserve sterility)

Sterile barrier systems (wrappers, trays and materials necessary to preserve sterility)

Strapping

Strapping

Strips of card for pot- and pan-handles

Strips of card for pot- and pan-handles

Supermarket trolley bags

Supermarket trolley bags

This is a particular type of packaging, excluded from the Conai environmental Contribution.
Sweet boxes

Sweet boxes

Transparent plastic films intended to be filled at the point of sale

Transparent plastic films intended to be filled at the point of sale

Various types of refillable gas receptacles

Various types of refillable gas receptacles

This is a particular type of packaging, excluded from the scope of the Conai environmental contribution (Chapter 8, Conai Guide)
Vials

Vials

Water bottles

Water bottles

Wooden spools for electric cables

Wooden spools for electric cables

Wrapping covering the cases of CDs, video cassettes, cassettes

Wrapping covering the cases of CDs, video cassettes, cassettes

Wrapping paper for non-domestic use Wrapping paper for non-domestic use

Wrapping paper for non-domestic use Wrapping paper for non-domestic use