Statement regarding the use of alphanumerical codes for the identification of packaging materials as defined by the Commission Decision 97/129/EC
Driven by responsibility for the planet, its people, the nature and its resources, many efforts are being made today to improve the environmental performance and circularity of the packaging materials, to facilitate the reuse of already available resources and to guide raw material suppliers, manufactures and end consumers on the communication about their materials and products along the value chains.
The EU packaging and Packaging Waste Directive 94/62/EC1 and its amendments, together with the amended EU Waste Framework Directive 2008/98/EC2 provide the basis and define the governance hierarchy for waste management on European level.
Directive 94/62/EC defines the EU-wide rules on managing packaging and packaging waste. In order to prevent the generation of packaging waste, the Directive sets the targets of the recycling of used packaging for the EU Member States. By these means, the Directive encourages the reuse, recycling and other forms of recovering of packaging waste and aims to improve the quality of the environment by preventing and reducing the impact of packaging and packaging waste on the environment – thus contributing to the transition towards a circular economy in the environmentally friendly manner. To enable the proper sorting of collected waste, to facilitates the collection, reuse, recovery and recycling of packaging, the identification symbols for the nature of the packaging has been established in Europe by the Decision 97/129/EC3. This decision introduces the alphanumerical codes for various natures of packaging materials – ANNEX I of 97/129/EC introduced Numbering and abbreviation system for plastics, ANNEX II – Numbering and abbreviation system for paper and fiberboard, with the corresponding annexes III – VIII for metals, wood materials, textile materials, glass and finally composite materials.
In particular, for paper and paperboard, the following alphanumerical codes are specified in Annex II of 97/129/EC:
- Corrugated fiberboard PAP 20
- Non-corrugated fiberboard PAP 21
- Paper. PAP 22
According to Article 3 of 97/129/EC, the use of alphanumerical codes is, inter alia, voluntary for the paper and fiberboard materials mentioned in Annex II. In accordance with the procedure referenced to in Article 21 of Directive 94/62/EC, it may be decided whether the identification system for one or more materials is to be introduced on a mandatory basis.
Article 4 of 97/129/EC states that the Decision is addressed to the Member States. National legislative documents per Member State shall define whether the use of the alphanumeric codes will becomes mandatory. On September 3, 2020, Italy has published Legislative Decree No. 116 and made mandatory material coding of all packaging entering the Italian market as per January 1st 20224. However, originally from January 1st 2022, this deadline has been extended till January 1st 2023, together with the possibility of marketing stocks of products already placed on the market or labeled and purchased before 31 December 20225.
Following the above-mentioned extended deadline, the Italian Ministry of Ecological Transition (Ministero della transizione ecologica) in collaboration with CONAI (the Italian National Packaging Consortium), developed and published the guidance “Labelling for packaging – Guidelines according to Art. 219 paragraph 5 of Legislative Decree 152/2006 and subsequent modifications and integrations” 6-7
(hereafter ”The Guidance”) to support companies with operational and management decisions to fulfill their regulatory obligation regarding the labelling of packaging destined for the Italian market. This document was subjected to a public consultation and several updates in light of constant dialogue and discussions with companies and associations, as well as following regulatory developments on the subject. The latest update of the above guidance is dated November 21, 2022 and is followed by Ranpak in defining Ranpak’ position, steps and actions on fulfillment of the obligations under Italian Legislative Decree No. 116 from September 3, 2020, as set forth in the present statement published by Ranpak at the end of December 2022.
Please be aware that in accordance with the latest edition of the above mentioned Guidance, “packaging – even if empty – that has been labelled (e.g., already printed, or for which the label has already been produced/applied) before 31 December 2022 or packaging that has been purchased by packaging users from their suppliers before 31 December 2022, can be marketed. Also, according to the Guidance, “if the packaging was purchased before 31 December 2022, it can be marketed even if the stocks are held in another country. The date of purchase of the packaging is the decisive criterion in this case”
Ranpak, a company providing protective packaging solutions made of paper, herewith confirms that all paper converted and supplied by Ranpak for its protective packaging solutions, is entirely within the category “Paper” as defined in Annex II of the Commission Decision 97/129/EC. Consequently, PAP22 is the proper alphanumerical code for all Ranpak protective packaging solutions. This information is also available on the Materials Safety Data Sheets of all Ranpak products and can be freely requested at Ranpak at any time.
Delivery of Ranpak paper products
For delivery, Ranpak paper products are transported on pallets with a wooden base, alphanumerical code FOR50, according to Annex IV, of the Commission Decision 97/129/EC. Pallets themselves are wrapped in thin plastics film, alphanumerical code LDPE4 (suppliers information), according to Annex IV, of the Commission Decision 97/129/EC.
The packaging system on a pallet consists of either a number of larger paper rolls (PAP22) with a noncorrugated fiberboard core (PAP21) which is closed in the center by a plug (HDPE2), or a number of packs consisting of paper (PAP22) within the so-called L-shape (PAP21) and a sealing strap (PP5) around each L-shape.
Figures 1 and 2 provide a schematic visual illustration of possible packaging system on a pallet, as well as for the proper alphanumerical codes for each material used in the packaging system. For the application of abovementioned alphanumerical codes reference is made to the Annexes I, II and IV from the Commission Decision 97/129/EC.
In addition, Ranpak is implementing the appropriate alphanumerical codes on stickers and L-shapes for
purchases that will be made per 01 January 2023 onwards. In the meantime, Ranpak continues using the current stock of stickers and L-shapes printed and purchased before 31 December 2022. Proof of purchase will be provided upon explicit request. Furthermore Ranpak will provide a list of its products, their related packaging material(s) as well as the corresponding alphanumerical codes on Ranpak’ distributor portal.
Finally, on the transportation documents Ranpak will indicate a reference regarding material and packaging information of Ranpak products to its distributor portal.
For any inquiries in this respect you are kindly requested to submit your questions by sending an e-mail to email@example.com for the attention of the Quality/Legal Departments of Ranpak.
Disclaimer: This document presents the current opinion of Ranpak based on best available knowledge and practices from both external and internal resources, and independent external expert advice. This opinion can change in view of evolving discussions on the subject matter described above. No legal rights can be derived from this statement.
1 EUR-Lex – 32018L0852 – EN – EUR-Lex (europa.eu)
2 EUR-Lex – 32018L0851 – EN – EUR-Lex (europa.eu)
3 EUR-Lex – 31997Do129 – EN – EUR-Lex (europa.eu)
4 Guidelines for the environmental labeling of packaging – Environmental labeling for packaging (etichetta-conai.com)