Does the law allow the use of digital technology?
In the Guidelines released on November 21st, on page 19 it says: “The use of digital solutions to fulfil the obligation of environmental labelling of packaging (e.g. App, QR code, websites) is allowed, in line with the process of technological innovation and simplification, a fundamental aspect envisaged in the National Recovery and Resilience Plan (PNRR). Such digital channels can completely replace or supplement the information indicated directly on the packaging."
Is the digital label complete?
The Digital Environmental Label is exhaustive. In the CONAI Guidelines, on page 19, it says: "The use of digital solutions to fulfil the obligation of environmental labelling of packaging (e.g. App, QR code, websites) is allowed, in line with the process of technological innovation and simplification, a fundamental aspect envisaged in the National Recovery and Resilience Plan (PNRR)."
Not only our label is exhaustive, but it goes far beyond the requirements set out in Legislative Decree 116/20 and the CONAI Guidelines. In fact, it also provides accurate geolocated disposal information for every Italian municipality, thanks to the GPS-system of the smartphones. An impossible feature for a paper label.
Does the digital label replace the material symbols?
In the case of products intended for the final consumer, the Digital Environmental Label fully replaces the material symbols, even with more information.
Which wording should be associated with the barcode?
The minimum and sufficient wording to be printed next to the barcode is: "Read the barcode with Junker app to get the disposal info of this packaging". Minimum font size 6.
Is the barcode a new one or the one already on the product's packaging?
It is the official product's barcode: EAD uses it to identify the specific product and display the disposal information for its packaging.
If I choose the barcode option, do I have to add something else on the packaging?
MiTE (Italian Ministry for Ecological Transition) and CONAI (Italian Consortium for Packaging) agree on three options: a brief sentence next to the barcode (in our case: "Scan the barcode with Junker app to get the disposal information); a notice at the point of sale; a virtual notice (i.e. on the website/e-commerce).
In the CONAI Guidelines, on page 19, it says: "If the packaging is intended for the final consumer, the party subject to the obligation is required to provide, on the packaging or at the point of sale (that can be physical or digital), clear indications on how the consumer can search for the mandatory information through digital tools or websites (App, QR code, websites, etc.). Alternatively, these instructions can be shared and made available through traditional or digital communication channels, initiatives or campaign promoted by companies or with the collaboration and contribution of representative trade associations."
What is the minimum size of the qrcode to be printed on the labels and with which wording?
It is advisable to never go below the size of 1 cm per side. It must be easy for the consumer to understand that by reading the QRcode you can access the environmental information. It can be included in the logo of the virtuous circuit with the green leaves proposed by Junker and the words "digital environmental label", or you can put a sentence such as: "Read the QRcode for disposal info" (minimum font size: body 6)
What is the difference between a QR code given by Giunko and a QR code produced by us?
While a usual QR code refers to a webpage, our QR code refers to an information sheet for a specific product that is created dynamically and relates the information about the product's packaging with the waste disposal rules of the Municipality where the user is located. Such information is, therefore, geolocated. This aspect makes EAD unique and represents the excellence of this solution offered by Giunko.
Are QR codes ready to print and customize?
Yes, they are ready to print and customize, both in size (we suggest not to drop below 1x1 cm sideways) and colors, to adapt to the packaging style. They cannot be either cut or changed visually.
If I choose the QR code option, do I have to add something else on the packaging?
The QR code given by Giunko is inside a circle with the sentence "Disposal information", in Italian or in three languages (IT-EN_FR) and that is enough to comply with the law. If you erase the circle, the same indication given for the barcode applies in this case as well.
What is intended with "reference"?
With reference we refer to a QR code, a barcode, or a amily QR code. You can read the description for each solution on our website, under the menu entry EAD Solutions.
What is a "products' family"?
A group of products, slightly different from each other, which have the same packaging. For instance, perfumes or wine bottles: the content might differ, while the packaging, thus the Digital Environmental Label, is the same.
Who is a "reviser"?
The reviser is an expert for environmental labeling from our team, who will oversee the uploaded products and the packaging materials.He/she will check if the Digital Environmental Label is correct and coherent with the actual packaging.
Is there an expiration date for the purchased references?
Yes, each reference is valid for one year. The customer purchases the right to use our platform, not its property. This means that, once the reference is expired, if the purchased license is not renewed, the product will be automatically eliminated from the platform.
How can I check the expiration date of my contract?
You can view the expiration date of your contract directly from the Account menu of the EAD portal.
Do all references have the same price?
Yes. It does not matter if the identification of the product happens via barcode, a QR code or a "family QR code", the unit cost is the same.
If the packaging changes during the year, what should I do?
You just need to enter the portal with your data (username and password), change the details, and save. EAD is automatically updated. This is the great advantage of a digital solution.
Is EAD valid for those products that are exported abroad?
EAD by Giunko is already available in 11 languages and thus ready for the market abroad.
To be compliant with the law of other countries, EAD geolocates the country where the user is located and displays the disposal information according to the local rules. The extension to countries other than Italy, however, is not operative because of the lack of specific legislation in other countries. France is the only EU country that has implemented its own legislation on environmental labeling, but does not allow a digital version for those packaging larger than 20 cm (by side). For further information, please get in contact with us.
How to manage warehouse stocks?
On May 21, 2021, the conversion law no. 69, of the decree law 22 March 2021 n. 41, so-called DL Sostegni. Among the changes made in the process of converting the decree, there is also the suspension of the obligation of environmental labeling of packaging until 31 December 2021. Then, only the disposal of stocks is allowed, provided that it is demonstrated that they have been printed / purchased by this date (must be proven with official documentation: delivery notes, invoices etc.)
Which packaging can be distributed after December 31st, 2022?
According to the Guidelines of the Ministry for the Ecological Transition, released on November 21st, 2022 (pages 41-42):
1. Products without an environmental label that were distributed and/or already labelled before January 1st, 2023, until stocks are
2. Stocks of packaging, also empty, that are not compliant with the new requirements before January 1st, 2023, until stocks are exhausted.
3. Packaging that was purchased until December 31st, 2022.
Which documentation can prove that the stocks in question can be distributed?
The date of marketing authorization of the packaging can be traced through the purchase documentation. In case you purchase from a supplier packaging that is already labelled, which means the label has been already printed, the date of such documents is considered proof of it, even if the goods are delivered to the customer on a later stage. It is important that you can prove to have purchased the packaging before December 31st,2022.
Can stocks of packaging in storage in third countries be distributed?
If the packaging is purchased before December 31st, 2022, it can be distributed, even if the stocks are in third countries. The date of the purchase documentation is considered proof.
What are the authorised digital channels? How to use them?
In the Guidelines released by the Ministry for the Ecological Transition, on page 19 it says: “If the packaging is intended for the final consumer, the party subject to the obligation is required to provide, on the packaging or at the point of sale (that can be physical or digital), clear indications on how the consumer can search for the mandatory information through digital tools or websites (App, QR code, websites, etc.). Alternatively, these instructions can be shared and made available through traditional or digital communication channels, initiatives or campaign promoted by companies or with the collaboration and contribution of representative trade associations.
In order to make the environmental labelling information available, it is possible to use a digital channel that refers to a page specifically dedicated to conveying the contents on the environmental labelling concerning the specific packaging, as long as access to this information is simple and the information is precise and easy to interpret. It is advisable to show and differentiate as much as possible each specific packaging under consideration on these channels, in order to make it easier for the final consumer to find and consult the information about each specific packaging.”
What is an EAD Iframe?
It is possible to include the EAD of a product in the webpage of the product itself, thanks to the Iframe given by Junker. In this way, the Digital Environmental Label will complete the product's description on the product's website.
What are the properties of an Iframe?
Do the nutritional values vary based on the alcohol content? Whether the wine is white or red? What do the ingredients of the wine mean?
The presentation format of nutritional values and ingredients is the same for all wines, whether red or white. The general regulations of the FIC (Food Information to Consumers) apply to the ingredient list format, as there are no specific rules for wine. The list should include a title with the word "ingredients," display ingredients in descending order of weight, and designate them by their specific names. The regulations also allow exceptions, such as using "grapes" for raw materials.
Does the regulation apply to the 2024 harvest and related labels?
As a general rule, the new mandatory labeling requirements apply to wines placed on the market from the respective application date set by Regulation (EU) 2021/2117, which is December 8, 2023. Wines "produced" before this date can continue to be marketed under the applicable labeling requirements before December 8, 2023, until stocks are depleted. For example, wine (category 1) is a product obtained solely from the total or partial alcoholic fermentation of fresh grapes, crushed or not, or grape must. The same applies to sparkling wine (category 4) produced by a second alcoholic fermentation.
Source: Questions and answers on the implementation of the new EU provisions on wine labeling following the amendment of Commission Regulation (EU) No 1308/2013 of the European Parliament and of the Council and Commission Delegated Regulation (EU) 2019/33.
In the case of bulk wine sales, does the legal labeling go on the containers containing the bulk?
According to Article 2 of the FIC Regulation, "mandatory food information" refers to the information that must be provided to the final consumer, regardless of the container in which the food is marketed. This provision applies to wine as well.
Are aromatized drinks based on wine subject to the same labeling directives as wine?
Yes, they follow the same regulations as wine regarding nutritional and ingredient labeling.
Is digital labeling also valid in non-EU countries? If yes, are the rules the same for all states or do they vary depending on the exporting country?
The nutritional label is regulated by a European regulation, mandatory for all Member States. Therefore, it must be translated into the marketing languages.
Environmental labeling is not yet mandatory in all member states (currently in Italy, France, Bulgaria, among others), and the rules vary from country to country. Electronic versions are not always accepted (e.g., in Bulgaria and Germany).
More information on the CONAI website: https://www.etichetta-conai.com/faqs/dove-e-possibile-accedere-a-informazioni-circa-disposizioni-di-etichettatura-ambientale-del-packaging-in-altri-paesi-europei/
Is a 2019 vintage wine, to which 15% of the same wine from the 2016 vintage is added, a new product subject to the new nutritional labeling regulations?
What matters for compliance with labeling rules is when the aforementioned wine is ready for marketing: before or after December 8? If the answer is after, not only is it obligatory, but the values of the wine obtained from the blend of the two vintages must be indicated.