Key takeaway
What This Development Means
Italy says packaging and labels produced or purchased before 27 September 2026 may qualify as old stock. The ministry's six-month horizon is non-binding guidance, and businesses must still correct consumer information through reasonable and proportionate measures.
Does Italy Provide A Six-Month Legal Grace Period For Packaging And Labels?
No. The ministry describes six months as an indicative exhaustion horizon. It is administrative guidance, not a statutory exemption. Businesses must still take reasonable and proportionate steps to correct or supplement consumer information and should document why continued use of each stock line is defensible.
Which Packaging Can Qualify As Old Stock In Italy?
Packaging and labels produced or purchased before 27 September 2026 may qualify, including material later used for durable or perishable goods. Companies should retain dated evidence and consider stock volumes, packaging cycles, prior orders and feasible corrective measures. Goods manufactured or packaged before that date may also qualify.
Source basis: Italian Ministry of Enterprises and Made in Italy, Directive (EU) 2024/825 FAQs (last modified 1 October 2026)
Italy has clarified how Directive (EU) 2024/825 packaging stock may be handled after the strengthened consumer-protection rules began applying on 27 September 2026. The Ministry of Enterprises and Made in Italy FAQs, modified on 1 October, state that packaging and labels produced or purchased before that date may fall within an old-stock situation and may continue to be used for durable and perishable goods.
Italy Directive 2024/825 Packaging Stock Guidance Expands The Old-Stock Approach
The clarification adds operational detail to the ministry's 27 August circular. It does not amend Legislative Decree No 30 of 20 February 2026, which implemented Directive (EU) 2024/825 in Italy. The decree and the wider EU framework already apply to business-to-consumer practices.
The FAQs define an existing product broadly. It includes goods placed on the market before 27 September and goods manufactured and packaged by then, even if they are commercialised later. A perishable good has a shelf life of no more than 30 days, while a durable good has a longer shelf life. Businesses must be able to demonstrate the relevant production, packaging or purchase date.
Six Months Is Guidance, Not A Legal Exemption
The ministry says the horizon for exhausting qualifying products should remain within the indicative six-month period described in its earlier circular. This is not a fixed statutory grace period, and it does not make a misleading environmental claim lawful.
Companies must still take every reasonable and proportionate step to inform consumers correctly. The FAQs refer to factors in the Consumer Protection Cooperation network's common understanding, including packaging cycles, stock volumes and purchase or production orders already placed. Corrective measures may include over-labelling, covering a claim, point-of-sale notices or online information where appropriate.
The underlying EU approach supports proportionate enforcement where genuine transitional difficulty exists. Foresight's earlier analysis of EU green claims old stock explains why this does not create a Union-wide sell-through exemption.
Implications For Manufacturers, Importers And Retailers
Manufacturers and brand owners should link each retained packaging version to dated purchasing or production evidence and assess the claims printed on it. Importers and distributors need records showing when goods or packaging entered the relevant supply chain. Retailers should align shelf material, product pages and marketplace listings with any corrective action.
Italy has extended the old-stock analysis beyond finished goods to unused packaging and labels. This may reduce avoidable waste, but it also moves the compliance question from a simple cut-off date to a documented proportionality assessment under the Green Claims framework.
Businesses should create an Italian stock register covering packaging version, production or purchase date, claim risk, volume, shelf life, expected exhaustion date and any corrective consumer information.
Summary
Italy's ministry says qualifying pre-27 September packaging and labels may continue to be used under a documented old-stock approach. The suggested six-month horizon remains non-binding, so businesses still need evidence, proportionate corrective measures and accurate consumer information for each retained stock line.
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