Paolo Bonamigo – ASSOVERNICI
The coatings industry is facing a significant acceleration in regulatory developments which, while providing clear direction, is making the transition towards a more sustainable economy increasingly complex for companies. This is highlighted by Assovernici, the association representing the decorative and industrial coatings sectors. These sectors employ approximately 15,000 people in Italy and generate an estimated annual turnover of € 3.5 billion, with production volumes exceeding one million tonnes.
One of the most pressing challenges is the new PPWR (Packaging and Packaging Waste Regulation), which addresses packaging and packaging waste. Introduced with the aim of reducing packaging volumes while promoting recycling and reuse, its practical implementation is creating significant operational challenges for coatings manufacturers and could potentially disrupt the functioning of the single market.
From conformity declarations for each type of packaging to requests for detailed information to suppliers, as well as the difficulties involved in obtaining the necessary documentation from non-EU manufacturers, the administrative burden is steadily increasing. Furthermore, since waste management remains the responsibility of individual Member States, companies areincr easingly confronted with a growing layer of bureaucratic requirements.
While established recycling streams are already in place for materials such as PET, the coatings industry frequently relies on multi-material packaging, such as metal combined with paper. Overly stringent requirements could therefore make compliance with recyclability criteria particularly challenging and could have significant implications for packaging used for dangerous goods.
The annual reporting obligation for microplastic emissions is another requirement that companies need to take into account, as it will require adequate resources and training. CEPE, the association representing manufacturers at European level, is currently developing a calculation methodology to estimate emissions, in an attempt to provide operators with a standardised method by the end of the year, so that they can be prepared for the reporting deadline set for 31 May 2027.
With regard to the revision of the EU Environmental Crime Directive, Assovernici is calling on industry operators to remain particularly vigilant, as the revised legislation strengthens administrative penalties while broadening the scope of liability.
The protection of companies must extend beyond the internal management of emissions or spills to include outsourced activities, such as the transportation of dangerous goods and waste disposal. This is not an issue that concerns technical personnel alone; it directly involves company management.
For this reason, in order to support its members, Assovernici is planning a webinar with a lawyer specialising in environmental law, which will also address the revision of the CLP Regulation (Classification, Labelling and Packaging), commonly referred to as the “CLP Omnibus”.
The “Stop the Clock” clause has in fact postponed the main deadlines until January 2028, providing some additional breathing room for products already on the market. According to Assovernici, despite some positive aspects, such as the new advertising rules replacing the requirement for pictograms with clearer warning statements, significant issues remain. The introduction of a minimum font size for labels, combined with the requirement to include all the languages of the target markets, will force manufacturers to redesign their labels or, alternatively, use more costly multi-page labels, consequently increasing warehouse stock levels and the associated additional costs.
Another issue that should not be underestimated, for the increasingly stringent regulations, is unfair competition, fuelled by the limited controls on goods imported from non-EU countries, particularly through e-commerce platforms. Despite the attention shown by the European Environment Council and the efforts of the ECHA Enforcement Forum to prepare inspection programmes for the online sales channel, the first official control programme specifically targeting imported products is not scheduled until 2028. This delay risks undermining the competitiveness of European companies vis-à-vis their non-EU competitors.
On the innovation front, there is also a slowdown in the largescale adoption of sustainable and bio-based raw materials. Despite intensive research and development efforts, their uptake remains largely limited to small-scale trials. Moreover, the current focus on price, exacerbated by the challenges affecting global supply chains as a result of international tensions, prevents these products from commanding a price premium, putting them at a disadvantage both in the consumer market and in public procurement.
Acting as a compass and operational partner for companies seeking to navigate the regulatory maze, including through dedicated meetings and information sessions, the association is sending a clear message to industry entrepreneurs in light of this substantial body of regulatory requirements: these obligations need to be addressed from a strategic perspective, turning them into an opportunity to rationalise product portfolios and identify competitive levers.
The need to analyse packaging documentation, reports and declarations of conformity in detail can serve as a starting point for developing and communicating concrete, data-driven sustainability strategies, enabling companies to differentiate themselves from competitors and strengthen their position in the market.
