La normativa sanzionatoria degli imballaggi, definiti in gergo tecnico M.O.C.A. (Materiali ed Oggetti a Contatto con gli Alimenti), disciplinata per molti anni dal Decreto del Presidente della Repubblica n. 777 del 23 agosto 1982 e già modificato nel ‘92, ha visto nel mese di aprile di quest’anno (dopo ben 35 anni!), un importante rinnovamento legislativo.
Dal 2 aprile, infatti, è entrato in vigore il Decreto Legislativo n. 29 del 10 febbraio 2017 “Disciplina sanzionatoria per la violazione di disposizioni di cui ai regolamenti (CE) n. 1935/2004, n. 1895/2005, n. 2023/2006, n. 282/2008, n. 450/2009 e n. 10/2011, in materia di materiali e oggetti destinati a venire a contatto con prodotti alimentari e alimenti”, con il quale saranno applicate ammende che potranno raggiungere anche importi significativi, comminate a tutti coloro che operano nelle filiere. Per un valore pari a 80.000 €, ad esempio, nel caso di produttori che possono creare pericoli per la salute umana, o per valori massimi di 25.000 € nel caso di etichettatori di prodotti o verso tutti coloro che possono indurre in errore il consumatore circa l’impiego sicuro e corretto dei materiali, mediante pubblicità.
Tra le novità del nuovo Decreto, che avrà il compito di regolamentare e sanzionare tutte le violazioni relative agli obblighi derivanti dai diversi Regolamenti che hanno definito e armonizzato la legislazione comunitaria in materia di MOCA negli ultimi anni, si può osservare (nell’art. 13) modifiche DPR n. 777/82 con l’abrogazione di alcuni articoli in esso contenuti e nello specifico: l’art. 2, l’art. 4 con i relativi commi 1, 2, 3, 4, 6, 7 e 8, l’art. 5-ter e l’art.7.
La norma, infine, prevede anche le condizioni di applicazione nel caso di violazioni di lievi entità (art.11).
Nel caso di accertamento da parte dell’organo preposto (organi che esercitano poteri di accertamento nella materia oggetto del presente decreto a norma delle leggi vigenti, ma anche ufficiali e agenti di polizia giudiziaria che procedono a norma della Legge 689/1981- art. 13) di una o più violazioni di lieve entità, infatti, lo stesso procederà con una contestazione diffidando il trasgressore a regolarizzare le violazioni ed indicando non solo le eventuali prescrizioni necessarie per ottemperare alla diffida, ma ponendo anche termini temporali trascorsi i quali, l’organo preposto verificherà l’effettiva ottemperanza alla diffida stessa.
Nel caso di osservanza della diffida si procederà pertanto all’estinzione degli illeciti, in caso contrario seguirà la contestazione e la notificazione della violazione con conseguente irrogazione della sanzione.
Segue un focus della normativa maggiormente rappresentativa nell’ambito dei MOCA:
- Il Reg. CE n. 852/2004 s.m. – Norme generali sull’ igiene dei prodotti alimentari;
- Il Reg. CE n. 1935/2004 s.m. – regolamento quadro – riguardante i materiali e gli oggetti destinati a venire a contatto con i prodotti alimentari;
- Il Reg. CE n. 1895/2005 restrizioni dell’uso di alcuni derivati epossidici in materiali e oggetti destinati a entrare in contatto con prodotti alimentari;
- Il Reg. CE n. 2023/2006 s.m. – buone pratiche di fabbricazione dei materiali e degli oggetti destinati a venire a contatto con i prodotti alimentari. Indicate anche con la sigla G.M.P. (Good Manifacturing Practices). Regolamento nato per portare uniformità in un settore che, fino a poco tempo fa, non era tenuto a dimostrare di dover operare secondo “le buone prassi”;
- Il Reg. CE n. 282/2008 – relativo ai materiali e agli oggetti di plastica riciclata destinati al contatto con gli alimenti (che modifica il Reg. CE 2023/2006);
- Il Reg. CE n. 450/2009 s.m. – materiali attivi e intelligenti destinati a venire in contatto con gli alimenti;
- Il Reg. UE n. 10/2011 e ss. mm.- riguardante i materiali e gli oggetti di materia plastica destinati a venire a contatto con i prodotti alimentari;
- Decreto Ministeriale 21 marzo del 1973 e ss.mm – Disciplina igienica degli imballaggi, recipienti, utensili, destinati a venire in contatto con le sostanze alimentari o con sostanze d’uso personale.
© Produzione riservata
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Dr.ssa Sabina Rubini
Biologa – Esperta in Sicurezza degli Alimenti
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