Case history

Pelliconi & C.

Target: By-product qualification 


Pelliconi & C., a world leader in the production of crown caps, metal and plastic closures for the bottling industry. Its global sales and distribution network has four foreign subsidiaries that have enabled the group to be recognised as one of the world’s largest producers and exporters of crown caps.  

The group recycles more than 97% of its production waste each year, and at the same time has launched numerous projects to combat climate change, to support local and international communities, and to guarantee its employees stability and safety in the workplace. 

In light of the above, Pelliconi & C. was looking for new channels to valorise some of its production waste and required external support to assess the existence of all the necessary requirements to include this waste as a by-product and to prepare the administrative paperwork for the possible registration of the by-products with the Chamber of Commerce, Industry, Crafts and Agriculture.  

Circularity’s support for qualifying process residues as by-products was divided into 3 steps:   

Technical-administrative feasibility analysis to assess the possibility of identifying production waste as by-products, as it complies with regulatory criteria

Preparation of the administrative paperwork for the by-product technical file that meets all the following conditions of Art. 184-bis of Legislative Decree 152/2006

Identification of the plant or activity or destination for the by-product to be reused in partial substitution of raw materials in a new production cycle


Pursuant to Article 184-bis of Legislative Decree No 152 of 3 April 2006, the residues referred to in Article 2(1)(b) are by-products and not waste when the producer demonstrates that, since they were not produced voluntarily and as the primary purpose of the production cycle, they are intended to be used in the same or a subsequent process, either by the producer himself or by a third party.   

For this purpose, at each stage of the management of the residue, proof must be provided that all of the following conditions are met:   

(a) the substance or object arises from a production process of which it forms an integral part and whose primary purpose is not the production of that substance or object   

(b) the use of the substance or object in the same or a subsequent production or use process by the producer or a third party is certain   

(c) the substance or article can be used directly without any further processing other than normal industrial practice   

(d) the further use is lawful, i.e. the substance or object fulfils, for the specific use, all relevant product, health and environmental protection requirements and will not lead to overall adverse environmental or human health impacts; 

DECREE No. 264 of 13 October 2016 – Regulation setting out indicative criteria to facilitate the demonstration of the existence of the requirements for the qualification of production residues as by-products and not as waste – defines certain methods by which the holder can demonstrate that the general conditions set out in Article 184-bis of Legislative Decree No. 152 of 3 April 2006 are met. 

qualifica sottoprodotto


Aluminium is an excellent, infinitely recyclable circular material that can be transformed by reintroducing the material into the production cycle.  

Through recycling and melting, aluminium from ‘by-product aluminium’ can then be reused to produce new raw material.  

An important aspect to emphasise is that aluminium does not lose its qualities as a result of this process. Thus, aluminium from recycled aluminium is no different from that obtained from the original ore (bauxite) and its fundamental characteristics remain unchanged.  

In addition, recycling aluminium saves 95% of the energy needed to produce it from the ore: to obtain 1 kg of aluminium from bauxite requires 16 kW/h, while to obtain 1 kg of new aluminium from used aluminium requires 0.4 kW/h. 


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