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With Ministerial Decree (dated 18 September 2024, published in the Official Journal on 26 September), the Ministry of Agriculture imposes starting from 1 July 2025 the obligation for olive traders di register on SIAN e deliver the batches to the mills within six hours of acquisition by the olive growers. The measure is part of the implementation of art. 9 of Law 206/2023 on Made in Italy, with the declared aim of increasing transparency, traceability and quality in the virgin olive oil supply chain.
The doubts
The provision, however, raises doubts and criticisms from the world of logistics and agricultural trade. According to several operators, the Time restrictions are excessively rigid and inapplicable in inter-regional contexts.
Just think of a buying and selling between Puglia or Calabria and Liguria, but simply too in Lazio, where i Travel times easily exceed six hours, even without considering the mandatory stops for professional drivers imposed by the Highway Code and European legislation.
The law, then, does not distinguish between small local businesses and inter-regional operators, penalising the latter.
I mills they are not subject to the same obligations if they purchase olives directly and then resell them. This opens the way to a possible unfair competition, with traders forced to operate under less favourable conditions.
The penalties
The principle of the free market, protected by both Italian and Community legislation, could be unduly limited by such a rigid time constraint.
Although the decree does not directly specify the sanctions, please refer to the general provisions set out in the Ministerial Decree of 10 November 2009 and subsequent amendments (Ministerial Decree of 23 December 2013, Ministerial Decree of 8 July 2015), which outline the obligations to maintain the electronic register of oils. In the event of violation of the provisions on traceability and registration administrative pecuniary sanctions may be triggered and, in the event of false registrations or declarations, even criminal sanctionsFailure to update records in a timely manner may result in suspension or limitation of business activity.
Il the decree requires the trader to record the time of acquisition (rounded to the next hour) and the time of transfer; note this data in the “Notes” field of the telematic codes provided, respect the maximum deadline of 6 hours for delivery to the mill and for registration on the SIAN. In the case of mixed lots (purchases from multiple olive growers), the time runs from the time of the first acquisition.
Till today, the decree does not impose a symmetrical obligation on the oil mills who buy olives to resell them or process them later. This element introduces a structural disparity that could favor vertical integrations and penalize intermediate figures, traditionally fundamental for market balance.
In my opinion, this rule, if not accompanied by adequate flexibility or exemptions for distances exceeding a certain limit, could cause a contraction of the network of independent olive traders; an increase in the bargaining power of integrated mills; a logistical and organizational difficulty for companies operating on a national or international scale.
Certainly these provisions should be reviewed with the introduction of exemptions for distances greater than 100 or 200 km.
Se the intent of the decree is legitimate, to improve traceability and guarantee quality, its practical application risks creating imbalances in the olive market, that is, in the agricultural and commercial phase that precedes the transformation into oil. Without changes or clarifications, the risk is that the provision will create more problems than solutions, in a sector that is already fragile and strategic for the Italian agri-food economy.
