Italy
The Italian catch most foreign sellers miss
Packaging EPR in Italy runs on the Testo Unico Ambientale (D.Lgs. 152/2006, Part IV), and its packaging duties work through the mandatory CONAI system under article 221. So far, so familiar.
The catch is who actually owes the money. A foreign EU producer without an Italian establishment usually has no direct CONAI duty at all. The environmental contribution is declared and paid by the Italian importer or first buyer that places the goods on the market.
That is the opposite of what many sellers assume, and it flips only in one case, which the rest of this page builds toward.
The CONAI route step by step
Where a CONAI duty does fall on you, membership is the compliance vehicle, not a separate register like the RENAP streams. You file a membership application (adesione) with company data, packaging types, materials and expected quantities, then join or use an approved autonomous system.
Reporting follows annually. Packaging volumes placed on the market are declared through the MUD, the annual environmental declaration, typically due by 30 April for the previous year, alongside CONAI's own declaration calendar.
The cost picture in Italy
The money comes in three layers.
- Membership: joining CONAI (or an approved autonomous system) is the entry duty, with simplified procedures for smaller producers.
- The CAC: the Contributo Ambientale CONAI is a per-material contribution, set separately for steel, aluminium, paper, wood, plastic, glass and bioplastic.
- Eco-modulation: more recyclable packaging can qualify for a reduced CAC, so the rate rewards better design.
CONAI updates the CAC rates each year through its governing body, so Italy does not publish one flat figure. Through EPR in Italy packaging is the heaviest stream to budget for.
Distance sellers and Italy
For a foreign seller the practical question is simple: is there an Italian importer or first buyer in the chain? If yes, the CONAI duty is theirs.
If you sell direct to Italian consumers by e-commerce, it is yours, and there is no separate authorised representative step, because CONAI membership is the mechanism itself.
Enforcement runs under the D.Lgs. 152/2006 penalty provisions with MASE supervision, and CONAI can add surcharges for late declarations. Marketplaces may also ask for EPR registration numbers as their own policy rather than Italian law.
From national law to EU rules in Italy
The near-term change is not national but European, and the PPWR reaches the product itself, not just how it is reported.
Single-use plastic items that are also packaging already run through CONAI, so those producers pay through the same route. The wider picture is covered on single-use plastics EPR in Italy.
Frequently asked questions about Italian packaging EPR
The points packaging sellers raise most often about the Italian rules.
Who has to register for packaging EPR in Italy?
Producers and importers established in Italy that place packaging on the market join CONAI (or an approved autonomous system). A foreign EU producer without an Italian establishment usually has no direct duty, because the Italian importer or first buyer declares and pays the contribution.
Is there a threshold or exemption for small producers?
CONAI offers simplified procedures for smaller producers, but the duty to join is not waived. There is no exemption that removes membership altogether for those placing packaging on the Italian market.
Do foreign or online sellers need an authorised representative in Italy?
There is no separate authorised-representative step, because CONAI membership is the mechanism. A foreign seller only joins CONAI directly when selling packaged goods to Italian consumers by e-commerce, or by voluntary adhesion. Otherwise the Italian importer carries it.
What happens if I sell without registering?
Where a CONAI duty applies and is not met, the D.Lgs. 152/2006 penalty provisions apply under MASE supervision, and CONAI can levy surcharges for late declarations. Marketplaces may also block listings until an EPR number is shown.
What changes next for packaging EPR in Italy?
The PPWR applies directly from 12 August 2026 and changes the packaging itself, not just reporting. The CONAI contribution system continues underneath it, with CAC rates and eco-modulation reviewed each year.
