Italy EPR
Provinces
Packaging
Provinces
Packaging
About
Packaging
About
Packaging
Packaging
Packaging
What is Italy EPR Packaging
Italy operates a mandatory Extended Producer Responsibility (EPR) system for packaging under:- Legislative Decree No. 152/2006 (Environmental Code)
- EU Packaging legislation (currently transitioning toward PPWR framework)
- Register with CONAI
- Declare packaging quantities
- Pay environmental contribution (Contributo Ambientale CONAI – CAC)
- Ensure recycling targets are met via the national system
Does this apply to e-commerce & online sales
Yes. Italy applies EPR rules regardless of the sales channel. If you sell packaged goods to customers in Italy — including via cross-border e-commerce — you may qualify as the obligated producer. Distance sellers shipping directly to Italian end users can fall within scope if they are considered the entity placing packaging on the Italian market. Online marketplaces do not automatically assume producer responsibility (unless they qualify as importer or first placer).Who is the “producer” under Italy EPR?
Under Italian law, obligated entities may include:- Manufacturers of packaging
- Manufacturers of packaged goods
- Importers of empty packaging
- Importers of packaged goods
- Entities introducing packaged goods from another EU Member State
- Distance sellers supplying directly into Italy
Who must register for EPR packaging in Italy
Entities placing packaging or packaged goods on the Italian market must:- Register with CONAI
- Determine applicable material consortia
- Submit periodic packaging declarations
- Pay the CONAI Environmental Contribution (CAC)
Italy EPR Packaging Registration Threshold
Italy does not provide a general exemption from registration. However:- There is a simplified procedure for small quantities
- Micro-importers placing very low volumes may benefit from simplified annual declarations
Make your first declaration within 24 hours
Easy to use EPR Software
Packaging Covered (and Excluded)
Covered All packaging types are covered, including:- Primary packaging
- Secondary packaging
- Tertiary (transport) packaging
- Steel
- Aluminium
- Paper
- Wood
- Plastic
- Glass
Exclusions
Items not classified as packaging under EU definitions are excluded. Reusable packaging follows specific reporting rules. Producer Responsibility Organization (PRO) Italy operates a centralised national model. The system is managed by:- CONAI (National Packaging Consortium)
- Six material-specific consortia (e.g. COREPLA for plastics, COMIECO for paper)
EPR Registration in Italy
The compliance process generally involves:- Registering with CONAI
- Determining packaging material categories
- Setting up reporting method (ordinary, simplified, or flat-rate where applicable)
- Submitting periodic declarations (monthly, quarterly, or annually depending on volume)
- Paying environmental contributions
Authorized Representative
Italian law does not establish a standalone “authorized representative” regime specifically for packaging. However, foreign companies not established in Italy typically:- Appoint a local representative
- Use a fiscal representative for VAT-related alignment
- Engage a compliance service provider
What Data Must Be Reported
Producers must report:- Weight of packaging placed on the Italian market
- Breakdown by material type
- Packaging type (primary, secondary, tertiary)
- Imports vs domestic production
First Reporting Period
Obligations apply from the moment packaging is first placed on the Italian market. The first reporting period begins with the first transaction involving packaging subject to CONAI. Reporting frequency depends on annual volume:- Monthly
- Quarterly
- Annual (for small volumes)
EPR Reporting Deadlines
Deadlines depend on reporting frequency:- Monthly declarations: typically due by the 20th of the following month
- Quarterly declarations: typically by the 20th of the month following the quarter
- Annual declarations (for small volumes): usually by January of the following year
Labels & Marketing Claims
Italy has specific labelling obligations. Under Legislative Decree 116/2020:- Packaging must include material identification coding
- B2C packaging must include disposal instructions to consumers
- Labelling must be clear and compliant with Italian language requirements
- EU consumer protection law
- Italian Consumer Code
- Rules on misleading advertising
EPR Eco Fees & Eco-Modulation
The CONAI Environmental Contribution (CAC):- Is calculated based on material type
- Is charged per tonne of packaging
- Is updated periodically
- More recyclable packaging pays lower fees
- Difficult-to-recycle packaging pays higher fees
Risks, Penalties & Common Mistakes
Non-compliance may result in:- Administrative fines
- Backdated contribution payments
- Interest and penalties
- Reputational risks
- Not registering before first sale
- Misclassifying packaging materials
- Failing to apply correct CAC rates
- Assuming marketplace compliance covers obligations
- Not updating rates after CONAI revisions
What E-Commerce Sellers Should Do Now
- Determine if they qualify as importer or first placer
- Register with CONAI before selling
- Classify packaging materials accurately
- Set up volume tracking
- Choose correct declaration frequency
- Monitor CAC rate updates
- Ensure packaging labelling compliance
Register online
Start your EPR Reporting within 24 hours
FAQ
Is Italy’s packaging EPR mandatory?- Yes. It is mandatory under national law.
- Yes, if they place packaged goods on the Italian market.
- There is no full exemption, but simplified procedures exist for low volumes.
- Yes, particularly for plastic packaging.