Italy EPR

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)

The Italian packaging EPR system is organised through CONAI (Consorzio Nazionale Imballaggi) and its six material consortia. Any entity that places packaging or packaged goods on the Italian market must:

• Register with CONAI
• Declare packaging quantities
• Pay environmental contribution (Contributo Ambientale CONAI – CAC)
• Ensure recycling targets are met via the national system

The system is fully mandatory.

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

In practice, responsibility lies with the entity that first places packaging or packaged goods on the Italian market. In B2B supply chains, obligations may shift depending on invoicing structure and transfer of ownership.

Who must register for EPR packaging in Italy

Entities placing packaging or packaged goods on the Italian market must:

1. Register with CONAI
2. Determine applicable material consortia
3. Submit periodic packaging declarations
4. Pay the CONAI Environmental Contribution (CAC)

Registration must occur before starting activity. Both Italian and foreign companies placing goods on the Italian market may be required to register.

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

There is no full de minimis exemption removing EPR obligations entirely.

Packaging Covered (and Excluded)

Covered All packaging types are covered, including:

• Primary packaging
• Secondary packaging
• Tertiary (transport) packaging

Materials are organised into six consortia:

• Steel
• Aluminium
• Paper
• Wood
• Plastic
• Glass

Both household and commercial packaging are in scope.

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)

Unlike some countries, companies do not choose between competing PROs — CONAI is the national coordination body.

EPR Registration in Italy

The compliance process generally involves:

1. Registering with CONAI
2. Determining packaging material categories
3. Setting up reporting method (ordinary, simplified, or flat-rate where applicable)
4. Submitting periodic declarations (monthly, quarterly, or annually depending on volume)
5. Paying environmental contributions

Foreign companies typically appoint a fiscal or compliance representative to manage obligations.

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

In practice, local administrative support is strongly recommended.

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

Data must be supported by accounting and customs documentation.

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

CONAI determines applicable reporting frequency based on turnover and packaging volume.

Labels & Marketing Claims

An example of what a label looks like on packaging for Italy — PAP paper/cardboard packaging

it combines the material identification code from Decision 97/129/EC — for example PAP 20, PAP 21, PAP 22 — with an Italian disposal instruction, “Raccolta carta”. For B2C packaging, the information should be clear for the consumer and applied to each manually separable packaging component. CONAI provides official guidance and the E-tichetta tool for checking the correct label content.

PAP 20 label

The PAP 20 label means the component is made of corrugated fibreboard / corrugated cardboard. It is typically used for shipping boxes, outer cartons, and corrugated cardboard packaging.

For Italy, it should be paired with the collection instruction:

SCATOLA: PAP 20 — Raccolta carta
Verifica le disposizioni del tuo Comune

📎Download / obtain the PAP 20 label:

• PNG – best for digital use.

You can create the PNG from the PAP 20 recycling symbol and add the Italian instruction “Raccolta carta”. For real packaging, verify the content using CONAI / E-tichetta rather than treating the icon alone as sufficient.

PAP 21 label

The PAP 21 label means the component is made of non-corrugated fibreboard / cardboard. It is commonly used for folding cartons, product boxes, sleeves, and retail cardboard packaging.

For Italy, it should normally be paired with the collection instruction:

ASTUCCIO: PAP 21 — Raccolta carta
Verifica le disposizioni del tuo Comune

📎Download / obtain the PAP 21 label:

• PNG – best for digital use.

Use it together with the Italian disposal instruction. The PAP 21 symbol alone identifies the material, but Italian B2C environmental labelling also requires disposal/collection information in Italian.

PAP 22 label

The PAP 22 label means the component is made of paper. It is typically used for paper labels, leaflets, paper bags, inserts, and paper wraps.

For Italy, it should normally be paired with the collection instruction:

ETICHETTA: PAP 22 — Raccolta carta
Verifica le disposizioni del tuo Comune

📎Download / obtain the PAP 22 label:

• PNG – best for digital use.

Use it when the component is paper, not cardboard or corrugated cardboard. The exact component name can change depending on the packaging: ETICHETTA, FOGLIO, SACCHETTO, INSERTO, etc.

Additional Italy PAP label variants

For multi-component packaging, each separable component may need its own line. For example:

SCATOLA: PAP 21 — Raccolta carta
ETICHETTA: PAP 22 — Raccolta carta
INSERTO: PAP 22 — Raccolta carta
Verifica le disposizioni del tuo Comune

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

Italy applies eco-modulation, particularly for plastic packaging, where:

• More recyclable packaging pays lower fees
• Difficult-to-recycle packaging pays higher fees

Fee levels vary by material and recyclability category.

Risks, Penalties & Common Mistakes

Non-compliance may result in:

• Administrative fines
• Backdated contribution payments
• Interest and penalties
• Reputational risks

Common mistakes include:

• 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

FAQ

• Is Italy’s packaging EPR mandatory?

Yes. It is mandatory under national law.

• Do foreign online sellers need to comply?

Yes, if they place packaged goods on the Italian market.

• Is there a de minimis threshold?

There is no full exemption, but simplified procedures exist for low volumes.

• Is eco-modulation applied?

Yes, particularly for plastic packaging.