Italy EPR

What is Italy EPR Batteries

Italy's battery EPR framework is governed by Regulation (EU) 2023/1542 — the EU Battery Regulation — which applies directly in all EU Member States from 18 August 2025. At national level, battery EPR in Italy is implemented through Legislative Decree No. 188/2008, which transposed the former Batteries Directive into Italian law, and is being updated to align with the new EU Battery Regulation requirements. The national body responsible for coordinating battery producer registration and EPR compliance in Italy is CDCNPA — Centro di Coordinamento Nazionale Pile e Accumulatori (National Coordination Centre for Batteries and Accumulators). CDCNPA coordinates the collective management systems for battery collection and recycling, manages producer registration, and monitors compliance with national battery EPR obligations. The supervisory authority is the Ministry of the Environment and Energy Security (MASE), which publishes lists of compliant producers and may impose administrative fines for breaches. Italy was included in the first wave of countries where Zalando activated battery EPR number verification — from January 2026. Kaufland and Amazon also actively require Italian battery registration numbers from sellers.

Does This Apply to E-Commerce & Online Sales

Yes. The EU Battery Regulation explicitly captures distance sellers and e-commerce operators as producers. A foreign brand selling batteries or battery-containing products directly to Italian consumers via an online store is treated as a producer and must comply with Italian battery EPR obligations. Online marketplaces operating in Italy — including Amazon.it, Zalando, and Kaufland — actively verify battery EPR registration numbers and restrict or block listings for non-compliant sellers. Italy was confirmed as a country where Amazon may either deactivate non-compliant offers or provide a Pay on Behalf service for sellers who have not independently registered. Non-Italian producers selling into Italy must appoint an authorised representative established in Italy to manage EPR registration and reporting obligations.

Who is the "Producer" under Italy EPR?

Under Regulation (EU) 2023/1542 and Legislative Decree No. 188/2008, a producer is any person who, in the course of commercial activity, places batteries — whether standalone or incorporated into products — on the Italian market for the first time. This covers:

1. Manufacturers established in Italy who produce and sell batteries domestically under their own brand.
2. Importers bringing batteries into Italy from non-EU countries for the first time under their own name.
3. Companies introducing batteries from another EU Member State into Italy for the first time.
4. Private label owners whose brand name appears on batteries manufactured by third parties.
5. Distance sellers and online retailers established outside Italy who sell batteries or battery-containing products directly to Italian consumers.
6. Economic operators who prepare batteries for re-use or repurposing — treated as producers for the second life of the battery.

Who Must Register for EPR Batteries in Italy

All producers placing batteries on the Italian market must register with CDCNPA and join an approved collective management system for battery collection and recycling, or demonstrate individual compliance with EPR obligations. CDCNPA manages the national coordination of battery collection systems and producer registration. Producers register through CDCNPA's online portal (cdcnpa.it), providing company details, battery categories, brand names, and collective system membership information. Upon registration, producers receive an Italian battery EPR registration number, which must be provided to online marketplaces and distributors as proof of compliance.

Italy EPR Battery Registration Threshold

Regulation (EU) 2023/1542 does not establish a minimum volume or turnover threshold below which producers are exempt from EPR obligations. All producers placing batteries on the Italian market must register and comply regardless of size or volume. The only exemption in the Regulation concerns batteries used in military or space equipment, which are outside the scope entirely. For due diligence obligations, companies with annual net turnover below €150 million (as adopted under the Omnibus IV package, July 2025) may be exempt — but this does not affect EPR registration and reporting obligations.

Batteries Covered (and Excluded)

Regulation (EU) 2023/1542 defines five battery categories, all within scope for EPR in Italy: Portable batteries Batteries under 5 kg not designed for industrial or vehicle use. Includes batteries in consumer electronics, power tools, household devices, and toys. Light Means of Transport (LMT) batteries Batteries used in e-bikes, e-scooters, e-mopeds, and similar light electric vehicles. Automotive (SLI) batteries Starting, lighting, and ignition batteries used in vehicles. Industrial batteries Batteries used in industrial applications and stationary energy storage systems. Those above 2 kWh have additional requirements including battery passports from 2027. Electric vehicle (EV) batteries Batteries used in electric cars and heavy electric vehicles. Subject to carbon footprint declarations, battery passports from 2027, and detailed collection obligations. Key exclusions:

• Batteries designed for military or space equipment — outside scope entirely
• Batteries in nuclear installations — excluded
• Second-life batteries where the operator performing re-use or repurposing becomes the new producer

Producer Responsibility Organization (PRO)

Italy's battery EPR system is coordinated through CDCNPA, which oversees the approved collective management systems operating in Italy. Collective systems manage the physical collection, transport, and recycling of waste batteries on behalf of their member producers, and report aggregated compliance data to CDCNPA and MASE. Producers join a collective system approved under Italian battery legislation, pay contributions based on the weight and category of batteries placed on the Italian market, and fulfil collection and recycling targets through the collective system's operations. CDCNPA's role is coordination rather than direct collection — it sets targets, monitors performance, and ensures that the collective systems operating in Italy collectively achieve the required collection rates for each battery category.

EPR Registration in Italy

The registration process for battery producers in Italy is as follows:

1. Determine whether your business qualifies as a producer under the EU Battery Regulation and Italian battery legislation.
2. If established outside Italy, appoint an authorised representative established in Italy before initiating any registration.
3. Register with CDCNPA through its online portal (cdcnpa.it), submitting company details, battery categories, and brand names.
4. Join an approved collective management system for battery collection and recycling in Italy.
5. Receive your Italian battery EPR registration number upon successful registration.
6. Provide the registration number to online marketplaces — Amazon.it, Zalando, Kaufland — and distributors operating in Italy.
7. Submit regular declarations of battery volumes placed on the Italian market through the collective system or CDCNPA reporting portal.
8. Pay applicable contributions to the collective system based on battery category and weight.

Authorized Representative

Under Regulation (EU) 2023/1542 (Article 57), producers established outside Italy must appoint an authorised representative — a legal or natural person established in Italy — to fulfill EPR obligations on their behalf. Non-Italian producers must appoint an AR before initiating registration with CDCNPA. The authorised representative is responsible for CDCNPA registration, collective system membership, reporting, fee payment, and communication with MASE and CDCNPA. The representative must be appointed in writing. Important development: In December 2025, the European Commission proposed suspending the authorised representative requirement for EU-established companies until 2035. This proposal has not been formally adopted as of May 2026. For non-EU producers, the requirement is not affected and continues to apply.

What Data Must Be Reported

Producers registered in Italy must declare and report the following data through CDCNPA or their collective system:

• Total weight (kilograms) of batteries placed on the Italian market during the reporting period, broken down by battery category (portable, LMT, SLI/automotive, industrial, EV)
• Battery chemistry type where relevant to contribution calculations and reporting
• Brand names under which batteries were placed on the market
• Collection and recycling performance data, compiled and reported by the collective system to CDCNPA on behalf of members
• For EV and LMT batteries: number of batteries made available and amounts of waste batteries collected and delivered to treatment facilities

First Reporting Period & EPR Reporting Deadlines

Battery EPR has been mandatory in Italy for many years under Legislative Decree No. 188/2008. The new EU Battery Regulation obligations took full effect from 18 August 2025. Key dates:

• 18 August 2025: EU Battery Regulation EPR obligations fully in force. All producers must be registered with CDCNPA.
• January 2026: Zalando activated battery EPR number verification for Italy — sellers without a valid Italian registration number have listings suspended.
• Annual: Declaration of batteries placed on the Italian market for the previous year, submitted to the collective system and CDCNPA. Specific deadlines are set by CDCNPA and the collective system.
• 18 February 2027: Battery passports mandatory for industrial batteries (>2 kWh) and EV batteries.
• 18 August 2027: Due diligence obligations in force (delayed under Omnibus IV).

Producers should confirm specific reporting timelines and declaration formats directly with CDCNPA and their chosen collective system at the time of registration.

Labels & Marketing Claims

Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol covering at least 3% of the area of the largest side of the battery, up to a maximum of 5 × 5 cm. Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb. Capacity marking Portable and rechargeable batteries must display capacity information. QR code From 18 August 2026, all batteries must carry a QR code. For LMT, industrial (>2 kWh), and EV batteries, this links to the Digital Battery Passport from 18 February 2027. CE marking Mandatory from 18 August 2024. Language requirements Consumer-facing information on batteries sold in Italy must be provided in Italian where required under Italian consumer protection law. Environmental claims All environmental and sustainability claims must comply with Italian consumer protection law and the Unfair Commercial Practices Directive. The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including Italy.

EPR Eco Fees & Eco-Modulation

Italy's battery eco-contribution structure is administered through the approved collective management systems coordinated by CDCNPA. Contributions are calculated based on:

• Weight (kilograms) of batteries placed on the Italian market by category
• Battery chemistry — different chemistries carry different recycling costs and contribution levels
• Collection and recycling costs — collective systems calculate contributions based on the actual cost of take-back, transport, and treatment

Under Regulation (EU) 2023/1542, eco-modulation — adjusting contributions based on battery environmental performance such as durability, recyclability, and recycled content — is required across all Member States. Italy's specific eco-modulation framework under the new Regulation has not been published in full detail as of May 2026. Specific fee schedules should be confirmed with the chosen collective system at the time of membership registration.

Risks, Penalties & Common Mistakes

1. Operating without CDCNPA registration. Placing batteries on the Italian market without a valid EPR registration number is a compliance breach. MASE may impose fines of up to €100,000 for serious violations. Amazon.it, Zalando, and Kaufland will block listings without a valid registration number.
2. Failing to appoint an authorised representative. Non-EU and non-Italian producers must appoint an Italian-established representative before registering with CDCNPA. Without one, registration cannot be completed.
3. Assuming one EU registration covers Italy. Battery EPR registration is national. Registration in another EU member state does not fulfil Italian obligations.
4. Not joining a collective management system. CDCNPA registration alone is insufficient — producers must also join an approved collective system for battery collection and recycling.
5. Missing the Zalando EPR number requirement. Italy was in the first wave of countries where Zalando activated battery EPR verification from January 2026. Sellers without a valid Italian registration number have listings suspended.
6. Missing labelling requirements. The crossed-out wheeled bin symbol and CE marking are mandatory from August 2025. Labels must include Italian-language consumer information.
7. Missing the QR code deadline of August 2026. Companies should begin QR code implementation well in advance.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products contain batteries and whether they are being sold to Italian consumers.
2. If established outside Italy, identify and appoint an authorised representative established in Italy.
3. Register with CDCNPA (cdcnpa.it) and join an approved collective management system for battery collection and recycling in Italy.
4. Receive your Italian battery EPR registration number and provide it to Amazon.it, Zalando, Kaufland, and other marketplaces where you sell battery-containing products.
5. Submit regular declarations of battery volumes placed on the Italian market through your collective system or CDCNPA reporting portal.
6. Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, capacity information, and Italian-language consumer instructions as required.
7. Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.

FAQ

• Is battery EPR mandatory in Italy?

Yes. Battery EPR has been mandatory in Italy for many years under Legislative Decree No. 188/2008. From 18 August 2025, the EU Battery Regulation (2023/1542) fully replaced the former Batteries Directive. All producers placing batteries on the Italian market must register with CDCNPA, join an approved collective management system, and comply with collection, reporting, and contribution obligations.

• Do foreign brands selling online into Italy need to register?

Yes. Distance sellers and e-commerce operators selling batteries or battery-containing products to Italian consumers are captured as producers under the EU Battery Regulation and Italian battery legislation. Non-Italian companies must appoint an authorised representative established in Italy before registering with CDCNPA. Amazon.it, Zalando, and Kaufland actively require valid Italian battery EPR registration numbers.

• What is CDCNPA and what is its role?

CDCNPA (Centro di Coordinamento Nazionale Pile e Accumulatori) is Italy's National Coordination Centre for Batteries and Accumulators. It coordinates the collective management systems for battery collection and recycling, manages producer registration, and monitors compliance. All battery producers in Italy register through CDCNPA and receive their Italian EPR registration number from this body.

• Is there a minimum volume threshold below which registration is not required?

No. The EU Battery Regulation does not establish a minimum volume or turnover exemption for EPR registration. All producers placing batteries on the Italian market must register and comply regardless of size.

• Do I need to register separately for batteries and WEEE in Italy?

Yes. Battery EPR and WEEE EPR are completely separate obligations in Italy with separate registration bodies. Batteries are registered through CDCNPA (cdcnpa.it). Electrical and electronic equipment is registered through Registro AEE (registroaee.it). A WEEE registration number does not cover batteries and vice versa.