Italy EPR Guide | Lovat Compliance

Italy: Extended Producer Responsibility (EPR) for packaging

The EPR framework in Italy, mandated by the Legislative Decree of April 3, 2006, addresses environmental concerns, particularly in Title 2 of Part 4, which pertains to Packaging Management. In a significant development, amendments were introduced in October 2020, with a specific focus on the handling of biodegradable and compostable plastic packaging in its end-of-life phase. These changes demonstrate a commitment to responsible packaging management and environmental conservation.

Get your EPR number in countries where you sell your goods with packages

Who bears the responsibility in Italy?

Registration is not mandatory for foreign companies but can be done voluntarily.

The Packaging Act and its associated regulations apply to everyone:

Manufacturer
Importer
Vendors of empty packaging
Distributor
Online seller

What constitutes packaging according to the Packaging Act of Italy?

Paper and cardboard;
Steel;
Aluminum;
Glass;
Wood;
Eco-friendly and compostable plastic.

Thresholds

Registration is not required for foreign companies. But, there are no limits on local producers and the responsibility for such companies lies with the start of product sales in Italy.

Producers’ Responsibilities for Extended Producer Responsibility (EPR) in Italy

The producer must register with the relevant authority to obtain the packaging registration number:

1) Registration

Producers must register with the Register of national producers’ established by the Italian Ministry of the Environment for the protection of the territory and the sea.
The producer must conclude a contract with the eco-operator to manage packaging.

2) Fee Payments

The producers are obliged to make eco-contributions corresponding to each type of material.
The EPR fees are determined based on each material, the corresponding fee level, and the unit weight per material of the supplied packaging.

3) Reporting

In special cases, EPR fee declarations are yearly.
Producers are required to present quarterly declarations in the first year.
From the second year onwards, declarations can be annual, quarterly, or monthly depending on the total EPR fee declared by material the previous year.

Authorized Proxy

The producer must appoint an authorized representative based in Italy to fulfill the packaging law requirements on the producer’s behalf.

Reporting Deadline

The deadline for submitting the yearly report in Italy is 20 January in the year following the reference year.
Quarterly declarations (20 April, 20 July, 20 October, 20 January) relating to the three months prior to each deadline.
Monthly declarations (by the 20th day of the month following the reference month).

Sanctions in case of violation

The government authority will enforce fines of €5,000 for producers who are not registered in the system and fines ranging from €15,000 to €46,500 for producers who fail to participate in the Packaging Material program.

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Italy: Extended Producer Responsibility (EPR) for EEE

The European Union has taken steps to simplify the management of EEE waste to protect the environment, human health, and preserve natural resources. In 2005, Italy embraced the WEEE Directive through Legislative Decree n. 151/2005 and implemented a domestic EEE management system in 2007. The European Directive 2018/849, which was incorporated into the Italian legal system through Legislative Decree 118/2020 as part of the Circular Economy Package, is currently in force.

Who is considered responsible?

The responsibility of EPR rules for EEE is given to producers, sellers, and holders. Each producer is responsible for the waste from the produced products. The producer can fulfill this obligation individually or by joining a collective scheme.

What does EEE include

Currently, there are 6 categories prescribed in Italy:

Temperature exchange equipment
Screens, monitors, and equipment with surface screens >100cm2
Lamps
Large equipment
Small equipment
Small IT and telecommunication equipment

Thresholds

The threshold does not apply. Every company that launches products on the market is obliged to register.

Registration procedure

The process of registering for compliance with Electrical and Electronic Equipment (EEE) regulations in Italy includes the following steps:

Select an approved Producer Responsibility Organization (PRO).
Submit the required statutory documents for company registration.
Establish a cooperation agreement.
Pay the applicable license fee.
Obtain an Extended Producer Responsibility (EPR) number for the company.
Provide annual reports detailing the amount of packaging released into the market.

Authorized representative

A producer from another country that sells EEE in Italy by remote means must appoint an authorized Italian representative who will be responsible for fulfilling the obligations of this producer.

Reporting Deadline

Every quarter, organizations involved in distributing electronic and electrical goods in Italy must submit complete reports to the authorized recycling organization.

Sanctions in case of violation

Under the law, offending manufacturers face a fine of up to EUR 20,000. This penalty applies to individuals or legal entities that place EEE on the market without registration in the National Register, fail to provide the required information or provide false information.