Italy

Extended producer responsibility (EPR) for packaging in Italy

Who must register for packaging EPR in Italy

• Italian manufacturers / packers that first place empty or filled packaging on the market

• Importers or intra-EU acquirers bringing packaged goods or empty packs into Italy

• Companies with no Italian establishment; they must appoint an authorised representative and register via that proxy

What the package includes

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

Threshold

1. Small-trader facilitation – If your total annual CONAI Environmental Contribution (CAC) does not exceed €200, you may opt for the small-trader regime: a single flat-fee payment and a single annual declaration

2. Standard declaration frequency – The amount of CAC you paid in the previous year sets your reporting calendar:
   • Up to €3 000: file and pay once a year
   • €3 001 – 31 000: file and pay quarterly
   • More than €31 000: file and pay monthly

3. Declaration-of-completeness (audited report) – If you placed more than 80 t of glass, 50 t of paper/cardboard, or 30 t of plastics + metals on the Italian market in a year, you must submit an audited declaration of completeness by 20 May of the following year

EPR registration procedure in Italy

• Submit the online “Domanda di Adesione” via the impresainungiorno.gov.it portal linked from conai.org

• Pay the one-off membership fee and receive your CONAI member number—the core proof of EPR registration Italy

• Classify each packaging type with its CONAI declaration code using the “Codice Imballaggio” tool

• Start applying the CAC on first supplies and show the amount on sales invoices (art. 224-d, Leg. Decree 152/2006)

• File periodic CAC declarations (see next section) through the CONAI “Dichiarazioni on-line” portal and settle invoices

• Enter the National Producers Register (RENAP) within 60 days of first placing, via the Chambers of Commerce portal

Authorized representative

Reporting deadline

• Monthly regime – If your annual CONAI Environmental Contribution (CAC) exceeds €31 000, you must file the declaration by the 20th of the following month, and pay the contribution on the same day

• Quarterly regime – If last year’s CAC was €3 001 – €31 000, you declare on 20 April, 20 July, 20 October, and 20 January (of the following year); payment is due the same day as each filing

• Annual regime – If your prior-year CAC is €3 000 or less, you file and pay once a year, on 20 January of the following year

Who assumes responsibility?

• Italian manufacturers / packers are fully responsible for their packaging from the moment a product is first sold on the Italian market

• Importers or intra-EU acquirers assume the same full liability at customs clearance or arrival—unless the packaging has already been registered upstream

• Foreign distance sellers become liable—acting through an Italy-based authorised representative—whenever they dispatch a direct B2C order to an Italian consumer

• CONAI consortium takes on the operational tasks of collection, recycling and allocating the CONAI Environmental Contribution (CAC) once a membership contract is in place

• MASE / RENAP and the regional Chambers of Commerce maintain the producer registry and enforce compliance through audits and fines

Duties of each group

• Producers / importers: join CONAI, classify packs, apply and declare CAC, pay invoices, file records, display CAC on invoices, and co-operate with audits—cornerstones of Italy packaging recycling

• Authorised representative: hold Italian VAT & PEC, maintain mandate, submit declarations and payments, serve as contact for MASE and CONAI

• CONAI: collect CAC, hit material-specific recycling targets (overall 65 % by 2025; 70 % by 2030), audit member data and report to MASE

• MASE / RENAP / Chambers: publish compliant-producer lists, cross-check customs/tax data and issue fines up to €100 000 for serious breaches