Italy
Extended Producer Responsibility (EPR) for packaging in Italy
Italian packaging EPR is laid down in Legislative Decree 152/2006 (Environmental Code) as amended by Decree 116/2020 and Decree 152/2022, which transpose the EU Packaging Directive and embed the “polluter-pays” principle into national lawOperational compliance is channelled through the private-law but state-supervised Consorzio Nazionale Imballaggi (CONAI), while strategic oversight and vigilance are carried out by the Ministry of the Environment and Energy Security (MASE) . Together these bodies ensure that EPR Italy collects and reallocates the CONAI Environmental Contribution (CAC) to finance collection, recycling and recovery, helping Italy exceed EU targets for Italy packaging recycling
Who must register for EPR in Italy
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Italian manufacturers / packers that first place empty or filled packaging on the market.
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Importers or intra-EU acquirers bringing packaged goods or empty packs into Italy.
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Distance-selling 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
Italy applies no de-minimis exemption for joining CONAI—one package triggers obligations.However, simplified regimes apply:
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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.
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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. -
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
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Submit the online “Domanda di Adesione” via the impresainungiorno.gov.it portal linked from conai.org
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Pay the one-off membership fee and receive your CONAI member number—the core proof of EPR registration Italy
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Classify each packaging type with its CONAI declaration code using the “Codice Imballaggio” tool.
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Start applying the CAC on first supplies and show the amount on sales invoices (art. 224-d, Leg. Decree 152/2006)
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File periodic CAC declarations (see next section) through the CONAI “Dichiarazioni on-line” portal and settle invoices.
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Enter the National Producers Register (RENAP) within 60 days of first placing, via the Chambers of Commerce portal.
Authorized representative
A non-Italian producer selling directly to end-users must designate a “rappresentante autorizzato” resident in Italy to perform all CONAI and RENAP obligations—registration, reporting, fee payment and audit liaison—under art. 221-bis, Leg. Decree 152/2006Reporting Deadline
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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.
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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.
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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?
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Italian manufacturers / packers are fully responsible for their packaging from the moment a product is first sold on the Italian market.
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Importers or intra-EU acquirers assume the same full liability at customs clearance or arrival—unless the packaging has already been registered upstream.
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Foreign distance sellers become liable—acting through an Italy-based authorised representative—whenever they dispatch a direct B2C order to an Italian consumer.
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CONAI consortium takes on the operational tasks of collection, recycling and allocating the CONAI Environmental Contribution (CAC) once a membership contract is in place.
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MASE / RENAP and the regional Chambers of Commerce maintain the producer registry and enforce compliance through audits and fines.
Duties of Each Group Who Is Responsible
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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
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Authorised representative: hold Italian VAT & PEC, maintain mandate, submit declarations and payments, serve as contact for MASE and CONAI
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CONAI: collect CAC, hit material-specific recycling targets (overall 65 % by 2025; 70 % by 2030), audit member data and report to MASE
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MASE / RENAP / Chambers: publish compliant-producer lists, cross-check customs/tax data and issue fines up to €100 000 for serious breaches
Extended Producer Responsibility (EPR) for EEE in Italy
Italy implements EPR for EEE through Legislative Decree No. 49/2014, which transposes EU Directive 2012/19/EU (WEEE Directive). This legislation mandates that producers are responsible for the entire lifecycle of EEE products, including their end-of-life disposal and recycling.Who Must Register for EEE EPR in Italy
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Italian manufacturers or packers placing EEE on the domestic market.
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Importers or intra-EU acquirers bringing EEE into Italy.
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Distance-selling companies without an Italian establishment, which must appoint an authorized representative.
What the Package Includes
All categories of EEE, including:
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Temperature exchange equipment
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Screens, monitors, and equipment with screens >100 cm²
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Lamps
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Large equipment
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Small equipment
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Small IT and telecommunication equipment
Threshold
There is no de-minimis exemption: any company placing EEE on the Italian market must comply with EPR obligations.EPR Registration Procedure in Italy
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Select an approved Producer Responsibility Organization (PRO), such as Erion or ERP Italia.
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Submit required statutory documents for company registration.
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Establish a cooperation agreement with the chosen PRO.
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Pay the applicable license fee.
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Obtain an EPR registration number for the company.
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Provide annual reports detailing the amount of EEE placed on 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
Organizations distributing EEE in Italy must submit complete reports quarterly to their authorized recycling organization.Who Assumes Responsibility?
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Italian manufacturers / packers bear full liability as soon as a product is first sold domestically.
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Importers / intra-EU acquirers assume full liability at customs clearance or upon arrival, unless the packaging is already registered upstream.
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Foreign distance sellers are liable—through an Italian-based authorised representative—when they dispatch a direct B2C order.
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CONAI consortium handles the operational duties of collection, recycling and fee allocation once a membership contract is in place.
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MASE / RENAP and the regional Chambers of Commerce maintain the producer registry and enforce compliance through audits and fines.
Duties of Each Group Who Is Responsible
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Producers / importers: Register with a PRO, classify products, apply and declare eco-contributions, pay invoices, maintain records, and cooperate with audits.
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Authorized representative: Hold Italian VAT & PEC, maintain mandate, submit declarations and payments, serve as contact for authorities.
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PROs: Collect eco-contributions, meet recycling targets, audit member data, and report to the Ministry.
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Ministry / Registry: Publish compliant-producer lists, cross-check customs/tax data, and issue fines for non-compliance.