Italy’s packaging EPR is governed by Legislative Decree No. 152/2006 (Environmental Code) and implemented through the national consortium system led by CONAI. Producers and users placing packaging on the Italian market must either join CONAI (and, for producers, the relevant material consortia) or establish an independent, approved return system that meets recovery and recycling targets. Obligations include financing waste management via the CONAI Environmental Contribution (CAC), accurate packaging data reporting, labeling to facilitate sorting, and consumer information.

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Italy EPR Regulations for Manufacturers, Importers and Ecommerce

The rules apply to companies that produce, import, fill, trade, or otherwise place packaging or packaged goods on the Italian market. Producers (raw materials/semi-finished for packaging; manufacturers/importers of empty packaging) and users (fillers, traders, importers of filled packaging, self-producers) are obligated parties. Most companies comply by joining CONAI; alternatively, firms may run own-return systems nationwide subject to authority approval, annual plans and reports. The EU’s new PPWR entered into force in 2025 and will progressively tighten recyclability and reporting requirements, complementing national EPR duties.

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Covered and Exempted Packaging under Italy EPR

Covered packaging: All packaging placed on the market in Italy across materials (steel, aluminium, paper/cardboard, wood, plastic including bioplastics, and glass) is in scope; restrictions include limits on heavy metals and requirements that packaging design facilitate collection, reuse, recovery and recycling.

• Examples considered “packaging” are defined in CONAI references (e.g., sales packaging, grouped packaging, transport packaging).
• Autonomous systems recognized under law may exempt companies from joining CONAI for those streams, provided recognition is granted and obligations are fulfilled.

Exemptions: End users of packaging (who buy packaged goods for use/consumption and do not redistribute them) are generally exempt from joining CONAI. Agricultural enterprises are not obliged to join but still pay CAC on Italian purchases and must declare CAC on imports. Exported packaging can be exempt via ordinary (ex post) reimbursement or simplified (ex ante) procedures.

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Who Must Register under Italy EPR

Obligated to join CONAI:

• Producers of raw materials/semi-finished for packaging, and manufacturers/importers of empty packaging — also join the relevant material consortia.
• Users: fillers/buyers of empty packaging; importers of filled packaging; traders of empty or filled packaging; self‑producers (who make/repair packaging to pack their own goods).

Companies choosing independent return systems must obtain authority approval, inform users/end‑users, and submit annual prevention/management plans and reports to the Authority and CONAI.

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Italy EPR Data Reporting

Declarations to CONAI (CAC): Report packaging quantities by material via the Online Declarations service. Regimes depend on annual CAC level (ordinary vs. simplified). Users typically pay CAC shown on supplier invoices and include the required wording (e.g., “CAC paid”) on their own invoices; importers file periodic declarations and pay CAC on imports. For independent systems, producers report participating users, achieved recovery/recycling results, and planned measures in annual submissions to the Authority and CONAI.

• Ordinary procedure: Forms 6.1/6.2/6.10; declaration frequency (monthly/quarterly/annual) based on total CAC per material in prior year.
• Simplified procedure: Form 6.2; single invoice for all materials.
• Online Declarations: secure portal for submissions; CONAI issues invoices per material (ordinary) or single invoice (simplified).

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Italy EPR Schedule and Deadlines

CONAI declaration due dates (based on regime):

• Monthly: by the 20th day of the month following the reference month.
• Quarterly: by 20 April, 20 July, 20 October, 20 January for the preceding quarter.
• Annual (single): by 20 January for the prior year.

Independent systems: seek approval within 90 days of becoming a producer; submit the management report by 31 May (for the prior year) and the prevention & management plan by 30 September (for the following year) to the Authority and CONAI.

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Italy EPR Fees and Penalties

Environmental Contribution (CAC): payable at the first transfer of packaging/material to a user in Italy or when imported packaging is placed on the market. Amounts vary by material and are periodically updated (e.g., wood CAC adjusted in 2025). CONAI invoices follow your reporting regime.

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• Penalties (per Legislative Decree 152/2006): approx. €5,000 for producers/users not joining CONAI; €15,000–€46,500 for producers not joining the relevant material consortia.
• Export exemptions: ordinary (ex post reimbursement) and simplified (ex ante) options by material.

Common EPR Compliance Challenges In Italy

Frequent pitfalls include: correctly classifying your role (producer vs. user); capturing imports of filled packaging for CAC declarations; applying and displaying the “CAC paid” statement on invoices; managing ex ante/ex post export exemptions; aligning material‑consortium membership; and preparing for PPWR recyclability/labeling expectations alongside national EPR reporting. A proactive data model and internal controls across procurement, logistics and billing are essential.

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Why choose RegSurance as your Italy EPR Compliance Partner

RegSurance is a trusted EPR compliance service provider for international businesses needing to comply with Italy packaging EPR rules. We support manufacturers, importers, and e-commerce sellers with complete EPR solutions — including EPR registration, packaging compliance assessments, ongoing regulatory updates, and accurate EPR data reporting for Italy. With our in-depth knowledge of Italy EPR requirements, we ensure your business stays fully compliant and up to date with changing legislation.

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FAQs — Italy Packaging EPR (CONAI) & PPWR

• 1) Who must join CONAI?
  Producers (raw materials/semi-finished for packaging; manufacturers/importers of empty packaging) and users (fillers, importers of filled packaging, traders of empty/filled packaging, and self‑producers) must join; producers also join the relevant material consortia.
• 2) Are any entities exempt from joining CONAI?
  Yes: end users of packaging (who do not redistribute goods) are generally exempt; agricultural enterprises are not obliged to join but must still pay/declare CAC where applicable.
• 3) What counts as “packaging” under Italian EPR?
  Sales, grouped and transport packaging across materials (steel, aluminium, paper, wood, plastic/bioplastic, glass) designed to facilitate handling, protection, marketing or delivery are in scope.
• 4) How do I declare and pay CAC?
  Use CONAI Online Declarations to report by material. Frequency (monthly/quarterly/annual) depends on prior‑year CAC. Payment follows receipt of CONAI invoices.
• 5) What must importers of filled packaging do?
  They must join CONAI as users, submit periodic declarations, and pay CAC on packaging placed on the market for consumption in Italy.
• 6) What invoice wording is required?
  Include the prescribed statement (e.g., “CAC paid”) on sales invoices to demonstrate contribution has been applied/charged as required.
• 7) How do export exemptions work?
  Choose ordinary (ex post reimbursement based on documented exported quantities by material) or simplified (ex ante determination of export quantities so CAC is not charged upfront).
• 8) Can I comply without CONAI?
  Yes—by establishing an independent return system approved by the Authority, with annual plan and management report, and user/end‑user information duties.
• 9) What penalties apply for non‑compliance?
  Approx. €5,000 for not joining CONAI; €15,000–€46,500 for not joining relevant material consortia; additional enforcement may apply.
• 10) How does the EU PPWR affect Italy EPR?
  PPWR (in force from 2025) tightens EU‑wide rules on recyclability, reuse and reporting; Italian EPR via CONAI continues, with companies needing to align national reporting and future PPWR performance criteria and labeling rules.