+49 6196 5835357

info@ecopv-eu.com

🇮🇹 EPR Compliance for Packaging in Italy |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Packaging under the CONAI System + PPWR Update

With CONAI (Consorzio Nazionale Imballaggi), Italy operates one of the oldest and most sophisticated packaging EPR systems in Europe – in operation since 1998, fundamentally reformed in 2020 by Legislative Decree 116/2020, and today characterized by one of the most complex eco-modulation systems within the EU.

What makes Italy unique: the requirement for environmental labeling on packaging, a recycling system consisting of seven material consortia, and, starting August 12, 2026, the application of the EU Packaging and Packaging Waste Regulation (PPWR) – which, however, will not initially replace the existing CONAI format but will allow both to run in parallel until August 11, 2028.
Starting on the effective date, a two-year grace period begins during which the CONAI format and the new, harmonized EU sorting symbols may be used simultaneously in a legally compliant manner.

Here are the 7 most important steps for packaging compliance in Italy – including current rates for 2026, the PPWR timeline, and a complete checklist.

🇮🇹 EPR Compliance for Packaging in Italy |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Packaging under the CONAI System + PPWR Update

With CONAI (Consorzio Nazionale Imballaggi), Italy operates one of the oldest and most sophisticated packaging EPR systems in Europe – in operation since 1998, fundamentally reformed in 2020 by Legislative Decree 116/2020, and today characterized by one of the most complex eco-modulation systems within the EU.

What makes Italy unique: the requirement for environmental labeling on packaging, a recycling system consisting of seven material consortia, and, starting August 12, 2026, the application of the EU Packaging and Packaging Waste Regulation (PPWR) – which, however, will not initially replace the existing CONAI format but will allow both to run in parallel until August 11, 2028.
Starting on the effective date, a two-year grace period begins during which the CONAI format and the new, harmonized EU sorting symbols may be used simultaneously in a legally compliant manner.

Here are the 7 most important steps for packaging compliance in Italy – including current rates for 2026, the PPWR timeline, and a complete checklist.

Who is considered a “manufacturer” or “user” (Produttore / Utilizzatore) under the CONAI system?

The CONAI system distinguishes between two roles, which may overlap:

Produttori (Manufacturers):

  • Manufacturers of packaging materials (e.g., plastic film, cardboard, glass bottles as empty packaging)
  • Importers of empty packaging or packaging materials into Italy

Utilizzatori (Users / Fillers):

  • Companies that fill or package goods into packaging
  • Importers of pre-packaged goods (including foreign online retailers)
  • Retailers who sell packaged goods and use service packaging

E-commerce & marketplaces: Foreign online retailers who deliver directly to end consumers in Italy are considered importers. Regardless of their origin (EU or non-EU), they are required to register with CONAI and pay the CAC environmental fee for all shipping cartons, filling materials, and service packaging. Marketplaces (Amazon.it, eBay.it, Zalando IT) have been actively requiring proof of CONAI registration since 2025/2026.

Practical example: A German company ships cosmetic products in cardboard shipping packaging directly to Italian end customers → is considered a “Utilizzatore” → must register with CONAI (directly or through an authorized representative) → must include the CONAI membership number on commercial documents → must report packaging quantities (cardboard, plastic film, filler material) annually → pay CAC based on the reported quantities → ensure environmental labeling in Italian on packaging.

The CONAI System: Umbrella Organization + 7 Material Consortia

CONAI is the umbrella organization. The physical collection, sorting, and recycling of the various packaging materials are handled by seven state-recognized material consortia:

ConsortiumMaterialCharacteristics
COMIECOPaper and cardboardWell-established system; high recycling rates
COREPLAPlasticMost complex system; 9 contribution tiers (Fasce); strong eco-modulation
COREVEGlassSignificant rate increase in 2025/2026 (from €15 to €40/t)
CIALAluminumHigh recycling rates; stable rates
RICREASteelFor steel packaging (cans, drums)
RILEGNOWoodPallets, wooden crates; industrial packaging
BIOREPACKBioplastics (compostable)Fully operational since 2021/22; for compostable packaging according to EN 13432

How it works for manufacturers: By joining CONAI, a company automatically becomes part of all relevant material consortia – no separate membership in each consortium is required. Reports are submitted centrally via the CONAI portal, and funds are distributed by CONAI proportionally to the relevant consortia. The consortia organize collection, processing, and recycling in close coordination with local municipalities.

The 7 Most Important Steps for EPR Compliance in Italy

Step 1: Appoint an Authorized Representative (for foreign companies)

1. Direct to End Consumers (B2C / Online Retail):
Any company without an Italian registered office that delivers packaged goods directly to end consumers must license the packaging with CONAI. Foreign companies (both EU and non-EU) can register directly and independently online; while appointing an authorized representative is legally optional, service providers often recommend it due to Italian bureaucracy.

A foreign company thus has two options with CONAI:

  1. Direct registration with CONAI – requires an Italian tax ID number. Without this, direct registration is not possible.
  2. Appointing an authorized representative / EPR service provider – this representative handles registration, volume reporting, and CAC payments on behalf of the foreign company. Preferred solution for companies without a branch in Italy.

Requirements for the authorized representative:

  • Headquarters in Italy
  • Written power of attorney
  • Liable for the accuracy of volume data and the completeness of CAC payments
2. To Italian retailers (B2B for resale):
When exporting to Italian intermediaries, the legal obligation falls on the Italian importer. However, foreign suppliers may voluntarily handle the registration to reduce the administrative burden on their customers.

3. Under the EU Packaging and Packaging Waste Regulation (PPWR):
The PPWR tightens regulations on cross-border direct sales across Europe. Online marketplaces are required to verify valid EPR registration procedures. Failure to provide proof of a CONAI number will result in account suspension for the Italian market. Under the PPWR, a local authorized representative is now only mandatory for retailers from non-EU third countries.

Step 2: Registration with CONAI

Registration with CONAI (www.conai.org) is a mandatory step for all companies that place packaging on the market in Italy.

Procedure:

  1. Register online on the CONAI portal as a Produttore, Utilizzatore, or both
  2. Specify the types of materials (plastic, paper, glass, metal, wood, bioplastic)
  3. Payment of the one-time membership fee: The base fee is €5.16. An additional, variable amount is payable only by companies whose total annual turnover in the previous year exceeded €500,000.00.
  4. Receipt of the CONAI membership number

Requirement to use the membership number: The CONAI membership number should be included on commercial documents. Amazon.it and Bol.com.be actively require this during merchant onboarding.

Step 3: Classify packaging by material and contribution tier

Before the first report can be submitted, all packaging must be classified by material and – in the case of plastic – by contribution tier. This classification determines the rate.

Rule for multi-component packaging: If a package consists of multiple materials and the secondary material accounts for less than 5% of the total weight, the package is considered single-material packaging (primary material). If it accounts for more than 5%, it is considered composite packaging and must be reported and labeled as such.

Step 4: Financial Obligations & CAC Rates

The CAC (Contributo Ambientale CONAI) is the core fee of the system – per ton of packaging material placed on the market.

The current overview of CONAI environmental contributions (Contributo Ambientale) for all materials is available at CONAI Contributo Ambientale.

Plastic Contribution Levels (COREPLA Fascia System)

The COREPLA system is the most complex and innovative within the EU: plastic packaging is divided into 9 contribution levels (Fasce A through E, with sub-levels), based on its recyclability, material mix, and processing route. More information is available at Contributo diversificato plastica.

Step 5: Reporting Requirements

Reporting frequency based on contribution amount:

  • Up to €3,000 in the previous year: Reporting and payment are due once a year.
  • €3,001 to €31,000: Reporting and payment are due quarterly.
  • Over €31,000: Reporting and payment are due monthly.

Reporting content:

  • Material quantities by weight (tons), broken down by material stream
  • Separation by primary packaging, secondary packaging, and transport packaging
  • Separation by household and commercial share

Channel: Digitally via the CONAI member portal

Step 6: Environmental Labeling

In Italy, all packaging must bear an environmental label. This requirement applies to almost all packaging throughout the entire supply chain (manufacturers, importers, online retailers).

  • Material labeling (CONAI code): All packaging materials (primary, secondary, and tertiary packaging) must be marked with an alphanumeric code in accordance with EU Decision 97/129/EC.
  • Disposal instructions (B2C): Packaging intended for end consumers must include specific instructions for waste separation and disposal.

Note: New rules will apply when the EU Packaging Regulation 2025/40 (PPWR) enters into force in August 2026. However, due to the statutory transition periods, it will be permitted to continue using the current Italian environmental labeling in its existing form until August 11, 2028. After that, it will be mandatorily replaced by the new, uniform EU labeling with pictograms, as specified in Article 12 of the Regulation.

Step 7: Comply with specific requirements: Single-Use Plastics (SUPD) & Recycled Content PET

Single-Use Plastics Directive: Italy has implemented the EU SUPD Directive through Legislative Decree 196/2021. Starting in 2025, specific requirements will apply to single-use plastic packaging:

  • PET beverage bottles must contain an average of 25% recycled plastic (effective 2025; increasing to 30% starting in 2030 for all single-use plastic bottles)
  • Bans on certain single-use plastic items (including straws, cutlery, and EPS plates) have been in effect since 2021/2022

Who is considered a “manufacturer” or “user” (Produttore / Utilizzatore) under the CONAI system?

The CONAI system distinguishes between two roles, which may overlap:

Produttori (Manufacturers):

  • Manufacturers of packaging materials (e.g., plastic film, cardboard, glass bottles as empty packaging)
  • Importers of empty packaging or packaging materials into Italy

Utilizzatori (Users / Fillers):

  • Companies that fill or package goods into packaging
  • Importers of pre-packaged goods (including foreign online retailers)
  • Retailers who sell packaged goods and use service packaging

E-commerce & marketplaces: Foreign online retailers who deliver directly to end consumers in Italy are considered importers. Regardless of their origin (EU or non-EU), they are required to register with CONAI and pay the CAC environmental fee for all shipping cartons, filling materials, and service packaging. Marketplaces (Amazon.it, eBay.it, Zalando IT) have been actively requiring proof of CONAI registration since 2025/2026.

Practical example: A German company ships cosmetic products in cardboard shipping packaging directly to Italian end customers → is considered a “Utilizzatore” → must register with CONAI (directly or through an authorized representative) → must include the CONAI membership number on commercial documents → must report packaging quantities (cardboard, plastic film, filler material) annually → pay CAC based on the reported quantities → ensure environmental labeling in Italian on packaging.

The CONAI System: Umbrella Organization + 7 Material Consortia

CONAI is the umbrella organization. The physical collection, sorting, and recycling of the various packaging materials are handled by seven state-recognized material consortia:

Consortium

  1. COMIECO: Paper and cardboard (Well-established system; high recycling rates)
  2. COREPLA: Plastic (Most complex system; 9 contribution tiers (Fasce); strong eco-modulation)
  3. COREVE: Glass (Significant rate increase in 2025/2026 (from €15 to €40/t))
  4. CIAL: Aluminum (High recycling rates; stable rates)
  5. RICREA: Steel (For steel packaging (cans, drums))
  6. RILEGNO: Wood (Pallets, wooden crates; industrial packaging)
  7. BIOREPACK: Bioplastics – compostable (Fully operational since 2021/22; for compostable packaging according to EN 13432)

How it works for manufacturers: By joining CONAI, a company automatically becomes part of all relevant material consortia – no separate membership in each consortium is required. Reports are submitted centrally via the CONAI portal, and funds are distributed by CONAI proportionally to the relevant consortia. The consortia organize collection, processing, and recycling in close coordination with local municipalities.

The 7 Most Important Steps for EPR Compliance in Italy

Step 1: Appoint an Authorized Representative (for foreign companies)

1. Direct to End Consumers (B2C / Online Retail):
Any company without an Italian registered office that delivers packaged goods directly to end consumers must license the packaging with CONAI. Foreign companies (both EU and non-EU) can register directly and independently online; while appointing an authorized representative is legally optional, service providers often recommend it due to Italian bureaucracy.

A foreign company thus has two options with CONAI:

  1. Direct registration with CONAI – requires an Italian tax ID number. Without this, direct registration is not possible.
  2. Appointing an authorized representative / EPR service provider – this representative handles registration, volume reporting, and CAC payments on behalf of the foreign company. Preferred solution for companies without a branch in Italy.

Requirements for the authorized representative:

  • Headquarters in Italy
  • Written power of attorney
  • Liable for the accuracy of volume data and the completeness of CAC payments
2. To Italian retailers (B2B for resale):
When exporting to Italian intermediaries, the legal obligation falls on the Italian importer. However, foreign suppliers may voluntarily handle the registration to reduce the administrative burden on their customers.

3. Under the EU Packaging and Packaging Waste Regulation (PPWR):
The PPWR tightens regulations on cross-border direct sales across Europe. Online marketplaces are required to verify valid EPR registration procedures. Failure to provide proof of a CONAI number will result in account suspension for the Italian market. Under the PPWR, a local authorized representative is now only mandatory for retailers from non-EU third countries.

Step 2: Registration with CONAI

Registration with CONAI (www.conai.org) is a mandatory step for all companies that place packaging on the market in Italy.

Procedure:

  1. Register online on the CONAI portal as a Produttore, Utilizzatore, or both
  2. Specify the types of materials (plastic, paper, glass, metal, wood, bioplastic)
  3. Payment of the one-time membership fee: The base fee is €5.16. An additional, variable amount is payable only by companies whose total annual turnover in the previous year exceeded €500,000.00.
  4. Receipt of the CONAI membership number

Requirement to use the membership number: The CONAI membership number should be included on commercial documents. Amazon.it and Bol.com.be actively require this during merchant onboarding.

Step 3: Classify packaging by material and contribution tier

Before the first report can be submitted, all packaging must be classified by material and – in the case of plastic – by contribution tier. This classification determines the rate.

Rule for multi-component packaging: If a package consists of multiple materials and the secondary material accounts for less than 5% of the total weight, the package is considered single-material packaging (primary material). If it accounts for more than 5%, it is considered composite packaging and must be reported and labeled as such.

Step 4: Financial Obligations & CAC Rates

The CAC (Contributo Ambientale CONAI) is the core fee of the system – per ton of packaging material placed on the market.

The current overview of CONAI environmental contributions (Contributo Ambientale) for all materials is available at CONAI Contributo Ambientale.

Plastic Contribution Levels (COREPLA Fascia System)

The COREPLA system is the most complex and innovative within the EU: plastic packaging is divided into 9 contribution levels (Fasce A through E, with sub-levels), based on its recyclability, material mix, and processing route. More information is available at Contributo diversificato plastica.

Step 5: Reporting Requirements

Reporting frequency based on contribution amount:

  • Up to €3,000 in the previous year: Reporting and payment are due once a year.
  • €3,001 to €31,000: Reporting and payment are due quarterly.
  • Over €31,000: Reporting and payment are due monthly.

Reporting content:

  • Material quantities by weight (tons), broken down by material stream
  • Separation by primary packaging, secondary packaging, and transport packaging
  • Separation by household and commercial share

Channel: Digitally via the CONAI member portal

Step 6: Environmental Labeling

In Italy, all packaging must bear an environmental label. This requirement applies to almost all packaging throughout the entire supply chain (manufacturers, importers, online retailers).

  • Material labeling (CONAI code): All packaging materials (primary, secondary, and tertiary packaging) must be marked with an alphanumeric code in accordance with EU Decision 97/129/EC.
  • Disposal instructions (B2C): Packaging intended for end consumers must include specific instructions for waste separation and disposal.

Note: New rules will apply when the EU Packaging Regulation 2025/40 (PPWR) enters into force in August 2026. However, due to the statutory transition periods, it will be permitted to continue using the current Italian environmental labeling in its existing form until August 11, 2028. After that, it will be mandatorily replaced by the new, uniform EU labeling with pictograms, as specified in Article 12 of the Regulation.

Step 7: Comply with specific requirements: Single-Use Plastics (SUPD) & Recycled Content PET

Single-Use Plastics Directive: Italy has implemented the EU SUPD Directive through Legislative Decree 196/2021. Starting in 2025, specific requirements will apply to single-use plastic packaging:

  • PET beverage bottles must contain an average of 25% recycled plastic (effective 2025; increasing to 30% starting in 2030 for all single-use plastic bottles)
  • Bans on certain single-use plastic items (including straws, cutlery, and EPS plates) have been in effect since 2021/2022

Step-by-Step Checklist

(a) Companies based in Italy

1. Determine your role: Producer, User, or both? (Difference: manufacturing empty packaging vs. filling/importing packaging)

2. Classify materials: Categorize all packaging materials according to the EU code; plastics according to the COREPLA category

3. Register with CONAI & pay fees

4. Obtain CONAI membership number and include it on commercial documents and marketplace account

5. Affix environmental labeling to all packaging: Material code + disposal instructions in Italian

6. Reporting frequency (monthly / quarterly / annually depending on CAC amount)

7. Report quantities via CONAI Online and pay CAC on time

8. Ensure recycled content for PET bottles (25% starting in 2025)

9. Keep an eye on the PPWR roadmap for labeling (transition period until Aug. 2028)

(b) Companies from other EU countries

1. Appoint an authorized representative or EPR service provider in Italy, or ensure direct access

2. Option A – Direct registration with CONAI: Italian VAT number required

3. Option B – EPR service provider: The service provider registers, reports, and pays on behalf of the foreign company

4. Record all packaging volumes delivered to Italy – including shipping cartons, filling material, and service packaging

5. Ensure environmental labeling in Italian on all B2C packaging for the Italian market

6. Report volumes according to schedule; pay CAC on time

7. Register CONAI membership number with Amazon.it and other platforms

(c) Companies from third countries (outside the EU)

1. Mandatory: Appoint an authorized representative in Italy –

2. Complete all steps listed under (b) through the authorized representative

3. Customs / Logistics: Ensure that shipping packaging (e-commerce) is included in the quantity declaration

4. Environmental labeling in Italian on all packaging reaching Italian end customers

Step-by-Step Checklist

(a) Companies based in Italy

1. Determine your role: Producer, User, or both? (Difference: manufacturing empty packaging vs. filling/importing packaging)

2. Classify materials: Categorize all packaging materials according to the EU code; plastics according to the COREPLA category

3. Register with CONAI & pay fees

4. Obtain CONAI membership number and include it on commercial documents and marketplace account

5. Affix environmental labeling to all packaging: Material code + disposal instructions in Italian

6. Reporting frequency (monthly / quarterly / annually depending on CAC amount)

7. Report quantities via CONAI Online and pay CAC on time

8. Ensure recycled content for PET bottles (25% starting in 2025)

9. Keep an eye on the PPWR roadmap for labeling (transition period until Aug. 2028)

(b) Companies from other EU countries

1. Appoint an authorized representative or EPR service provider in Italy, or ensure direct access

2. Option A – Direct registration with CONAI: Italian VAT number required

3. Option B – EPR service provider: The service provider registers, reports, and pays on behalf of the foreign company

4. Record all packaging volumes delivered to Italy – including shipping cartons, filling material, and service packaging

5. Ensure environmental labeling in Italian on all B2C packaging for the Italian market

6. Report volumes according to schedule; pay CAC on time

7. Register CONAI membership number with Amazon.it and other platforms

(c) Companies from third countries (outside the EU)

1. Mandatory: Appoint an authorized representative in Italy –

2. Complete all steps listed under (b) through the authorized representative

3. Customs / Logistics: Ensure that shipping packaging (e-commerce) is included in the quantity declaration

4. Environmental labeling in Italian on all packaging reaching Italian end customers

Are you planning to sell your products in Italy?

We’ll help you ensure compliance with Italy’s EPR regulations for packaging so you can get started with legal certainty.

Are you planning to sell your products in Italy?

We’ll help you ensure compliance with Italy’s EPR regulations for packaging so you can get started with legal certainty.

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn