Italy — packaging EPR

Does it apply to me?

Italy's packaging framework sits mainly in Legislative Decree 152/2006 and is administered through CONAI, the National Packaging Consortium. Packaging imported from abroad is subject to the environmental contribution because its use generates waste on Italian territory — which is the principle that reaches you.

You ship to Italian consumers, no Italian establishment

Yes from 12 August 2026 under the PPWR. Under the current CONAI rules you may already be covered — see the platform question first, because it changes the answer.

You sell through a platform with a CONAI arrangement

The platform may be handling the contribution. CONAI recognises simplified arrangements agreed between platforms and EPR systems. Establish which world you are in before doing anything.

You sell from your own shop, no platform

Then it is yours. CONAI states that where the business does not use the platform service, it must join and complete the necessary obligations.

You're established outside the EU

Caught by the PPWR producer definition. Whether Italy took the Art. 45(3) second-sentence option on the representative is not published as far as we can find.

You brand your own packaging

Then the labelling section below is not optional reading. It is the duty most likely to cost you a print run.

Ask your platform first

Italy is the one country in these desks where the first question is not about the register at all.

So the sequence is: ask the marketplace, in writing, whether it operates a CONAI arrangement covering your sales, and get the answer before you sign anything with anyone. Two failure modes follow from skipping it — paying a contribution the platform already paid, or assuming it did when it did not.

Note that this is an arrangement about the CAC, the environmental contribution. It is not a substitute for Art. 44 registration under the PPWR, which is a duty on the producer, and a platform arrangement does not discharge it.

CONAI and the seven consortia

CONAI sits above seven material consortia. You deal with CONAI; the consortia do the material-specific work.

An approved autonomous system exists in law as an alternative. It is not a practical route for an ordinary small business, and we mention it only so you recognise the term if a consultant offers it.

The foreign-company route

CONAI has a dedicated door for companies established abroad, and it is an email address rather than a portal:

One nuance worth being precise about. Under the national CONAI rules, membership for a foreign seller is framed as optional — the CAC is otherwise owed, declared and paid by whoever carries out the placing, unless it has already been paid by a foreign company that has (optionally) registered with CONAI. That optionality belongs to the Italian contribution system.

The labelling duty, live now

This is the section to read if you read nothing else on this page.

Three reasons this catches people. It is a national duty, so it does not appear in EU-level PPWR summaries. It applies now, unlike the Art. 12(1) harmonised sorting label, which is 2028 at the earliest. And it lands on the artwork rather than on a form — which means the cost of finding out late is a print run, not a filing.

The harmonised PPWR labelling system will progressively replace or modify national requirements. That is a reason to check CONAI's current labelling guidance before you print, not a reason to wait: the Italian duty is what applies to the boxes you ship this month.

What it costs

CONAI membership includes a one-time fixed participation fee of €5.16, with a possible variable component. That is not a typo, and it is the smallest joining fee in any of our desks. The money is in the contribution.

Declarations

Periodic declarations are normally due by the 20th day of the month following the reporting period, submitted through CONAI's online declaration portal. Since 2026 the online declaration service is mandatory for compiling and submitting all forms, including contribution requests and exemption/reimbursement requests — there is no paper route left.

Small importers may be eligible for simplified or flat-rate procedures. Ask about these by name; they are the kind of thing that exists in the guide and does not get volunteered.

The representative

From 12 August 2026 Art. 45(3) requires a producer established in another member state or a third country selling packaged products directly to Italian end users to appoint an EPR authorised representative established in Italy.

Italy had not published an official PPWR representative register or appointment procedure when we checked. There is a useful national precursor, though: CONAI guidance already allows a foreign company that joins voluntarily to elect a special domicile in Italy with an appointed person or legal entity.

What changed for 2026

CONAI publishes an annual guide, and the 2026 edition made three changes worth knowing about even if you are new to Italy:

Export reimbursement threshold doubled

From €25,000 to €50,000 under the simplified procedure. If you bring packaged goods into Italy and ship some back out again, this is money.

Group-company reimbursement procedure

A new reimbursement/exemption route for exporting companies belonging to the same corporate group.

Online declaration made mandatory

For all forms, including contribution requests and exemption or reimbursement requests.

Contribution values also moved: from 1 January 2026 for wood, plastic band B1.2 and glass, and from 1 July 2026 for biodegradable and compostable plastic. Rates in Italy move more often than in most member states — take them from the current guide rather than from a desk.

If you don't

Enforcement runs under Legislative Decree 152/2006, alongside the CAC liability itself. We do not have a verified headline figure and will not invent one.

The distinctively Italian exposure is the labelling one. It is separately enforceable, it is visible on the product rather than buried in a filing, and it is the requirement a foreign seller is most likely to have been breaching without knowing — on every parcel, for as long as they have been shipping.

And underneath, Art. 44(4): until the register entry exists you may not make packaging available on the Italian market at all.

Known traps

Sources

The Italian statute establishes the framework and the labelling duty. CONAI is the consortium and the source for the contribution mechanics — useful, and not a neutral source.

1. CONAI — Contributo Ambientale (CAC) Scheme source. Source for the contribution being owed on packaging imported from abroad because its use generates waste in Italy, for the CAC being declared and paid by whoever carries out the placing unless already paid by a foreign company optionally registered with CONAI, and for the declaration frequencies and the 20th-of-the-following-month deadline
2. CONAI — Guida al Contributo Ambientale 2026 Scheme source. The annual reference guide. Source for the 2026 changes: the export reimbursement threshold doubling from €25,000 to €50,000, the new group-company reimbursement procedure, mandatory online declaration for all forms, and the contribution changes for wood, plastic band B1.2, glass and compostable plastic
3. CONAI — membership and the seven material consortia Scheme source for the €5.16 one-time participation fee, the dedicated foreign-company route at aziendaestera@conai.org, the special-domicile arrangement for voluntarily joining foreign companies, the platform simplified arrangements, and RICREA, CIAL, COMIECO, RILEGNO, COREPLA, BIOREPACK and COREVE
4. Legislative Decree 152/2006 — Codice dell'ambiente The national framework. Source for the environmental labelling duty: material identification using the Commission Decision 97/129/EC code plus separate-collection information for consumers
5. Regulation (EU) 2025/40 (PPWR) — EUR-Lex Read in full, 14 August 2026. Source for Art. 3(1)(15)(c)–(d) on the distance-selling producer, Art. 44(2) and 44(4) on registration, Art. 45(3) on the representative and Art. 12(1) on the 2028 harmonised label
6. European Commission — PPWR Frequently Asked Questions, 2nd edition DG ENV Unit B01, August 2026 (KH-01-26-068-EN-N). Read in full

Help us finish this desk

This draft was assembled on 15 August 2026 from CONAI's published material, the 2026 guide and a contributed country profile. It has not been checked by anyone who has been through the Italian process as a foreign seller, and it has no keeper.

Four things we specifically don't know. Which platforms actually operate a CONAI arrangement, and what it covers — this is the single most useful thing a member could tell us. What the simplified or flat-rate procedure for small importers involves in practice. Whether the CONAI special domicile is being accepted as an Art. 45(3) appointment, or whether providers are documenting both. And how the labelling duty is being enforced against foreign distance sellers, if at all.