Who must register for packaging EPR in Italy, and how

Last checked against Italian law and the CONAI guide on 29 September 2026. This is general information about Regulation (EU) 2025/40 and Italy's national EPR scheme, not legal advice. Thresholds, fees, penalty amounts and go-live dates come from national law and PRO schedules that change: treat every figure as needing a fresh check, and confirm anything you act on with the national authority or qualified counsel.

The scheme and what it involves

CONAI (Consorzio Nazionale Imballaggi) is the national packaging consortium; membership is mandatory for producers and users of packaging under Article 221 of Legislative Decree 152/2006 (or you set up an approved autonomous system). Joining carries a one-off fixed participation share of €5.16 (CONAI Statute art. 6(3)), plus a variable share for companies whose previous-year revenue exceeds €500,000. The fixed share is a membership fee, not a de-minimis threshold.

You then pay the Contributo Ambientale CONAI (CAC), charged per material, per tonne, at the moment of first transfer, with plastic and paper split into recyclability bands. Producers and importers of packaging also join the relevant material consortium; there are seven (CoReVe, Comieco, Rilegno, CiAl, Corepla, Ricrea and Biorepack).

Foreign and distance sellers

The CAC attaches to the first transfer in Italy, so it usually falls on the Italian importer or user rather than the foreign supplier. Under the CONAI guide a foreign company is not itself liable for the CAC, but it can join CONAI and meet the contribution for its Italian customers through an Italian fiscal representative or a direct VAT identification with a special domicile in Italy. No separate Italian rule requiring an authorised representative for packaging was located.

If you sell directly to Italian end users from another country, with no Italian importer in between, you are the producer for that packaging under PPWR, and Article 45(3) requires you to appoint an Authorised Representative for EPR in Italy from 12 August 2026. If you sell only to Italian businesses that resell the goods unchanged, they are the producer there and you need no representative.

De-minimis and reporting

There is no de-minimis on the obligation to join CONAI. On declaring and paying the CAC there is relief: under the ordinary procedure, nothing is declared or paid for a material whose CAC stays within €200 a year; under the simplified procedure the limit is €300 a year in total. Declaration frequency is set per material by the previous year's CAC, and each declaration is due by the 20th of the month after the reference period. Tariffs are re-modulated roughly twice a year (the 2026 changes applied from 1 January and 1 July 2026), so check the live schedule before quoting any rate.

Penalties

Not joining CONAI carries a fine of €5,000 (Art. 261(1), Legislative Decree 152/2006), and you still owe the joining share and any back contributions. A packaging producer that does not join its material consortium faces €15,500 to €46,500 (Art. 261(2)). Under the CONAI rules, serious CAC breaches, such as not applying the contribution or filing a late or wrong declaration, cost 50% of the sums due for a first breach and 150% for later ones. If you self-report (autodenuncia) before CONAI starts a check and declare the contribution due within 30 days, no penalty applies, though late-payment interest does.

How onerous is it?

Moderate. Membership is a low one-off fee and the per-material maths is simple, but it is mandatory from the first unit, carries per-material declarations on a monthly, quarterly or annual cadence, and the tariffs are re-modulated roughly twice a year, so a compliant filing needs regular re-checking.

Frequently asked questions