Who must register for packaging EPR in Italy, and how
Producers and users of packaging in Italy must join CONAI (the national packaging consortium) under Article 221 of Legislative Decree 152/2006, and pay the per-material environmental contribution (Contributo Ambientale CONAI, CAC). There is a one-off €5.16 membership share — not a threshold. For B2C distance sales the foreign seller is expected to register via an Italy-resident representative; this is indicative, confirm nationally.
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.
| Register / authority | CONAI membership (Art. 221, Legislative Decree 152/2006) |
|---|---|
| PRO / compliance scheme | CONAI plus the relevant material consortium (Corepla, Comieco, etc.) |
| Authorised Representative | Indicative — confirm nationally Indicative — confirm nationally (Art. 45 requires it from 12 Aug 2026) |
| De-minimis threshold | None to join; €200/material/yr to declare (ordinary) |
| National instrument | Article 221 of Legislative Decree 152/2006 |
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 CONAI carries a one-off fixed participation share of €5.16 (CONAI Statute art. 6(3)) — which is a membership share, 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. There are seven material consortia (CoReVe, Comieco, Rilegno, CiAl, Corepla, Ricrea and Biorepack).
Foreign and distance sellers (indicative)
Under CONAI the CAC obligation legally attaches to the first Italian entity (the importer or user). A foreign B2B seller has no direct CONAI obligation but may voluntarily appoint an Italian tax representative. For B2C distance sales (a foreign seller shipping directly to Italian consumers with no Italian importer of record) the foreign seller is expected to register and pay — in practice via an Italy-resident representative, and Italian marketplaces have required proof of CONAI registration since 2025/2026. This B2C position is established practice and marketplace enforcement rather than a single quoted CONAI clause — indicative, confirm nationally. PPWR's harmonised AR concept layers over this from 12 August 2026.
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, €200 of CAC per material per year (below which no periodic declaration for that material); under the simplified/import procedure, €300 total CAC per year; and under the import flat-rate, full exemption below €200,000 prior-year turnover. Declaration frequency is set per material by prior-year CAC, all due by the 20th of the month after the reference period. Tariffs are re-modulated roughly twice a year — re-verify the live schedule before quoting any rate.
Penalties
Failure to join a supply-chain consortium carries €15,500–€46,500; failure to register with CONAI, €5,000; a general environmental-management breach (art. 261, D.Lgs. 152/2006), €10,000–€60,000 plus back-contributions. CAC declaration or payment infractions run at 50% of the amounts owed (first) and 150% (subsequent), with a self-denunciation route to regularise penalty-free within 30 days.
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/annual cadence, and the tariffs are re-modulated roughly twice a year, so a compliant filing needs constant re-checking.
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Get my full PPWR obligations report →Frequently asked questions
Is the €5.16 a de-minimis threshold?
No. The €5.16 is a one-off fixed CONAI membership share (Statute art. 6(3)), not a small-quantity threshold. There is no de-minimis on the obligation to join CONAI at all; the relief is on declaring the CAC (€200/material/year ordinary, €300/year simplified).
As a foreign online seller shipping to Italian consumers, must I register?
For B2C distance sales the foreign seller is expected to register and pay the CAC, in practice via an Italy-resident representative, and marketplaces have required proof of CONAI registration since 2025/2026. This is established practice rather than a single quoted CONAI clause — treat it as indicative and confirm nationally.
How often do the CONAI (CAC) tariffs change?
Roughly twice a year. The per-material CAC is re-modulated periodically, so any rate you rely on is a decaying figure — re-verify the live tariff schedule before quoting or filing.
Sources
- CONAI — the environmental contribution (CAC), declaration and payment — https://www.conai.org/en/companies/services-for-managing-consortium-obligations-and-business-opportunities/epr-fee/declaration-and-payment/
- CiAl — 2025 CONAI environmental-contribution guide (€5.16 share, CAC rates) — https://www.cial.it/wp-content/uploads/2025/01/Guida_Conai_Contributo_Ambientale_2025.pdf
- CONAI obligations on import and distance sales (penalties, B2C practice) — https://www.tradecube.it/obblighi-conai-importazione/