EPR in Italy: CONAI, the environmental contribution, and the labelling rule sellers miss

Who is obligated

Italy assigns the obligation to whoever first places packaging on the Italian market. For a cross-border online seller shipping direct to Italian consumers, that is you. There is no small-seller exemption and no volume threshold to clear before the duty starts, which puts Italy in the same camp as France and Spain.

If an Italian importer or distributor buys your goods and puts them on the market, the obligation follows them instead. The test is who performs the first placing on the Italian market, not who manufactured the product or printed the box.

CONAI and the contributo ambientale

CONAI is the national packaging consortium. You join CONAI, and the material consortia sit underneath it: Comieco for paper and board, Corepla for plastic, Coreve for glass, Ricrea for steel, CiAl for aluminium, Rilegno for wood, and Biorepack for compostable bioplastics. What you pay is the contributo ambientale CONAI, the CAC, calculated per tonne by material on everything you place on the Italian market.

What the rates look like in 2026

The plastic bands are the number to pay attention to. An eighteen-fold spread between the easiest and hardest band means the same weight of packaging can cost dramatically different amounts depending on whether it can actually be sorted and recycled in Italian infrastructure. A mono-material PE mailer and a metallised multi-layer pouch are not in the same financial universe here.

Declaration frequency depends on how much contribution you owe. Small contributors declare annually; larger ones move to quarterly or monthly declarations. Your consortium tells you which band you are in when you join.

If you have no Italian entity

A foreign producer without a legal presence in Italy generally joins CONAI voluntarily, electing a special domicile in Italy, and usually appoints a local representative to handle registration, declarations, and correspondence with the authorities and consortia. Whether Italy will oblige non-EU sellers to appoint a representative under PPWR is its own decision, and its coordination decree is due by 9 December 2026, so confirm your position with CONAI rather than assuming. From 12 August 2026 the EU Packaging Regulation does require an EU-established seller to appoint a representative in each member state it is not established in, so an Italian appointment can be one of several you make.

The labelling rule that catches sellers

Legislative Decree 116/2020 amended Article 219(5) of the Italian environmental code, and since 1 January 2023 environmental labelling has been mandatory on packaging placed on the Italian market. There are two separate obligations inside it, and they have different scopes.

1. Material identification, on all packaging. Every packaging component carries the alphanumeric code from Commission Decision 97/129/EC, for example PAP 20 for corrugated board, PP 5 for polypropylene, ALU 41 for aluminium. This applies whether the packaging goes to a consumer or only ever moves between businesses.
2. Disposal information, on packaging that reaches consumers. Packaging destined for households must also tell the consumer where to put it, and it has to do so for each manually separable component. Packaging that only ever travels business to business is exempt from this second part.

Fines for incorrect or missing labelling run from €5,000 to €25,000, and the person on the hook is whoever put the packaging on the Italian market. Because the label is physically visible on every parcel you ship, this is one of the easiest obligations in the EU for an authority or a competitor to verify.

What PPWR changes for Italy

From 12 August 2026 the EU Packaging Regulation applies directly in Italy alongside the national framework: a packaging authorised representative for an EU-established seller not established in Italy, conformity documentation per packaging type, and new PFAS limits in food-contact packaging. For non-EU sellers, Italy's own choice on requiring a representative is not yet settled. Italian producer registration through CONAI and the national arrangements carries on as before rather than restarting, and PPWR's own national packaging register is a later step that member states set up after the implementing act fixing the registration format. The EU's own harmonised sorting label, based on standard pictograms, only becomes mandatory on 12 August 2028. Until then the Italian format is what has to be on your packaging, so do not wait for the EU pictograms to solve this.

Electronics and batteries have their own Italian registers

Packaging is one stream. If you sell anything with a plug or a cell, Italy runs a separate producer register for electrical and electronic equipment through the chambers of commerce, with its own registration, consortium membership and reporting. Same principle, different paperwork. See WEEE and battery registration for online sellers.

How Italy compares with Germany, France and Spain

The shape is familiar: register, join a scheme, declare, label. The differences are that Italy prices per tonne rather than per kilo, that its plastic banding is unusually aggressive at the top end, and that its labelling rule is both older and more granular than Spain's sorting indication and structured differently from France's Triman and Info-Tri. If you have already done Germany, the CONAI declaration will feel routine and the labelling will not.

How Assuro helps

Assuro totals packaging by material across your Shopify catalogue so a CONAI declaration starts from real numbers, flags Italy as a likely obligation when you ship there with no registration on record, and tracks the declaration window. It organizes and flags. It does not join CONAI for you, act as your Italian representative, file declarations, or approve label artwork.

• If you have no Italian entity, check whether you must appoint an Italian representative or can register with a special domicile
• Join CONAI and the relevant material consortia
• Work out your packaging weight per material, per year
• Declare on the frequency your contribution level requires
• Put the 97/129/EC alphanumeric code on every packaging component
• Add disposal information for each manually separable component that reaches a consumer
• Diarise 12 August 2026 for PPWR and 12 August 2028 for the EU harmonised label