EPR Requirements Italy: The Compliance Guide for Packaging Producers and Importers

EPR requirements Italy centre on three duties: registering with CONAI, the national packaging consortium; declaring the packaging you place on the Italian market; and paying the Contributo Ambientale CONAI, known as the CAC. Any business that places packaged goods on the Italian market falls in scope, including Italian producers, EU importers, brand owners, and e-commerce sellers shipping directly to Italian consumers. From 12 August 2026 the EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, adds a second layer on top of these national duties, and it does not replace them.

Key takeaways

• Italy’s packaging EPR runs through CONAI under Leg. Decree 152/2006, reformed by Leg. Decree 116/2020.
• Core duties: register, declare packaging by material, pay the Contributo Ambientale CONAI (CAC), and label every component.
• Environmental labelling has been mandatory since 1 January 2023, using Decision 97/129/EC material codes.
• Foreign and non-EU sellers that ship packaged goods to Italy generally hold the obligation and can register with CONAI directly.
• PPWR (Reg. (EU) 2025/40) applies from 12 August 2026 and runs in parallel with CONAI until 11 August 2028.

What EPR requirements Italy cover for packaging

They are the packaging Extended Producer Responsibility obligations that apply when packaging is released for consumption in Italy, run through CONAI under Italian environmental law.

EPR requirements Italy sit on the principle of Extended Producer Responsibility, where the company that places packaging on the market pays for its collection, sorting, recycling, and recovery. The legal foundation is the Italian Environmental Code, Legislative Decree 152/2006, reinforced by Legislative Decree 116/2020, which transposed the EU waste and packaging directives and introduced mandatory environmental labelling for packaging.

In practice, EPR requirements Italy operate through CONAI and its material-specific consortia for steel, aluminium, paper, wood, plastic, glass, and bioplastics, with each consortium managing one packaging stream. Because CONAI has run since the 1990s and was reformed in 2020, Italy now applies one of the more detailed eco-modulation systems in the EU, where the fee you pay varies with how recyclable each material is.

• Legal basis: Italian Environmental Code (Leg. Decree 152/2006) and Leg. Decree 116/2020.
• Operated by CONAI and its material consortia (steel, aluminium, paper, wood, plastic, glass, bioplastics).

Ready for PPWR EPR Registration?Determine where your business has EPR obligations, identify the packaging data you need, and streamline registration and reporting across EU markets.

Who must comply with EPR requirements Italy

The first company placing packaged goods on the Italian market, whether it is established in Italy or abroad.

The party that carries EPR requirements Italy is usually the first business to place packaged goods on the Italian market. That can be an Italian manufacturer, an importer bringing goods into Italy, a brand owner selling under its own name, an Italian distributor, or an online seller shipping directly to consumers. All packaging counts, including product packaging, shipping boxes, filler, tape, labels, and pallets.

Foreign companies are not exempt. Both EU and non-EU sellers can register with CONAI directly, provided they hold an Italian tax identification number, and many appoint an authorised representative to handle filings even though this step is optional. One point deserves care: under PPWR, an importer must be established in the EU, so a company based outside the EU is treated in law as a non-EU producer rather than an importer, which affects how EPR requirements Italy and the wider EU rules assign responsibility.

Core obligations under EPR requirements Italy

Register, declare packaging volumes on a set cadence, pay the CAC, apply eco-modulated fees, and label every component.

Four obligations sit at the centre of EPR requirements Italy. First, register with CONAI before packaging reaches the Italian market. Second, declare the quantity and material of packaging released for consumption, on a cadence that is annual, quarterly, or monthly depending on your prior-year CAC value. Third, pay the Contributo Ambientale CONAI, the fee that funds separate collection and recycling. Fourth, apply environmental labelling to each packaging component.

Labelling has been mandatory since 1 January 2023 and must show the material identification code from Commission Decision 97/129/EC, with disposal instructions written in Italian on packaging aimed at consumers. Meeting EPR requirements Italy therefore depends on packaging data that is accurate at material level, because both the fee you pay and the label you print flow directly from that data.

• Register, then declare packaging by material and quantity.
• Pay the CAC; cadence is annual, quarterly, or monthly by prior-year value.
• Label each component (material code + disposal instructions in Italian).

Turn PPWR Compliance Into a Structured Process. Don’t manage PPWR requirements across spreadsheets, supplier emails and disconnected documents. TraceX helps you centralize packaging data, connect suppliers and evidence, and build a structured compliance workflow.

How PPWR reshapes EPR requirements Italy from 2026

PPWR applies from 12 August 2026 and runs alongside CONAI until 11 August 2028, adding EU-wide duties rather than removing national ones.

From 12 August 2026, Regulation (EU) 2025/40, the PPWR, applies directly in Italy and every other member state. It does not switch off EPR requirements Italy; the CONAI system and PPWR run in parallel until 11 August 2028, so producers manage both frameworks at once during the transition period.

Two distinctions matter here. A recurring EPR volume declaration filed to CONAI is not the same document as a PPWR Declaration of Conformity, which a manufacturer issues once per packaging design. Likewise, the PPWR manufacturer role, tied to design and the Declaration of Conformity, is separate from the PPWR producer role, which carries the EPR obligations. Reading EPR requirements Italy correctly means keeping these roles and documents apart rather than merging them.

Building an audit-ready system for EPR requirements Italy

Capture material-level packaging data continuously and map the responsible entity across every route to market.

Monthly filing leaves little room to rebuild packaging figures from spreadsheets after the fact, so the practical test of EPR requirements Italy is whether your evidence stays audit-ready throughout the year. That means recording packaging weight and material for every product, tracking the eco-modulation inputs behind each fee, and mapping which entity is responsible when goods move through distributors, marketplaces, and fulfilment providers.

The same dataset then feeds your CAC declaration, your environmental labels, and, from 2026, your PPWR evidence. Treating EPR requirements Italy as a data problem rather than a once-a-year form is what keeps the national and EU systems aligned while the parallel period runs.

Penalties and common mistakes with EPR requirements Italy

Non-registration, under-declaring volumes, and missing labels are the frequent failures, and enforcement is tightening.

Enforcement against businesses that skip registration or under-declare is increasing, which raises the cost of getting EPR requirements Italy wrong. The most common errors are assuming the rules apply only to companies established in Italy, forgetting that shipping boxes, filler, tape, labels, and pallets all count as packaging, and treating environmental labelling as optional.

Non-EU e-commerce sellers are especially exposed, because they often place packaging on the Italian market without realising they hold the obligation. A short internal assessment of your role, packaging flows, materials, and Italian-market volumes usually surfaces the gaps before an authority does.

Most teams miss Italy EPR filing dates not because the rules are unclear but because packaging data lives in scattered spreadsheets that are hard to reconcile at declaration time. The TraceX PPWR platform is built to hold packaging specifications at material and component level, so the same verified dataset can generate CONAI declarations, feed eco-modulation calculations, produce label content, and, from 2026, support PPWR evidence

Because the TraceX platform maps the responsible entity across producers, distributors, marketplaces, and fulfilment routes, it helps you show who placed which packaging on the Italian market when an authority asks.

EPR requirements Italy: manual approach vs the TraceX platform

Buyer checklist for EPR requirements Italy compliance

Use this checklist when scoping a tool or internal process to manage Italy packaging EPR:

• Confirms whether your entity is the obligated party across each route to the Italian market
• Stores packaging weight and material for every product and component
• Generates CONAI declarations on your filing cadence (annual, quarterly, or monthly)
• Supports Contributo Ambientale CONAI (CAC) calculation and eco-modulation inputs
• Produces environmental label content with Decision 97/129/EC material codes
• Handles PPWR duties in parallel with CONAI through the 2028 transition
• Keeps timestamped, audit-ready records for enforcement queries

frequently asked questions