Italy EPR Packaging Compliance: CONAI, CAC, and What Sellers Must Know

Italy's EPR System: Distinct and Underestimated

Italy's EPR system is often underestimated by international sellers focused on German LUCID and French Citeo. But Italy is the EU's fourth-largest e-commerce market — and its packaging compliance system has several features that trip up the unprepared.

Italy's packaging EPR operates through CONAI (Consorzio Nazionale Imballaggi) and six material-specific consortia. The legal basis is Legislative Decree 152/2006, amended by 116/2020 and 152/2022.

Here's what you need to know, in order.

Is Italy EPR Obligatory for You?

You have packaging EPR obligations in Italy if you are:

• A manufacturer, importer, or re-seller placing packaged goods on the Italian market
• A marketplace seller shipping to Italian consumers
• An Italian company reselling imported packaged products

*No minimum threshold** — like Germany and France, obligations attach from the first unit.

If you are a non-Italian entity (EU or non-EU) selling into Italy, you need an Authorised Representative established in Italy. This is a legal obligation, not optional.

Step 1: Join CONAI

*CONAI** is the umbrella organisation that coordinates packaging compliance in Italy. You join CONAI directly, and CONAI distributes your contribution to the appropriate material consortia.

Registration process:

1. Visit the [CONAI portal](https://www.conai.org) and create an account 2. Submit your company details, VAT number, and legal representative information 3. Declare your packaging types and estimated volumes 4. Pay the annual membership fee (~€20–€100, depending on company size)

*Lead time**: 1–2 weeks.

CONAI membership is mandatory before you can declare or pay the CAC (Contributo Ambientale CONAI).

Step 2: Understand the Material Consortia

CONAI delegates collection, sorting, and recycling to six material-specific consortia:

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You don't contract with these consortia directly. Your CONAI registration covers them all. But you declare volumes by material, and each consortium's rates apply to your corresponding material volumes.

Step 3: Pay the CAC (Contributo Ambientale CONAI)

The CAC is a per-kg fee applied to each packaging material. Rates for 2026:

|----------|-----------|

Plastic has the widest rate range due to eco-modulation — easily recyclable plastics (PET, HDPE) at the lower end, complex/multi-layer plastics at the higher end.

Declaration Cadence (This Catches People)

Your CAC declaration frequency depends on your prior-year CAC total:

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This is important: if your business grows and your CAC crosses a threshold, your declaration frequency changes. Missing a declaration because you were on annual and now need quarterly is a common compliance gap.

*How to manage this**: Track your running CAC total throughout the year. CONAI notifies you of threshold changes, but the notification may arrive after the deadline has passed. Be proactive.

Step 4: Environmental Labelling

Since January 2023, Italy requires mandatory environmental labelling on all packaging. This is different from France's Triman/Info-Tri system.

What must appear on the label:

1. Material identification code per Decision 97/129/EC (e.g., "PAP 20" for corrugated cardboard, "PET 1" for PET plastic) 2. Sorting instructions in Italian — which bin the consumer should use 3. Optionally: the type of packaging ("Bottle", "Box", "Wrapper")

Format:

• Can appear on the packaging itself, on a label, or on accompanying documentation
• Digital delivery is acceptable for products sold online, but only if the information is clearly accessible before purchase
• Must be in Italian

Common enforcement issues:

• English-only labels on products sold to Italian consumers
• Missing material codes on secondary packaging (the outer box needs labelling too)
• Digital-only Info-Tri that isn't easily findable from the product page

Step 5: Annual Declaration

Every year, you file an annual declaration with CONAI covering all packaging placed on the Italian market in the previous calendar year. This is the reconciliation step:

1. Declare total kg per material (paper, plastic, glass, aluminium, steel, wood) 2. Calculate your annual CAC 3. Compare to what you've already paid through periodic declarations 4. Pay any balance due (under-declaration) or carry forward credit (over-declaration)

*Deadline**: For annual declarers, 20 January. For quarterly declarers, the Q4 declaration serves as the annual reconciliation.

Italy vs Germany vs France — Quick Comparison

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Special Case: WEEE in Italy

If you also sell electronics in Italy, WEEE is separate from packaging. You need:

• Registration with Registro AEE (registroaee.it)
• Membership in a WEEE consortium (Ecodom, Ecoelit, Ecolamp, etc.)
• Separate WEEE fee schedule and reporting

Italy's WEEE system is administered by the Ministry of Environment through the CdC RAEE (Centro di Coordinamento RAEE).

Action Checklist

• ☐Register with CONAI and receive your membership number
• ☐Identify all packaging materials and estimate annual volumes (kg per material)
• ☐Determine your CAC declaration frequency (annual/quarterly/monthly)
• ☐Apply environmental labelling to all packaging (material codes + sorting in Italian)
• ☐Set up a declaration calendar — don't rely on CONAI reminders
• ☐If non-Italian entity, appoint an Authorised Representative
• ☐If selling electronics, register with Registro AEE separately
• ☐Build a CAC tracking spreadsheet — monitor your running total against thresholds
• ☐File annual declaration and reconciliation by the appropriate deadline

This article provides general guidance and does not constitute legal advice. EPR requirements change frequently. Verify details with CONAI, your material consortia, and your legal counsel.