Packaging obligations in Italy (2026)
DraftVerified on: 2026-09-01
EU framework: PPWR (EU) 2025/40, applicable since 12 Aug 2026
National: D.Lgs. 152/2006 (Testo Unico Ambientale – consolidated environmental code), packaging title (Art. 217 et seq.) with the CONAI consortium system; Art. 178-ter (national producer register RENAP, DM No. 144 of 15 Apr 2024) and Art. 178-quater (simplified EPR fulfilment via e-commerce platforms). Responsible authority: Ministero dell'Ambiente e della Sicurezza Energetica (MASE).
Italy has no LUCID-style public packaging register in operation: packaging EPR runs through the CONAI consortium system (or recognised autonomous schemes such as CO.N.I.P. for plastic crates/pallets) with the Contributo Ambientale CONAI (CAC – CONAI environmental contribution), which falls due on the first transfer (prima cessione) on the Italian market. The national producer register RENAP (renap.gov.it, online since 7 May 2025) so far only covers the electrical equipment, batteries and tyres sections; according to a CONAI notice from spring 2026, the packaging section is 'di prossima attuazione' (coming soon). Until it goes live, the CONAI rules of the Guida 2026 continue to apply to EU foreign companies (no CONAI obligation of their own except for platform sales; voluntary membership possible).
Packaging EPR: CONAI membership & Contributo Ambientale (Italy)
The Contributo Ambientale CONAI (CAC) falls due on the first transfer of packaging on the Italian market. Anyone importing packaging or packaged goods into Italy (including intra-EU acquisitions) or producing/trading empty packaging in Italy must join CONAI, file periodic CAC declarations and pay the contribution. If you purchase in Italy, the CAC has already been settled via your supplier's invoice.
- Authorised representative:
- Formally, Art. 45 PPWR has required an authorised representative since 12 Aug 2026 in Member States where a distance seller without an establishment first makes packaging available. However, Italy does not yet have an operational registration/authorised-representative procedure for packaging: according to the CONAI Guida 2026, EU foreign companies have 'a oggi' (as at the Guida's date) no CONAI obligations of their own – except when selling via e-commerce platforms – and may join voluntarily (with a special service address in Italy, fixed membership quota €5.16). These rules explicitly apply until the RENAP packaging section goes live. Non-EU companies without an Italian establishment must provide security covering 12 months of CAC when joining.
- Cross-border:
- Practice for foreign online sellers: (1) selling via marketplaces/platforms – under Art. 178-quater D.Lgs. 152/2006, the EPR obligations can be fulfilled through simplified agreements between the platform and the EPR scheme; anyone not using the platform's offering must join CONAI themselves. (2) Selling via your own shop – currently no CONAI obligation of your own; without (voluntary) membership, your Italian business customers owe the CAC as importers. With voluntary membership, the foreign company is placed on an equal footing with domestic ones and also declares the packaging delivered to Italian private customers; invoices must then carry the CONAI CAC details.
- Costs:
- CAC rates per material (7 material types, with eco-modulated fascia banding for plastic and paper) are published in the Guida CONAI 2026; one-off membership quota (fixed €5.16 for foreign companies). Exemptions: up to €200 CAC per material, no periodic declaration; flat-rate procedure for importers by turnover band (prior-year turnover up to €200,000: exemption).
- Deadlines:
- Join before starting the activity subject to the contribution; declarations monthly/quarterly/annually depending on class. Export plafond returns (Mod. 6.5) due by the end of February each year.
Typical steps
- Clarify your role in the supply chain: importing empty or filled packaging into Italy (including intra-EU acquisitions)? Then CONAI membership and CAC declarations are required.
- If purchasing goods/packaging in Italy: check that the CAC is shown on supplier invoices – the contribution is then already settled.
- As a foreign direct seller: consider voluntary CONAI membership (form for imprese estere – foreign companies – with a special service address; contact aziendaestera@conai.org) or, for platform sales, use the simplified fulfilment via the platform.
- Determine your CAC declaration class: annually, quarterly or monthly depending on the previous year's CAC volume; up to €200 CAC per material an exemption from the periodic declaration applies.
- For imports, check the simplified procedures (including flat-rate CAC by turnover band; with prior-year turnover up to €200,000, full exemption under the flat-rate procedure).
- Determine the material classification and contribution bands (plastica/carta fasce – plastic/paper bands) with the CONAI tool 'Codice imballaggio'.
Providers for this obligation
Sources: CONAI – Guida all'adesione e all'applicazione del Contributo Ambientale 2026 (impresa estera S. 28 f., Erklärungsklassen und 200-€-Befreiung S. 63, Pauschalverfahren S. 4/69, Plafond S. 78 f.) (accessed 2026-09-01) · CONAI – Ankündigung der Guida 2026 (offizielle Quelle) (accessed 2026-09-01) · Normattiva – D.Lgs. 152/2006 (Art. 178-ter, 178-quater, 217 ff.) (accessed 2026-09-01) · CONAI-Mitteilung an Konsorten (04/2026) – RENAP für Verpackungen 'di prossima attuazione', Datenübermittlung durch CONAI (accessed 2026-09-01)
RENAP producer register for packaging (Italy, in preparation)
Italy is setting up the national producer register RENAP under Art. 178-ter D.Lgs. 152/2006 (portal online since 7 May 2025, so far covering the electrical equipment, batteries and tyres sections). The packaging section is in preparation: in future, all economic operators placing packaging on the Italian market will have to be registered there and report volumes – for CONAI members, the consortium can handle its members' registration.
- Authorised representative:
- How the RENAP packaging section will technically implement the PPWR authorised-representative requirement (Art. 45) for foreign distance sellers is still open (as of Sep 2026). The CONAI Guida 2026 explicitly ties the end of today's special rules for EU foreign companies to RENAP becoming operational.
- Cross-border:
- For foreign sellers, the RENAP launch is the key event: it is likely to bring the first direct registration obligation (replacing today's voluntary CONAI membership) together with an authorised-representative mechanism for distance selling into Italy. As at 1 Sep 2026, no official start date had been set.
- Deadlines:
- Packaging section not yet operational as at 1 Sep 2026; per the CONAI notice from spring 2026 it is 'di prossima attuazione' (coming soon). No official start date known – do not speculate; watch the portal.
Typical steps
- Watch for the launch of the RENAP packaging section (renap.gov.it and CONAI notices).
- As a CONAI member: keep your master data with the consortium up to date – CONAI will transfer its members' data to RENAP as soon as it is operational.
- As a non-member without an Italian establishment: once RENAP launches, review the registration route and authorised-representative requirements.
Providers for this obligation
Sources: RENAP-Portal – aktive Sektionen (AEE, Pile, Pneumatici; noch keine Verpackungen), Portalstart 07.05.2025 (accessed 2026-09-01) · MASE – Registro nazionale dei produttori (RENAP), Rechtsgrundlage Art. 178-ter Abs. 8 D.Lgs. 152/2006, DM Nr. 144/2024 (accessed 2026-09-01) · CONAI-Mitteilung (04/2026) – RENAP-Verpackungsregister in Kürze, Pflichteninhalt, Sammelanmeldung über Konsortien (accessed 2026-09-01) · CONAI – Guida 2026, S. 28: Sonderregeln für EU-Auslandsunternehmen gelten bis zur RENAP-Operativität (accessed 2026-09-01)
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