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Packaging obligations in Italy (2026)

Verified on: 2026-09-01

Draft
2 documented obligationsAuthorised representative: depends on situation2 Providers →
Legal framework (EU & national)
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.

AuthorityMinistero dell'Ambiente e della Sicurezza Energetica (MASE)
Authorised representativedepends on situation
DeadlinesJoin 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.
CostsCAC 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 (€300 under the flat-rate/simplified procedures), no periodic declaration; flat-rate procedure for importers by turnover band (prior-year turnover up to €200,000: exemption). Note: from 1 Oct 2026 CONAI raises the rates of all nine plastic fasce (+2% to +33%, e.g. fascia A1.1 from €40 to €51/t; board decision of 25 May 2026) and is also adjusting the flat-rate/simplified import procedures.

Your to-dos

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Providers for this obligation:CONAI – Consorzio Nazionale ImballaggiCO.N.I.P. – Consorzio Nazionale Imballaggi PlasticaCompare all schemes & representatives for Italy →
Why does this affect me 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.
Required documents
  • Packaging volumes by material (and fascia for plastic/paper) for the CAC declarations
  • Membership form for foreign companies including designation of the service address in Italy (if joining voluntarily)
Sources & verification status

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.

AuthorityMinistero dell'Ambiente e della Sicurezza Energetica (MASE)
RegisterRENAP – Registro Nazionale dei Produttori
Authorised representativeunclear
DeadlinesPackaging section not yet operational as at 1 Sep 2026 (renap.gov.it still lists only electrical equipment, batteries and tyres); 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. At EU level, the consultation on the draft implementing regulation with the harmonised format for national packaging producer registers (Art. 44 PPWR) also ran until 10 Sep 2026.

Your to-dos

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Providers for this obligation:CONAI – Consorzio Nazionale ImballaggiCompare all schemes & representatives for Italy →
Why does this affect me 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.
Sources & verification status

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Legal information, not legal advice. The linked official sources prevail; data marked “draft” has not been finally verified.