Italian EPR: How to Register With CONAI and Pay Your Eco-Contributions

Selling into Italy makes you responsible for the packaging in which your orders are delivered. Italian environmental legislation imposes this Extended Producer Responsibility (EPR) obligation, and it applies to foreign sellers under the exact same conditions as Italian producers. It is administered by a private consortium, rather than a government ministry. To be compliant, you must register, submit regular declarations, and apply specific environmental labelling. Most sellers discover this labelling obligation too late. Read on to stay one step ahead.

Key Takeaways

• Packaging EPR in Italy is managed by CONAI, the national packaging consortium, which is funded by an eco-contribution known as the CAC.
• The contribution is payable upon the "first placing on the market" of packaging in Italy, which, for cross-border e-commerce, corresponds to the point of importation.
• Rates in 2026 range from 5 euros per tonne for steel to 922 euros per tonne for the least recyclable plastics.
• Declarations must be submitted before the 20th of the month following the reference period (annual, quarterly, or monthly), depending on the value of your contribution.
• Packaging sold in Italy must legally feature environmental labelling—a legal obligation completely distinct from the payment of the eco-contribution.

What Packaging EPR in Italy Covers

Italy enforces Extended Producer Responsibility (EPR) for packaging through CONAI, a consortium established under Legislative Decree 152/2006. Membership funds collection and recycling via six material-specific consortia (covering steel, aluminium, paper, wood, plastic, and glass). The system is funded by the Contributo Ambientale CONAI, generally abbreviated as CAC (environmental contribution). Member companies apply this fee to the packaging they place on the Italian market.

Two parallel obligations coexist and are frequently confused: on the one hand, you must pay this eco-contribution, and on the other, you must print the regulatory labelling that must appear on every package shipped.

Who Must Register With CONAI?

The obligation is triggered by the "first placing on the market" of packaging in Italy. This includes the final Italian producer selling finished packaging to an end-user, as well as packaging imported into the country for the shipment of goods. If you are a foreign online retailer shipping parcels to Italian customers, you are legally placing packaging on the Italian market.

Sellers who do not have a permanent establishment in Italy cannot submit a declaration themselves. You must appoint an authorised representative established in Italy, possessing an Italian VAT number and a certified email address (PEC), to register and submit declarations on your behalf. Although the European Packaging and Packaging Waste Regulation has been applicable since 12 August 2026, producer registration is still managed at a national level. An Italian representative cannot fulfil your obligations in Spain or Germany.

How to Join CONAI, Step by Step

None of these steps are immediate; do not leave them until the week before you launch in the Italian market.

1. Submit your membership application to CONAI and pay the one-off registration fee, which is determined by your company category.
2. Receive your membership number and activate your access to the online declaration portal.
3. Classify each component of your packaging by material type and, for plastic and paper, by its level of recyclability.
4. Apply the corresponding contribution and indicate it on a separate invoice line, detailed by material and by level.

The classification step requires the most effort. A single e-commerce parcel can easily fall under three or four different contribution categories.

What is the Cost of the Eco-Contribution in 2026?

Note: The figures given above are the initial published rates for 2026. Companies are advised to consult the official CONAI website to check current rates, as these are subject to regular revision.

Plastic and paper are classified according to their level of recyclability, meaning the actual design of your packaging has a direct impact on your final bill. The base rate for plastic rises to 51 euros per tonne from October 2026, while composite paper packaging costs several times the price of a single-material cardboard box. For example, a cardboard mailer containing plastic loose fill can cost significantly more in eco-contributions than the exact same order shipped in a 100% single-material box.

Declare and Pay Without Missing a Deadline

Declarations are processed via the CONAI online portal and must be submitted before the 20th of the month following the reference period. During their first year, new members submit a quarterly declaration. Thereafter, the frequency depends on the amount of eco-contribution declared per material during the previous year:

• Up to 3,000 euros: Annual declaration, to be submitted before 20 January.
• From 3,001 to 31,000 euros: Quarterly declaration, to be submitted before 20 April, 20 July, 20 October, and 20 January.
• More than 31,000 euros: Monthly declaration, to be submitted before the 20th of the following month.

CONAI invoices each material separately. Payment is triggered upon receipt of the invoice, not at the time of declaration. Failing to declare or under-declaring volumes constitutes a severe infringement of Italian environmental legislation, punishable by fines of up to 100,000 euros in the most serious cases.

Environmental Labelling: The Obligation Sellers Forget

Since 1 January 2023, packaging placed on the Italian market must legally bear environmental labelling, in accordance with Legislative Decree 116/2020. Each component must display its alphanumeric material code from European Commission Decision 97/129/EC (for example, PAP 21 for corrugated cardboard or LDPE 4 for a polyethylene bag). In addition, packaging destined for consumers (B2C) must include clear sorting instructions, informing the buyer which recycling bin to use for each packaging element.

This rule applies equally to B2B (commercial) and B2C (consumer) packaging. As this labelling is not recorded in any central database, the responsibility lies entirely with the person who approves the design of your packaging. The issue generally resurfaces when a customer, a marketplace, or a customs inspector demands proof of compliance.

Ship to Italy Without Using Multiple Providers

Compliance with CONAI remains your strict legal responsibility, and no logistics provider can fulfil it on your behalf. However, the operational and customs management of your shipments to Italy is a completely different matter. Backed by Bnode (formerly bpostgroup), Landmark Global delivers to Italy and 220+ destinations via a carrier-neutral network. We rely on in-house customs teams and our proprietary Mercury platform to consolidate your carrier selection, tracking, and customs data under a single integration, replacing the operational overhead of managing separate provider relationships. 

Are you running a multi-carrier setup to Italy? Speak to our team to benchmark your current delivery mix against a carrier-neutral alternative and see how the Mercury platform can consolidate your customs and tracking data.

Sources:

• CONAI, EPR Fee: https://www.conai.org/en/companies/services-for-managing-consortium-obligations-and-business-opportunities/epr-fee/ 
• CONAI, Declaration and payment: https://www.conai.org/en/companies/services-for-managing-consortium-obligations-and-business-opportunities/epr-fee/declaration-and-payment/ 
• Lovat Compliance, Italy EPR Guide: https://vatcompliance.co/guides/epr/italy/ 
• UL Solutions, Italy: Environmental Labeling Requirements for Packaging: https://www.ul.com/news/italy-environmental-labeling-requirements-packaging