D.Lgs 116/2020
Italy EPR — D.Lgs 116/2020. The regulatory authority is CONAI, operating through the CONAI system.
All producers, importers, online sellers, and fulfillment service providers placing packaged goods on the Italy market must register with a PRO and fulfill EPR obligations. Non-Italy sellers must appoint an Authorized Representative.
CONAI (Consorzio Nazionale Imballaggi) is the sole mandatory national packaging consortium. All producers and importers placing packaging on the Italian market must register with CONAI. Under CONAI, six material-specific consortia manage collection and recycling:
Registration: conai.org — Foreign companies: aziendaestera@conai.org
Reporting & Deadlines: Annual by May 20 (quarterly for >1M€). Packaging data must be reported by material type and weight. Reports are submitted through CONAI Registry.
Maximum Fine: €100,000. Non-compliance with Italy EPR regulations can result in fines, marketplace listing deactivation, and legal consequences. Amazon and other marketplaces may independently verify compliance and suspend non-compliant sellers.
CONAI membership and environmental labeling required
If you sell on Amazon, eBay, or other marketplaces and ship products to Italy, you are responsible for EPR compliance in this market. The "pay on behalf" model is ending — marketplaces will no longer handle this for you. Register now to avoid listing deactivation.
Follow these steps to become fully EPR-compliant in Italy. Foreign companies must appoint an Authorized Representative before starting.
Register with CONAI (Consorzio Nazionale Imballaggi) through conai.org. You will be classified as either a producer (if you manufacture packaging) or a user (if you use packaging for your products). Foreign companies should contact aziendaestera@conai.org for guidance.
Enroll with the relevant consortia under CONAI based on your packaging materials: Corepla (plastic), Comieco (paper/cardboard), CiAl (aluminium), CoReVe (glass), Ricrea (steel), or Rilegno (wood). Most e-commerce sellers need Corepla and Comieco at minimum.
Submit your packaging data through CONAI's CAC (Contributo Ambientale CONAI) system. Report by material type and weight. Annual declarations are due by May 20. Companies with turnover above a certain threshold must report quarterly. Costs depend on your packaging volumes and material types.
Upload your CONAI membership number and compliance documentation to Amazon Seller Central (under EPR compliance settings) and any other marketplace platforms. This prevents listing deactivation and demonstrates your compliance to the marketplace.
Complete your annual waste declarations through the MUD system or the new RENTRI (Registro Elettronico Nazionale per la Tracciabilità dei Rifiuti) national traceability register. Ensure all packaging carries mandatory environmental labeling as required by Decreto 228/2022.
The EU Packaging and Packaging Waste Regulation (PPWR) is a directly applicable regulation that will progressively replace the current Packaging Directive framework. For sellers operating in Italy, this means significant changes on top of existing CONAI obligations:
Italy will need to adapt its CONAI system and D.Lgs. 152/2006 framework to align with PPWR requirements. Sellers should monitor developments and prepare for additional obligations. Contact ekoniq for up-to-date guidance.
If your company manufactures products outside the EU and exports them to the European market, PPWR requires you to prove that your packaging meets EU sustainability standards — before your goods cross the border. ekoniq prepares the complete PPWR compliance package so you can export with confidence.
What we deliver (15–18 documents):
✓ Full Technical Documentation (Annex VII, Module A)
✓ EU Declaration of Conformity (Annex VIII)
✓ Recyclability assessment of all packaging
✓ Substance restriction verification (PFAS, heavy metals)
✓ Recycled content declaration
✓ Packaging minimisation statement
✓ Labeling guidance (material codes, sorting pictograms, QR)
✓ Accredited lab testing coordination (SGS, Intertek, Bureau Veritas)
✓ EPR registration in target EU countries
✓ Authorised Representative appointment (Article 45)
Many sellers make these mistakes when registering for EPR in Italy. Avoid them to stay compliant and prevent fines up to €100,000.
CONAI membership is mandatory for all companies placing packaging on the Italian market — there are no exceptions, no thresholds, and no alternative systems. Unlike some EU countries with multiple competing PROs, Italy has one mandatory national consortium. Skipping this step means you are non-compliant from day one.
CONAI is the umbrella consortium; the material-specific consortia (Corepla, Comieco, CiAl, CoReVe, Ricrea, Rilegno) operate underneath it. You need to join CONAI first, and then also register with each relevant material consortium. Joining only CONAI or only a material consortium is not sufficient.
Italy has mandatory environmental labeling on all packaging since Decreto 228/2022. Every packaging component must display material identification codes and disposal instructions. Many foreign sellers overlook this requirement because it is unique to Italy and not required in most other EU countries.
The CAC (Contributo Ambientale CONAI) is not optional. Many sellers join CONAI but fail to submit their packaging declarations and pay the environmental contribution. Costs depend on your packaging volumes and material types — but the obligation to declare and pay exists regardless of the amount.
RENTRI (Registro Elettronico Nazionale per la Tracciabilità dei Rifiuti) is Italy's new electronic waste traceability register. It is gradually replacing the older MUD declaration system. Many sellers are unaware of this requirement or assume CONAI membership alone covers all obligations. Failing to register with RENTRI is a separate compliance gap.
Yes, CONAI (Consorzio Nazionale Imballaggi) is Italy's sole mandatory national packaging consortium. All producers, importers, and sellers placing packaged goods on the Italian market must join CONAI. There are no alternative systems or opt-outs. CONAI coordinates six material-specific consortia that handle collection and recycling for each material type.
Since Decreto 228/2022, all packaging sold in Italy must carry environmental labeling. Each packaging component must show material identification codes (following Decision 129/97/EC) and disposal instructions for consumers. This applies to primary, secondary, and tertiary packaging. Non-compliant packaging can result in fines and product recalls.
RENTRI (Registro Elettronico Nazionale per la Tracciabilità dei Rifiuti) is Italy's new national electronic waste traceability register. It is replacing the older MUD declaration system with a digital platform for waste tracking. Registration deadlines are being phased in by company size. RENTRI is a separate obligation from CONAI membership — both are required.
Costs depend on your packaging volumes, material types, and whether you need an Authorized Representative. The CAC (environmental contribution) is calculated per kilogram for each material type. There is also a CONAI membership fee. Contact ekoniq for a personalized quote based on your specific situation.
If your company is not established in Italy, you must appoint an Authorized Representative (AR) to fulfill your EPR obligations. The AR handles CONAI registration, material consortia enrollment, CAC reporting, RENTRI registration, and annual declarations on your behalf. ekoniq can serve as your AR for Italy.
Amazon verifies EPR compliance for all EU marketplaces. If you have not uploaded a valid CONAI membership number for Italy, Amazon may deactivate your listings on amazon.it. To restore your listings, you must complete your CONAI registration and upload the membership details. ekoniq can expedite this process — contact us for urgent assistance.
CONAI registration typically takes several weeks, depending on the completeness of your documentation and whether you need an Authorized Representative. Material consortia enrollment is an additional step. ekoniq manages the entire process end-to-end — contact us for current processing times.
Complete overview of EPR packaging requirements across all 27 EU member states and EEA countries.
Key changes under the EU Packaging and Packaging Waste Regulation and how they affect online sellers.
Step-by-step guide to uploading your EPR registration numbers to Amazon Seller Central for all EU marketplaces.
Complete guide to LUCID registration and packaging compliance in Germany — the EU's largest market.
ekoniq handles your complete EPR registration and compliance. We take care of registration, reporting, and ongoing obligations so you can focus on selling.
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