Any company that places packaged goods on the Italian market carries a packaging Extended Producer Responsibility (EPR) obligation. In Italy, that obligation runs through CONAI, the national packaging consortium, and is paid through the Contributo Ambientale CONAI (CAC). From 12 August 2026, a second layer applies on top of it: the EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, which is directly applicable in every member state.

This guide explains who must register, how the CAC works, what the reporting cadence is, and how Italy's national system interacts with PPWR. It is written for compliance managers, exporters, and supply chain leaders who need a reliable starting point before confirming their specific obligations with CONAI and the applicable authorities.

If you want to map your Italy packaging EPR exposure across products and entities, you can request a compliance review at any point.

Key Takeaways

📌 Italy's packaging EPR runs through CONAI under the Italian Environmental Code (D.Lgs. 152/2006); registration is required before packaging is placed on the Italian market.

📊 The Contributo Ambientale CONAI (CAC) is charged per tonne, by material, with plastic eco-modulated across recyclability tiers.

⏳ Reporting frequency (annual, quarterly, or monthly) is tied to the CAC amount owed in the prior year.

🔗 Foreign producers and e-commerce sellers placing packaged goods on the Italian market fall within scope; the obligation typically sits with the first party placing goods on the market.

📌 From 12 August 2026, PPWR (Regulation (EU) 2025/40) applies directly across the EU, adding design, recyclability, labelling, and PFAS obligations on top of national EPR.

⚠️ National CONAI registration and CAC payment continue to apply alongside PPWR; PPWR does not remove them.

What Italy Packaging EPR Requires

Italy operates a single national packaging EPR system. Companies that place packaging on the Italian market must register, declare the packaging they place on the market by material and weight, and pay an environmental contribution that finances separate collection, recycling, and recovery.

The legal foundation is the Italian Environmental Code, Legislative Decree 152/2006 (Testo Unico Ambientale), under which CONAI coordinates packaging waste management nationally. Later reforms, including Legislative Decree 116/2020, reinforced EPR, registration, and mandatory environmental labelling obligations.

For a broader view of how packaging EPR fits within EU rules, see Certivo's extended producer responsibility framework page and the PPWR framework overview.

You can verify the national basis directly through the European Commission's packaging waste resource page.

The CONAI System and the Six Material Consortia

CONAI (Consorzio Nazionale Imballaggi) is the coordinating body. Beneath it sit material-specific consortia that manage collection and recycling for each packaging stream. Understanding this structure matters because CAC rates and recyclability treatment differ by material.

Producers report all materials through CONAI rather than to each consortium separately. Plastic is the most complex stream because its contribution is eco-modulated: fees vary according to recyclability, material mix, and processing route.

For manufacturers managing packaging alongside product-level material obligations, this connects directly to BOM-level compliance tracking and materials and environmental compliance.

Who Must Register With CONAI

Registration is required before packaging is placed on the Italian market. The obligation generally falls on the first party placing packaged goods on Italian territory. This is significant for imports: for finished goods brought into Italy, the obligation usually sits with the first party placing them on the market, so importers and distributors should confirm in writing who carries it.

Parties typically in scope include:

• Italian producers and importers of packaging or packaged goods

• EU sellers placing packaged goods on the Italian market

• Non-EU companies selling directly to Italian customers, including through e-commerce

📌 Direct registration with CONAI generally requires an Italian tax identification number. Companies without one typically appoint an authorized representative or EPR service provider to handle registration, reporting, and payment.

Marketplaces reinforce this in practice. Amazon.it and other platforms verify CONAI membership during merchant onboarding, and the membership number is expected on commercial documents.

CONAI registration scope decision for Italy packaging EPR compliance

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Contributo Ambientale CONAI (CAC): How the Fee Works

The Contributo Ambientale CONAI is the core fee of the system. It is levied per tonne of packaging material placed on the market and differentiated by material type. The contribution is triggered at the "first transfer" of packaging within Italy, a defined moment in the supply chain that determines who pays.

Because rates are material-specific and, for plastic, eco-modulated by recyclability tier, accurate classification is essential. A key classification rule affects multi-material packaging:

• If a secondary material accounts for less than 5% of total weight, the package is treated as single-material (the primary material).

• If it accounts for more than 5%, it is treated as composite packaging and must be reported and labelled as such.

Based on currently available regulatory guidance, 2026 CAC rates span a wide range across materials, with certain plastic categories carrying substantially higher per-tonne contributions than materials such as wood. Because CONAI updates these figures periodically, current rates should always be confirmed on CONAI's official contribution page before filing.

Struggling to classify packaging accurately across a large product portfolio? You can speak with a compliance specialist about mapping materials to obligations.

CONAI Reporting Frequency and Thresholds

CONAI declaration and payment frequency is tied to how much CAC a company owed in the previous year. This tiering lets smaller obligated parties file less often while larger volumes report more frequently.

📊 The practical implication: as your Italian packaging volumes grow, your reporting cadence intensifies. A company that files annually one year may move to quarterly or monthly filing the next, which raises the operational burden of keeping packaging data accurate and current.

This is where continuous, audit-ready documentation matters. Monthly filing leaves little room for reconstructing packaging data from spreadsheets after the fact. Thresholds should be confirmed against current CONAI guidance, as consortium rules are periodically updated.

Environmental Labelling Obligations

Italy requires environmental labelling on packaging, an obligation reinforced under Legislative Decree 116/2020. Each packaging component must carry the material identification code from Decision 97/129/EC (for example, the alphanumeric codes identifying specific plastics, papers, or metals).

This requirement applies across almost all packaging in the supply chain, which means labelling decisions cascade from producers through to the parties placing goods on the market. Getting composition and coding right at the design stage avoids relabelling and rework later.

Certivo's materials and environmental compliance solution helps teams keep material composition data structured so labelling and reporting draw from the same verified source.

How PPWR Changes Italy Packaging Compliance

From 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, applies directly across all 27 member states, replacing the 1994 Packaging Directive (94/62/EC). Because it is a regulation rather than a directive, it applies uniformly without national transposition, and member states are barred from adding national packaging requirements unless PPWR explicitly permits them.

PPWR entered into force on 11 February 2025, with obligations phasing in from 12 August 2026 through to 2040. Several high-profile requirements, such as harmonized labelling pictograms, mandatory recycled content, and recyclability grading, arrive in later phases (2028, 2030, and beyond).

Critically, PPWR does not remove Italy's national EPR obligations. CONAI registration and CAC payment continue to apply. PPWR adds a harmonized EU layer on packaging design, recyclability, labelling, and restricted substances on top of the national system.

You can review the full legal text through EUR-Lex, Regulation (EU) 2025/40, and the Commission's implementation guidance via the European Commission packaging waste page.

PPWR compliance timeline for Italy packaging EPR obligations through 2040

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PFAS Restrictions in Food-Contact Packaging

One PPWR obligation that begins at the general application date affects food-contact packaging directly. From 12 August 2026, PPWR restricts placing food-contact packaging on the market where it contains per- and polyfluoroalkyl substances (PFAS) at or above specified concentration limits.

Based on currently available regulatory guidance and Commission materials, the restriction is framed around a limit for any single PFAS and a separate limit for the sum of targeted PFAS. Manufacturers should confirm the exact analytical thresholds and measurement methods against the Commission's PFAS implementation guidance before relying on them for product decisions.

For manufacturers already tracking PFAS across products, this connects to Certivo's broader PFAS compliance framework and guidance on tracking PFAS across the US and EU. The practical challenge is the same one that runs through all packaging compliance: knowing what substances are present, at what concentration, in which components.

Supply Chain and Documentation Impact

Italy packaging compliance is fundamentally a data problem. To register, classify, and report accurately, a company needs verified packaging composition data for every product it places on the Italian market, often sourced from suppliers who supply the packaging.

Common friction points include:

⚠️ Incomplete or inconsistent packaging weight and material data from suppliers

⚠️ Composite packaging misclassified as single-material (or the reverse)

📄 Environmental labelling codes missing from supplier documentation

🔗 Unclear ownership of the "first placer" obligation for imported goods

For exporters into Italy, PPWR also requires a Declaration of Conformity and supporting technical documentation for packaging placed on the market from 12 August 2026. That evidence has to be retrievable, not reconstructed under audit pressure.

This is where automated supplier data collection and multi-tier supplier engagement reduce risk. When packaging data is collected once, validated, and stored centrally, both CONAI reporting and PPWR documentation draw from the same verified backbone.

Compliance Preparation Checklist

Compliance and supply chain teams preparing for Italy packaging obligations should work through the following:

✅ Confirm scope. Determine whether your company is the first party placing packaged goods on the Italian market for each product line.

✅ Resolve import responsibility. For imported finished goods, agree in writing whether you or your distributor carries the CONAI obligation.

✅ Register with CONAI. Complete registration (directly with an Italian tax ID, or via an authorized representative) before placing packaging on the market.

✅ Classify every packaging component. Map each component to its material and, for plastic, to its recyclability tier. Apply the 5% composite rule correctly.

✅ Determine reporting cadence. Confirm whether you file annually, quarterly, or monthly based on prior-year CAC.

✅ Apply environmental labelling. Ensure each component carries the correct material identification code.

✅ Prepare PPWR documentation. Build Declarations of Conformity and technical files for packaging placed on the market from 12 August 2026.

✅ Screen food-contact packaging for PFAS. Confirm concentrations against PPWR limits before the application date.

✅ Verify current figures. Confirm CAC rates and thresholds against CONAI, and PPWR provisions against EUR-Lex and Commission guidance, before filing.

How Certivo Supports Italy Packaging Compliance

Italy's dual-layer system rewards companies that treat packaging compliance as continuous data management rather than periodic filing. As reporting cadence intensifies and PPWR phases in through 2040, the manual approach becomes progressively harder to sustain.

Certivo functions as a centralized system of record for compliance data. Packaging composition, supplier declarations, material classifications, and labelling codes are collected once and reused across obligations, so CONAI reporting and PPWR documentation draw from the same verified source rather than parallel spreadsheets.

CORA, Certivo's regulatory intelligence layer, supports horizon scanning across frameworks, so changes to PPWR delegated acts or national rules surface earlier. The objective is not to eliminate compliance risk, which no software can do, but to reduce surprises, improve evidence retrieval, and shorten response time when a customer audit or regulatory query arrives.

To see how this maps to your specific Italian and EU packaging obligations, book a compliance risk assessment.