EPR Obligations EU → Authorized representative → 🇮🇹 Italy
Authorized Representative in Italy 2026:
Who Needs One and Why
You do not need an Italian company to sell into Italy — but you do need someone in Italy. Which kind of representative depends on what you sell and whether you sell directly to end users.
Last reviewed: · Sources linked below
Short answer: foreign sellers without an Italian establishment handle packaging (CONAI) through an Italy-based representative with an Italian VAT number and a PEC address. Since 12 August 2026 the EU Packaging Regulation adds an authorized representative for every producer — EU or non-EU — that sells packaged products directly to end users in Italy. Electrical equipment must be in the Registro AEE before the first sale, and batteries in the Registro Pile.
Authorized representative in Italy at a glance
- Packaging (CONAI)
- Sellers without an Italian establishment work through an Italy-based representative with an Italian VAT number and a PEC (certified e-mail) address, according to specialist compliance sources.
- Packaging (PPWR)
- Art. 45 PPWR, since 12 August 2026: authorized representative for producers, EU or non-EU, that sell packaged products directly to end users in Italy from another country.
- Electrical equipment
- Foreign distance sellers count as producers and must be in the Registro AEE before the first sale. According to ERP Italia, they can register themselves or through a representative appointed by written mandate (Art. 30 D.Lgs. 49/2014).
- Batteries
- Registro Pile. EU Battery Regulation, Art. 56(3): representative for distance sellers, according to law-firm analysis.
- Own Italian company?
- Not required.
- Minimum quantity
- According to specialist sources, none for the PPWR duty of distance sellers to consumers.
- National PPWR rules
- In our review, no Italian implementing act had been published as of October 2026. The EU duty applies directly.
- Exemption?
- Proposal – not yet law For small EU-established packaging producers only.
Do I need an authorized representative in Italy?
If your company is not established in Italy and you place packaged goods on the Italian market, you need a partner established in Italy. The table shows which rule applies to which seller.
| Your situation | What Italy requires |
|---|---|
| Company established in Italy | No representative. You join CONAI and register yourself. |
| Online shop in another EU country shipping packaged goods to Italian consumers | Italy-based representative (Italian VAT number and PEC) for CONAI, and an authorized representative under Art. 45 PPWR for the direct sales to end users. |
| Seller outside the EU (for example US, UK, China) shipping directly to Italian end users | The same. The proposed EU exemption would not cover you. |
| You sell electrical or electronic equipment directly to Italian customers | You count as the producer in Italy: Registro AEE before the first sale, directly or through an authorized representative. |
| Your products contain or are batteries | Registro Pile. Under the EU Battery Regulation, distance sellers appoint a representative in each member state where they sell. |
| Non-EU manufacturer supplying an Italian importer, no sales to end users | The PPWR duty for distance sellers does not apply. Whether Italy requires a representative from other non-EU producers is not settled in the sources we reviewed — ask us for a case-specific check. |
Not sure which row is yours? Ask for a free check.
Why Italy asks for a representative
Italian EPR runs through Italian bodies: CONAI for packaging, the Registro AEE at the Chambers of Commerce for electrical equipment, the Registro Pile for batteries. The system works with an Italian VAT number and with PEC, the certified e-mail system used for official correspondence in Italy. A company abroad usually has neither. The representative supplies both and is the party in Italy that the system can address.
A common misunderstanding: Italy does not require foreign sellers to set up their own Italian company. What is needed is an Italy-based representative with an Italian VAT number and a PEC address.
The PPWR duty has a second reason: since 12 August 2026 the EU wants every distance seller to have a responsible party in each country it ships to. It applies directly in Italy, even though — in our review — Italy had not published a national implementing act as of October 2026.
Packaging, electrical equipment, batteries: three different answers
Italy runs separate systems for the three product groups, and the representative question has a different answer in each.
| Product | Where | Representative |
|---|---|---|
| Packaging | CONAI; environmental contribution (CAC) by weight and material, on packaging placed on the Italian market | Italy-based representative (VAT number and PEC) for sellers without an Italian establishment; PPWR authorized representative for direct sales to end users |
| Electrical and electronic equipment | Registro AEE (registroaee.it), run through the Chambers of Commerce | According to ERP Italia, distance sellers — also from outside the EU — register themselves or through a rappresentante autorizzato appointed by written mandate |
| Batteries | Registro Pile; registration number on invoices and transport documents | EU Battery Regulation, Art. 56(3): representative for distance sellers, by written mandate |
Electrical equipment: register before the first sale
Foreign distance sellers who sell electrical or electronic equipment directly to Italian customers are producers in Italy and must be registered in the Registro AEE before the equipment is placed on the market. The WEEE Directive (Art. 17) expects a distance seller established in one member state to appoint a representative in the member state it sells into; Italy provides for the rappresentante autorizzato in Art. 30 of D.Lgs. 49/2014. Which route fits your company is part of the free check.
Batteries
Battery producers register in the Registro Pile, and the registration number has to appear on invoices and transport documents. On top of that, the EU Battery Regulation has applied its EPR regime since 18 August 2025, including the representative rule for distance sellers.
Registers, contributions and fines in full: EPR in Italy.
What happens without a representative
The representative is a means to an end: the registrations. Selling unregistered is what Italian law penalises.
| Breach | Fine |
|---|---|
| Placing electrical equipment on the market without Registro AEE registration | €30,000–100,000 |
| Late or incorrect Registro AEE data | €2,000–20,000 |
| Breaches of battery obligations (Registro Pile) | €30,000–100,000 |
For packaging we do not quote a figure: the legal basis is not clearly documented in the sources we reviewed. Member states must have PPWR penalty rules in place by 12 February 2027.
Marketplaces check as well. In its notice of 25 March 2026, Amazon named Italy among the countries where it checks packaging EPR compliance from 12 August 2026 and said it "may need to stop selling your non-compliant products". eBay may hide listings from buyers in a country for which the seller has no packaging EPR number.
Would the proposed EU exemption help?
Only small producers established in the EU, only for packaging — and only once it is law.
Proposal – not yet law EU exemption for small EU-established producers. The European Commission's Environmental Omnibus of 10 December 2025 proposes suspending the authorized-representative duty for producers established in the EU. The European Parliament adopted its position on 20 October 2026 (as reported: an exemption for EU micro and small enterprises until 2035). The Council's negotiating mandate of 21 October 2026 covers packaging only: EU-established producers placing less than 1 tonne of packaging per year in another member state would not need a representative there until 1 January 2032. It does not cover batteries. Trilogue negotiations follow. None of this is law yet, and none of it helps sellers established outside the EU — until a final text is adopted, the current duty applies.
Dates that matter for Italy
| Date | What applies |
|---|---|
| Before the first sale | Registro AEE registration for electrical and electronic equipment |
| First placing on the market | CONAI membership and CAC for packaging placed on the Italian market |
| 18 Aug 2025 | EU Battery Regulation: EPR regime applies |
| 12 Aug 2026 | PPWR applies: authorized representative for distance sellers (Art. 45) |
| 20–21 Oct 2026 | Parliament and Council positions on the exemption; trilogue next Proposal – not yet law |
| 12 Feb 2027 | Member states must have PPWR penalty rules in place |
Full calendar: EPR deadlines 2026–2027.
How Certify helps
- Free obligation check. Tell us what you sell into Italy, through which channels (Amazon, eBay, your own shop) and where your company is established. We tell you which representative duties apply to you — and which do not.
- Registration and representation. Certify prepares the registrations and, where the law requires it, acts as your authorized representative. Certify offers an authorized representative in all EU member states.
- Ongoing compliance. Certify supports the recurring declarations and reports, so your registration numbers stay valid for marketplaces and authorities.
This page explains the obligation. If you already know that you need a representative, the practical steps are on our sister site: appointing an EPR authorized representative (register-epr.com).
FAQ: authorized representative in Italy
Do I need an authorized representative in Italy?
If your company is not established in Italy and you sell packaged products directly to Italian end users, yes: Art. 45 of the EU Packaging Regulation has required an authorized representative since 12 August 2026, for EU and non-EU sellers alike. For the Italian packaging system CONAI, sellers without an Italian establishment work through an Italy-based representative with an Italian VAT number and a PEC address.
Do I have to set up an Italian company?
No. An own Italian establishment is not required. What is needed is an Italy-based representative that has an Italian VAT number and a PEC address.
What is a PEC address?
PEC stands for posta elettronica certificata, the certified e-mail system used for official correspondence in Italy. The Italy-based representative needs a PEC address and an Italian VAT number.
Is there a minimum quantity below which no representative is needed?
According to specialist compliance sources, there is no minimum quantity for the PPWR duty of distance sellers who sell to consumers in Italy. An EU exemption for producers established in the EU that place less than 1 tonne of packaging per year in another member state is being negotiated, but it is a proposal and not law.
Do I need a representative for electrical equipment in Italy?
Foreign distance sellers of electrical and electronic equipment count as producers in Italy and must be registered in the Registro AEE before the first sale. According to ERP Italia, distance sellers can register themselves or through an authorized representative appointed by written mandate under Art. 30 of D.Lgs. 49/2014.
I am established outside the EU. Does the proposed exemption help me?
No. The exemption under negotiation concerns producers established in the EU. Sellers established outside the EU would still need an authorized representative for packaging sold directly to end users in Italy.
- Registro AEE (official register portal)
- Camera di Commercio di Napoli: Registro AEE information
- Camera di Commercio Pistoia-Prato: RAEE webinar (2022)
- ERP Italia: Rappresentante autorizzato (Art. 30 D.Lgs. 49/2014)
- Landmark Global: Italian packaging EPR – CONAI registration and fees
- EUR-Lex: Regulation (EU) 2025/40 (PPWR), Art. 45
- EUR-Lex: Directive 2012/19/EU (WEEE), Art. 17
- EUR-Lex: Regulation (EU) 2023/1542 (batteries), Art. 56
- Herbert Smith Freehills Kramer: EU Battery Regulation – EPR provisions since 18 August 2025
- Council of the EU: negotiating mandate of 21 October 2026 (document 14765/26)
- Amazon Global Selling: EU packaging EPR notice (25 March 2026)
This page is general information, not legal advice. Last reviewed 5 November 2026.
Related guides
Representative rules differ from country to country and from product to product:
Check whether you need a representative in Italy
Tell us what you sell to Italian customers and where your company is established. You receive a structured answer on which representative and which registrations you need in Italy. Your message is delivered directly to Certify — specialists in EU-wide producer responsibility compliance. Free first consultation, no obligation.