EPR Obligations in Italy

Key legislation & authorities

Italy's EPR framework is governed by the Testo Unico Ambientale (D.Lgs. 152/2006) and subsequent implementing decrees:

• CONAI (Consorzio Nazionale Imballaggi) — national packaging consortium, mandatory membership for all producers
• Centro di Coordinamento RAEE — coordinates WEEE collection and treatment
• CDCNPA (Centro di Coordinamento Nazionale Pile e Accumulatori) — battery coordination center
• ISPRA (Istituto Superiore per la Protezione e la Ricerca Ambientale) — environmental monitoring
• Registro AEE — national register for WEEE producers

Non-compliance penalties include fines up to €100,000, product import bans, and mandatory registration before customs clearance for certain product categories.

Packaging obligations (CONAI)

Italy's CONAI system is mandatory for all producers placing packaged goods on the Italian market:

• Membership in CONAI is compulsory — there is no opt-out
• The Contributo Ambientale CONAI (CAC) is an environmental contribution levied per kilogram of packaging material, differentiated by material type
• Producers must submit quarterly or annual declarations depending on volume
• Material categories: steel, aluminium, paper/cardboard, wood, plastic, glass, bioplastics

Foreign producers selling into Italy (including e-commerce) are subject to CONAI obligations. Italy is one of the few EU countries where the packaging EPR contribution applies at the point of first sale on Italian territory, making customs declarations relevant for EPR compliance.

WEEE obligations (RAEE)

Producers of electrical and electronic equipment must:

• Register in the Registro AEE (national WEEE producer register)
• Join an approved collective scheme (e.g., Ecodom, Erion, Remedia)
• Report quantities placed on market annually
• Finance collection and treatment through the scheme
• Apply the crossed-out wheelie bin symbol

Registration in the Registro AEE must be completed before the first product is placed on the Italian market. Amazon.it verifies registration numbers and delists non-compliant sellers.

Battery obligations

Italy's battery EPR framework requires producers to:

• Register with the national battery register
• Join the CDCNPA coordination system
• Report battery types and quantities annually
• Finance collection and recycling through authorized schemes

With the EU Battery Regulation (2023/1542) now in force, Italy is updating its national implementation to include digital battery passports, minimum recycled content requirements, and carbon footprint declarations for certain battery types.

Environmental labeling requirements

Since January 2023, Italy requires environmental labeling on all packaging placed on the Italian market. This includes:

• Material identification codes (alphanumeric codes per Decision 129/97/CE)
• Consumer-facing disposal instructions in Italian
• The labeling must appear on the packaging itself or, for small packaging, on accompanying documentation

These requirements apply to both household and commercial/industrial packaging and are enforced alongside the CONAI contribution obligations.

Authorized representative

Non-Italian producers must appoint an authorized representative established in Italy to fulfil their EPR obligations. The representative is legally responsible for registration, reporting, and communication with Italian authorities and compliance schemes.

Certify acts as authorized representative in Italy for packaging (CONAI), WEEE (RAEE), and batteries — providing integrated multi-category compliance from a single contract.