EPR Obligations EU → 🇮🇹 Italy
EPR in Italy 2026: Packaging, WEEE & Batteries
CONAI and the CAC, Registro AEE and Registro Pile, and why foreign sellers need an Italy-based representative — not an Italian company.
Last reviewed: · Sources linked below
Short answer: if you place packaged goods on the Italian market, you join CONAI and pay the environmental contribution CAC on that packaging. Electrical and electronic equipment must be registered in the Registro AEE before it is placed on the market, and batteries in the Registro Pile. Foreign sellers do not need an Italian company: they work through an Italy-based representative with an Italian VAT number and a PEC address.
At a glance
- Packaging register / scheme
- CONAI (Consorzio Nazionale Imballaggi); environmental contribution CAC by weight and material, on packaging placed on the Italian market.
- Authorised representative
- Italy-based representative with Italian VAT number and PEC — no own establishment needed. PPWR: B2C distance sellers need an AR in Italy.
- WEEE
- Registro AEE (registroaee.it) via the Chambers of Commerce; register before placing on the market.
- Batteries
- Registro Pile; registration number on invoices and transport documents.
- Thresholds
- No de-minimis for the PPWR authorised-representative duty for B2C distance sellers.
- Penalties
- WEEE: €30,000–100,000 (unregistered), €2,000–20,000 (late/incorrect data). Batteries: €30,000–100,000.
- Marketplace checks
- Amazon names Italy in its EU packaging EPR notice (from 12 Aug 2026); eBay may hide listings without a valid number.
- What changed in 2026
- PPWR applies since 12 Aug 2026. In our review, no Italian implementing act had been published as of October 2026.
- What changed in 2026
- Packaging (CONAI)
- WEEE (Registro AEE)
- Batteries (Registro Pile)
- Representative
- Deadlines
- Penalties
- FAQ
Italy's three EPR registrations in one table
Italy runs separate systems for packaging, electrical equipment and batteries. A seller of packaged electronics with batteries typically deals with all three.
| Stream | Where | Key point for foreign sellers |
|---|---|---|
| Packaging | CONAI | Membership triggered by first placing packaging on the Italian market; CAC by weight and material |
| Electrical and electronic equipment | Registro AEE (Chambers of Commerce) | Register before placing on the market; foreign distance sellers are producers |
| Batteries | Registro Pile | Registration number on invoices and transport documents |
What changed in 2026
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied directly in Italy and every other member state since 12 August 2026. It entered into force on 11 February 2025 and replaced most of the old Packaging Directive 94/62/EC, which was generally repealed on 12 August 2026 (some provisions continue). National registers and schemes still exist — the PPWR sits on top of them. Read the full overview on our PPWR 2026 page.
- Authorised representative (Art. 45): producers that sell packaged products directly to end users in another member state — whether established in the EU or outside it — must appoint an authorised representative in each member state where they first make packaging available, other than their own. For other non-EU producers, member states may require one.
- Pragmatic enforcement: the European Commission has asked member states to enforce the authorised-representative duty in a "constructive and pragmatic" way while an exemption is being negotiated.
- Penalties: member states must lay down their PPWR penalty rules by 12 February 2027 (Art. 68).
- Fees and labels: EU-harmonised fee modulation by recyclability grade is expected from around 2028–2030; harmonised packaging labelling applies from 12 August 2028 or 24 months after the implementing acts, which had not been adopted as of September 2026.
Proposal – not yet law EU omnibus and the AR exemption. The Environmental Omnibus (COM(2025) 982, 10 December 2025) proposes suspending the authorised-representative duty for EU-established producers. The European Parliament adopted its position on 20 October 2026 (exemption for EU micro and small enterprises until 2035, as reported). The Council agreed its negotiating position on 21 October 2026: EU-established producers placing less than 1 tonne of packaging per year in another member state would not need an authorised representative there, until 2032. Trilogue negotiations follow. This is not law yet, and it does not cover sellers established outside the EU.
Italy: no national implementing act found yet
In our review of official sources, we did not find a national Italian implementing act for the PPWR published as of October 2026. The existing CONAI system continues. Because the PPWR applies directly, the EU authorised-representative duty for B2C distance sellers applies in Italy regardless — according to specialist logistics and compliance sources, without a de-minimis threshold. We will update this page when Italy publishes implementing rules.
Packaging obligations in Italy (CONAI)
CONAI membership is triggered when a business first places packaging on the Italian market — for example by importing packaged goods or by shipping them to Italian customers. Members pay the Contributo Ambientale CONAI (CAC), an environmental contribution calculated by weight and packaging material, on packaging placed on the Italian market (not on packaging sold elsewhere).
- Map your packaging flows into Italy: which products, which materials (paper/board, plastic, glass, metal, wood) and roughly what weight per year.
- Set up your Italian representative if you have no Italian establishment: the representative needs an Italian VAT number and a PEC (posta elettronica certificata) address.
- Join CONAI and declare your packaging so that the CAC can be calculated by weight and material.
- Appoint a PPWR authorised representative if you sell packaged products directly to end users in Italy from another member state or from outside the EU.
- Keep your declarations current and keep your registration details ready for marketplaces.
Correction to common claims: Italy does not require foreign sellers to set up their own Italian company. What is needed is an Italy-based representative (Italian VAT number and PEC). The CAC applies to packaging placed on the Italian market, not to all packaging a company uses.
WEEE obligations in Italy (Registro AEE)
The Registro AEE is Italy's national register of producers of electrical and electronic equipment (EEE), run through the Chambers of Commerce at registroaee.it. Registration must be completed before equipment is placed on the Italian market. Foreign distance sellers who sell EEE directly to Italian customers count as producers in Italy.
- Register before the first sale of EEE in Italy.
- Report the quantities placed on the market and keep the data correct and on time.
- Finance collection and treatment of waste equipment.
Fines are substantial: €30,000 to €100,000 for placing EEE on the market without registration, and €2,000 to €20,000 for late or incorrect data. We check whether you register through an Italian representative in the free obligation check.
Battery obligations in Italy (Registro Pile)
Battery producers in Italy register in the Registro Pile, and the registration number must appear on invoices and transport documents. Fines in this area range from €30,000 to €100,000. If you sell devices with built-in batteries, we check in the free obligation check how they are covered.
On top of national rules, the EU Battery Regulation (EU) 2023/1542 has applied its extended producer responsibility regime since 18 August 2025. Further steps are scheduled from 18 February 2027: a QR code on all batteries, removability and replaceability rules, and a battery passport for EV, LMT and industrial batteries above 2 kWh. Battery due-diligence obligations have been postponed to 18 August 2027 (Regulation (EU) 2025/1561).
Proposal – not yet law The EU omnibus would also suspend the authorised-representative duty for batteries (European Parliament vote on 20 October 2026; Council position pending).
Italian representative and PPWR authorised representative
Foreign sellers without an Italian establishment fulfil their Italian EPR obligations through an Italy-based representative with an Italian VAT number and a PEC address. In addition, the PPWR requires producers that sell packaged products directly to end users in Italy from another member state or from outside the EU to appoint an authorised representative in Italy.
The proposed EU exemption for small EU-established producers (Council position of 21 October 2026: below 1 tonne per year, until 2032) is not law yet and would not cover sellers established outside the EU. Background: authorised representative explained on register-epr.com. Who needs one, by seller type: authorized representative in Italy.
How Certify helps
- Free obligation check. Tell us what you sell into Italy, through which channels (Amazon, eBay, your own shop) and roughly in what volumes. We map which registers, schemes and representative duties apply to you.
- Registration and representation. Certify prepares the registrations and, where the law requires it, acts as your authorised 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.
Deadlines for Italy and the EU
For Italy, the decisive point in time is your first sale: Registro AEE registration must exist before EEE is placed on the market, and CONAI membership is triggered by first placing packaging on the Italian market. Full calendar: EPR deadlines.
| Date | Scope | What happens |
|---|---|---|
| Before first sale | Italy – WEEE | Registration in the Registro AEE |
| First placing on the market | Italy – packaging | CONAI membership and CAC on packaging placed on the Italian market |
| Ongoing | Italy – batteries | Registro Pile number on invoices and transport documents |
| 12 Aug 2026 | EU | PPWR applies; authorised-representative duty for distance sellers (Art. 45) |
| 20–21 Oct 2026 | EU | Parliament (20 Oct) and Council (21 Oct) positions on the AR exemption; trilogue next Proposal – not yet law |
| 12 Feb 2027 | EU | Member states must have PPWR penalty rules in place |
| 18 Feb 2027 | EU batteries | QR code on all batteries, removability rules, battery passport (EV, LMT, industrial >2 kWh) |
| 18 Aug 2027 | EU batteries | Battery due-diligence obligations start (postponed) |
| 12 Aug 2028 | EU | Harmonised packaging labelling (or 24 months after implementing acts) |
Penalties in Italy
The Italian EPR fine ranges documented in official sources concern electrical equipment and batteries.
| Breach | Fine |
|---|---|
| Placing EEE 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 fine figure here because the legal basis is not clearly documented in the sources we reviewed — ask us for a case-specific assessment. At EU level, member states must have PPWR penalty rules in place by 12 February 2027.
Marketplaces check EPR numbers. In its notice of 25 March 2026, Amazon announced packaging EPR compliance checks across the EU from 12 August 2026 and named Italy among the countries concerned; Amazon "may need to stop selling your non-compliant products". eBay requires packaging EPR numbers from 12 August 2026 for each country in which the seller is a producer, and listings may be hidden from buyers in that country. See also our sister site's guide to the Amazon EPR number.
FAQ: EPR in Italy
Do I need an Italian company to meet EPR obligations in Italy?
No. Foreign sellers without an Italian establishment work through an Italy-based representative that has an Italian VAT number and a PEC (certified e-mail) address. An own Italian establishment is not required.
What are CONAI and the CAC?
CONAI is Italy's national packaging consortium. Membership is triggered when a business first places packaging on the Italian market. Members pay the environmental contribution CAC (Contributo Ambientale CONAI), calculated by weight and material, on packaging placed on the Italian market.
What is the Registro AEE?
The Registro AEE is Italy's national register of producers of electrical and electronic equipment, run through the Chambers of Commerce (registroaee.it). Producers must register before placing equipment on the Italian market, and foreign distance sellers count as producers. Placing equipment on the market without registration can be fined 30,000 to 100,000 euros; late or incorrect data 2,000 to 20,000 euros.
How do batteries work in Italy?
Battery producers register in the Registro Pile. The registration number must appear on invoices and transport documents. Fines in this area range from 30,000 to 100,000 euros.
Has Italy adopted national rules for the PPWR?
The PPWR has applied directly in Italy since 12 August 2026. In our review we did not find a national Italian implementing act published as of October 2026. Under the PPWR, distance sellers who sell packaged products directly to Italian end users need an authorised representative in Italy.
Does Amazon check EPR compliance for Italy?
Yes. In its notice of 25 March 2026, Amazon announced packaging EPR compliance checks across the EU from 12 August 2026 and named Italy among the countries concerned. Amazon may need to stop selling non-compliant products, and eBay may hide listings in countries where the seller lacks the required EPR number.
- Registro AEE (official register portal)
- Camera di Commercio di Napoli: Registro AEE information
- Camera di Commercio Pistoia-Prato: RAEE webinar (2022)
- Landmark Global: Italian packaging EPR – CONAI registration and fees
- Regulation (EU) 2025/40 (PPWR) on EUR-Lex
- Amazon Global Selling notice, 25 March 2026
This page is general information, not legal advice. Last reviewed 27 October 2026.
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