Registering for packaging EPR in Italy yourself — CONAI, the seven material consortia and the word that decides your liability

Does this apply to you

Article 221(1) of legislative decree 152/2006 puts the obligation on two groups at once: i produttori e gli utilizzatori sono responsabili della corretta ed efficace gestione ambientale degli imballaggi e dei rifiuti di imballaggio riferibili ai propri prodotti — responsible for the sound environmental management of the packaging attributable to their own products, in proportion to the quantity placed on the national market.

Article 218(1) then defines the two groups, and this is the part to read twice:

• produttori — i fornitori di materiali di imballaggio, i fabbricanti, i trasformatori e gli importatori di imballaggi vuoti e di materiali di imballaggio: suppliers of packaging materials, manufacturers, converters and importers of empty packaging and packaging material.
• utilizzatori — i commercianti, i distributori, gli addetti al riempimento, gli utenti di imballaggi e gli importatori di imballaggi pieni: traders, distributors, fillers, users of packaging and importers of filled packaging.

If you sell packaged goods into Italy from abroad, you are importing imballaggi pieni. You are an utilizzatore, and Article 221(1) names you. The EU Packaging Regulation reaches the same result from the other direction: under Article 3(1)(15)(d) a seller established outside the European Union that supplies packaged goods to end users in a Member State under a distance contract is the producer in that Member State. Two routes, one answer.

There is no volume threshold in the statute. Article 221(2) requires producers and users to join the national packaging consortium, salvo il caso in cui venga adottato uno dei sistemi di cui al comma 3, lettere a) e c) — except where one of two alternative systems is adopted: organising your own nationwide collection scheme, or certifying an audited own-return system. That is a closed list of two exits, and neither of them is "you are small". We say this from the closed list, not from a sentence in the law that says "no minimum", because there is no such sentence. One caveat we will not hide: CONAI's own Guida all'adesione e all'applicazione del Contributo Ambientale, whose chapter 8 covers the special cases of application, exemption and declaration, is published on conai.org — a host that refuses every request we make, browser included. If CONAI operates a small-volume simplification at the procedural level, we have not been able to read it. See Sources.

The steps

Take them in this order. Step 1 is not paperwork — it is the classification that decides everything after it.

1 · Classify yourself, then join CONAI

CONAI — the Consorzio Nazionale Imballaggi — is constituted by Article 224 of legislative decree 152/2006 as a private not-for-profit body whose statute is approved by ministerial decree. It is the single body you join. Ricrea, the steel consortium, states the structure in one line on its own Sistema CONAI page: Tutti i soggetti sopra definiti aderiscono a CONAI — every one of the parties defined above joins CONAI. The material consortia are a second, narrower membership, and they are covered in the section below.

You join in one of two membership categories, and it is the classification from the section above that decides which: produttore if you place empty packaging or packaging material on the Italian market, utilizzatore if you import or trade filled packaging. Get this wrong and both the consortium you belong to and the point at which you owe the contribution come out wrong.

We are not going to walk you through the CONAI membership form screen by screen, because we cannot open it. conai.org — the site that carries the membership route, the Guida and the annual contribution tables — returns an Akamai Access Denied to us on every request, including from a real browser with a real browser's user agent. That is a fact about the host and our access to it, not about you: from an ordinary Italian connection the site works. We do not link a page we could not open, and we do not describe its screens from a service provider's blog. What we can tell you is verified from CONAI's own second site and from the consortia: membership is with CONAI, the operating manual is the annual Guida all'adesione e all'applicazione del Contributo Ambientale, and Comieco publishes CONAI's freephone information line for membership and contribution questions, 800.33.77.99.

2 · If you are established outside Italy: the representative question, open

Under Article 45(3) of the EU Packaging Regulation, a producer established in one Member State that sells into another must appoint an authorised representative in that other Member State. That first sentence is an EU-wide duty and it binds in Italy like everywhere else. The second sentence of the same article is different: for producers established outside the European Union it says Member States may provide for an authorised-representative requirement. It is a national option, and each Member State decides.

Whether Italy has taken up that option, we could not establish. We read the packaging title of legislative decree 152/2006 — articles 218, 221, 223, 224 and 226, in the consolidated text Normattiva records as last updated on 7 August 2026 — and the phrase rappresentante autorizzato does not appear in any of them. The environment ministry's own site, mase.gov.it, returns HTTP 403 to us on every path including robots.txt, and we do not work around hosts that refuse us. So the honest position is: no Italian provision requiring a third-country producer to appoint a representative was found, and the absence of a finding is not a finding of absence.

What that means for you in practice: do not buy an "Italian authorised representative" package on the strength of someone telling you it is mandatory, and do not assume you are free of one either. Put the question in writing to CONAI before you sign anything, and keep the answer. If you are established in another EU Member State rather than outside the EU, the first sentence settles it and you do need one.

3 · Join the material consortium only if you are a produttore

This is the step most guides get backwards. Ricrea's Sistema CONAI page sets out the split: I Produttori, oltre a iscriversi a CONAI nella categoria Produttori, si iscrivono a uno o più consorzi di filiera in rapporto ai materiali prodotti — producers, in addition to joining CONAI in the producers category, also join one or more material consortia according to the materials they produce. Users do not. Ricrea's own membership page confirms it from the other side: the categories that participate in Ricrea are suppliers of steel packaging material and manufacturers/converters of steel packaging, including importers of empty packaging — importers of filled packaging are not on the list.

So a seller shipping packaged goods into Italy normally joins CONAI and stops there. The seven consortia are set out in the next section because you will meet their names on invoices and in contracts, and because the contribution you pay is what funds them.

4 · Declare and pay at the prima cessione

The contribution is not charged at every step of the chain. It is charged once, at the prima cessione — the first transfer. Ricrea defines it: the moment the finished packaging passes from the last producer to the first user, or the moment packaging material passes from a raw-material producer to a self-producer who will give it its final form and fill it. Nel ciclo di vita di ogni imballaggio esiste una sola prima cessione — in the life of each packaging item there is exactly one first transfer, and identifying it clearly is what stops the cost being apportioned to the wrong party. For imported filled packaging, that moment is the import.

The declaration itself is form 6.1, one per material — steel, aluminium, paper, wood, plastic, bioplastic and glass — and since the 2014 declarations it must be filed through CONAI's online declaration service. Its frequency is not fixed for everyone: Ricrea says the declaration può essere inoltrata a CONAI con periodicità diverse in funzione dell'entità del Contributo — it may be filed at different intervals depending on how much contribution is due, and refers you to the Guida for the bands.

We are not going to quote those bands or a filing deadline here. They live in the Guida, on conai.org, and we could not open it. A date invented from a secondary source is worse than no date: confirm the interval that applies to your volume with CONAI directly, in writing, when you join.

The seven material consortia

Article 223 of legislative decree 152/2006 requires one consortium per packaging material listed in Annex E, operating nationwide, each a private not-for-profit body with a statute approved by ministerial decree. Article 224(3)(h) makes CONAI the body that sets the Contributo Ambientale and apportions it, and Article 224(3)(e) lets CONAI direct a share of it to the consortia that beat the minimum recovery and recycling rates — and cut the share of those that miss theirs.

Comieco's Sistema CONAI page names the seven materials CONAI manages: acciaio, alluminio, carta, legno, plastica, bioplastica e vetro. Six of the seven consortia are listed here with the name and site we opened ourselves on the date at the top of this page:

• Steel — Consorzio Ricrea (Raccolta e Riciclo Imballaggi Acciaio), consorzioricrea.org
• Aluminium — CiAl, Consorzio Nazionale Imballaggi Alluminio, cial.it
• Paper and board — Comieco, Consorzio Nazionale per il Recupero ed il Riciclo degli Imballaggi a base Cellulosica, comieco.org
• Wood — Rilegno, Consorzio Nazionale per la raccolta, il recupero e il riciclaggio degli imballaggi di legno, rilegno.org
• Plastic — Corepla, corepla.it
• Glass — Coreve, Consorzio Recupero Vetro, coreve.it

The seventh material is compostable bioplastic, and its consortium is Biorepack. We are not linking it and we are not quoting its statutory name, because biorepack.org answers us with a Cloudflare block page and we could not open it — the same rule we apply to conai.org. That the material exists as its own CONAI stream with its own contribution bands is not in doubt: CONAI's own Codice Imballaggio tool lists Plastica biodegradabile e compostabile among the seven materials and publishes its two bands, and both appear in our Italy rate table.

What this structure means when you are shopping for help: in Italy there is nothing to choose. Germany and Austria have competing licensed systems; Italy has one consortium, set up by statute, with a contribution the CONAI board sets by resolution. Nobody can offer you a better rate, because there is only one rate.

Reporting: what you file and when

• To CONAI, at membership: your classification — produttore or utilizzatore — and the materials you place on the Italian market.
• To CONAI, periodically: form 6.1 per material, through the online declaration service, covering the packaging subject to the contribution and the amount due. The interval depends on how much you owe; see step 4 for why we leave the bands blank.
• To your material consortium, if you joined one: the data and information its board requires, plus submission to its compliance checks. Ricrea's membership page lists both among the obligations of a consorziato.

The number that decides your bill is weight by material and by band, not units. Italy prices in euro per tonne, and for paper, plastic, aluminium and bioplastic the band matters as much as the weight: the plastic ladder runs from 40 euro per tonne to 790, a factor of nearly twenty. Keeping your packaging specifications — polymer, colour, label material, whether it is mono-material — is what lets you claim the band you actually qualify for.

When you actually need a provider

Italy has fewer places where money genuinely has to change hands than most of its neighbours, and it is worth being precise about which they are.

• You do not need anyone to choose a scheme. There is one national consortium and one contribution schedule set by its board. Any pitch built on finding you a cheaper Italian scheme is describing a market that does not exist.
• You may need an authorised representative — and this is the one open question on the page. If you are established in another EU Member State, Article 45(3) first sentence requires one. If you are established outside the EU, whether Italy has taken up the Member State option is the item we could not close in step 2. Ask CONAI in writing first; do not buy on a vendor's assertion.
• Classification is worth paying for, band assignment even more so. Whether a given item falls in Fascia B1.2 or Fascia C is a three-fold difference in what you pay per tonne, and it turns on details like whether a PET bottle's label is PVC or denser than 1 g/cm³. CONAI publishes a free questionnaire and a searchable archive of declaration codes for exactly this — we link the archive under Sources — so get a quote for judgement, not for lookups you can do yourself.
• Somebody who can read Italian correspondence is the practical need. The consortium membership route runs on certified email (PEC) and Italian-language forms.

We have no commercial relationship with CONAI, with any material consortium or with any compliance provider, and we take no referral fees.

What it costs

The contribution is published in euro per tonne, by material and by band. Every row on this site carries the source document and the date we verified it:

• The three single-rate materials — steel, wood and glass — one rate each, and the cheapest lines in the schedule.
• Paper — the single-material band is Fascia 1; paper-based composites climb through five more bands to Fascia 6, and beverage cartons have their own line at Fascia 4 (CPL).
• Plastic — nine bands. The industrial and C&I circuit sits at Fascia A1.1, well-designed PET bottles at Fascia B1.2, and anything that qualifies for nothing better lands in the residual Fascia C. That spread is the eco-modulation: it is where packaging design turns into money.
• Aluminium and compostable bioplastic — banded since 12 August 2026, the date the EU Packaging Regulation began to apply: aluminium Fascia 1, bioplastic Fascia 1 and Fascia 2. The single rates that applied before that date are kept on the page as their own rows.
• Consortium membership fees — the material consortia charge a joining fee and may levy an annual contribution decided by their assembly; Ricrea lists both in its members' obligations. Those are separate from the CAC and we do not publish them: they are not a national tariff.

The full table has every band with its effective dates — including the changes CONAI has already announced for 1 October 2026 and 1 January 2027. Italy changes its rates by board resolution rather than on an annual calendar: 2026 alone carries four effective dates. If you want to see what the same obligation looks like where the scheme competes on price, our German guide is the opposite case.