CONAI and Italian EPR: What E-commerce Sellers Must Declare

Italy is one of the most complex EPR markets in the EU. It is also one of the most strictly enforced. If you sell physical products to Italian consumers — whether through your own website, Amazon.it, or a distributor — you have packaging compliance obligations under Italian law, and those obligations run through CONAI, the Consorzio Nazionale Imballaggi.

CONAI is not a single organization that collects a single fee. It is an umbrella consortium that coordinates seven material-specific consortia, each managing a different packaging material. Understanding how this structure works is the first step toward knowing what you actually owe and where to pay it.

What Is CONAI?

CONAI was established in 1997 under Italy's Legislative Decree 22/1997, which implemented the EU Packaging Directive. It covers all packaging placed on the Italian market by producers and importers. With over 750,000 affiliated companies, it is one of the largest EPR consortia in Europe by membership count.

CONAI itself does not directly manage recycling infrastructure. Instead, it funds and coordinates seven material-specific consortia, each responsible for a different packaging material:

• COMIECO — paper and cardboard packaging
• COREPLA — plastic packaging
• Biorepack — biodegradable and compostable plastic packaging (the newest consortium, which joined the system in 2020–2021)
• RICREA — steel packaging (including tinplate)
• CiAl — aluminium packaging
• RILEGNO — wood packaging (pallets, crates)
• COREVE — glass packaging

When you register with CONAI, you register with the umbrella system. Your fees flow through CONAI to whichever of these consortia handles your packaging materials. You do not need to register separately with COMIECO or COREPLA. One CONAI registration covers all seven.

Who Must Register

The CONAI environmental contribution ordinarily attaches to the first transfer of packaging on Italian territory. In practice, this clearly covers you if you:

• Manufacture goods in Italy and sell them packaged to Italian buyers
• Import packaged goods into Italy from outside the EU (you are the importer of record)
• Import packaged goods into Italy from other EU member states (as an intra-EU acquirer)
• Use service packaging in Italy (restaurants, packaging supplied at point of sale)

The cross-border e-commerce case is less clear-cut. If you run a Shopify or WooCommerce store based in the UK, US, or another EU country and ship orders directly to Italian consumers without any Italian establishment or importer of record, the exact mechanics of your CONAI obligation are not clearly confirmed by CONAI's published sources. In practice, however, the pressure is real: marketplaces — Amazon.it in particular — require sellers to demonstrate Italian EPR compliance, which makes registration the pragmatic path for most distance sellers.

Italy does not have a meaningful de minimis threshold that exempts small sellers from the registration obligation. Companies whose annual contribution stays below €200 per material (€300 for the simplified import procedure) are exempt from paying the contribution, but registration itself is required regardless of size.

How to Register with CONAI

Step 1: Create an account on conai.org

Adhesion is handled through CONAI's website (www.conai.org), and declarations are later submitted via the dedicated declarations portal (dichiarazioni.conai.org). You will need to create a company account. The interface is primarily in Italian, so either work with an Italian-speaking compliance consultant or use browser translation tools carefully. Machine translation of legal forms is not reliable for making compliance decisions — use it to understand the process, not to submit data.

Step 2: Provide your company details

You will need:

• Partita IVA — the Italian VAT number. If you are an Italian company, you have one. If you are a non-Italian company selling into Italy, CONAI will ask for your home country VAT number and may require you to obtain an Italian fiscal code (codice fiscale) for the entity.
• Company legal name and registered address
• ATECO code — Italy's business activity classification code. For e-commerce, this is typically 47.91 (retail via mail order or internet).
• Legal representative details — name, role, and contact information for the person who will sign on behalf of the company.
• Packaging estimate — an estimated annual quantity of packaging by material type in tonnes. This is used to set your initial fee category.

Step 3: Sign the membership agreement

CONAI will generate a membership contract ("atto di adesione") for you to sign. This is a standard form that binds you to comply with CONAI's statutes and regulations, including timely submission of declarations and payment of fees.

Step 4: Receive your CONAI membership number

Once processed, you receive a CONAI member number. This is the reference used in all subsequent declarations and correspondence. Keep this accessible — you will use it frequently.

Timeline

Standard processing takes 2 to 4 weeks. Non-Italian companies sometimes face longer processing times due to additional identity verification requirements.

What You Must Declare

CONAI declarations cover all packaging materials broken down by the seven consortium categories. For a typical e-commerce operation, the relevant materials are:

• Paper and cardboard (COMIECO) — shipping boxes, product boxes, paper bags, tissue paper, paper tape
• Plastic (COREPLA) — poly mailers, bubble wrap, plastic void fill, plastic labels, plastic tape, blister packs
• Biodegradable/compostable plastic (Biorepack) — certified compostable mailers, bags, and void fill
• Steel (RICREA) — metal tins, steel closures
• Aluminium (CiAl) — aluminium foil, aluminium lids, aluminium tubes
• Wood (RILEGNO) — wooden pallets, wooden crates (usually relevant only for B2B or large-volume shipments)
• Glass (COREVE) — glass jars, glass bottles (relevant for food, cosmetics, beverages)

Packaging is classified by level: primary (directly contains the product), secondary (groups units together, typically the e-commerce shipping carton for B2C), and tertiary (transport packaging such as pallets). All three levels must be declared.

Reporting periods

Your declaration frequency depends on how much environmental contribution (CAC) you owed per material in the previous year:

• Annual — up to roughly €3,000 of CAC per material per year
• Quarterly — between €3,001 and €31,000 of CAC per material per year
• Monthly — above €31,000 of CAC per material per year
• Exempt from payment — below €200 of CAC per material (€300 under the simplified import procedure)

Note that these thresholds are set in euros of contribution, not in tonnes of packaging. For companies on the quarterly cadence, reporting periods are January-March, April-June, July-September, and October-December, and each declaration is due by the 20th of the month following the quarter: April 20, July 20, October 20, and January 20.

For a small e-commerce seller, the practical upshot is reassuring: with modest volumes you will almost certainly file annually — or fall below the payment-exemption threshold entirely. CONAI will confirm your cadence when you register.

CONAI Fee Structure for 2026

CONAI fees (Contributo Ambientale CONAI, or CAC) are charged per tonne of packaging placed on the Italian market. Rates are set annually and differ significantly by material. The 2026 rates are:

There is no single "mixed" plastic rate. COREPLA divides plastic packaging into fee bands (fasce) based on sortability and recyclability, and the differences are dramatic: fascia A1.1 is €40/tonne, A2 is €258, B1.1 is €219, B1.2 is €228, B2.1–B2.3 range from €611 to €785, and fascia C is €790/tonne. The flexible film formats that e-commerce typically uses — poly mailers, bubble wrap — usually sit in the high fasce, not the cheap ones.

A worked example

Say you ship 3,000 orders per year to Italy. Each order includes a corrugated cardboard shipping box (300g) and a plastic poly mailer inner layer (25g). Annual totals:

• Cardboard: 3,000 × 0.300 kg = 900 kg = 0.9 tonnes
• Plastic: 3,000 × 0.025 kg = 75 kg = 0.075 tonnes

CONAI fees: 0.9 tonnes of paper at ~€45–55/tonne comes to roughly €41–50, and 0.075 tonnes of flexible film in fascia B2 (€611+/tonne) comes to roughly €46. Total: approximately €90–95 per year.

The fees themselves are modest. The administrative effort of registering, tracking packaging by material, and submitting declarations on time is the main cost for most brands.

The CONAI Declaration Process

Declarations are submitted through the CONAI online portal. The process:

• Log in to dichiarazioni.conai.org with your member credentials.
• Select the relevant period (year, quarter, or month, depending on your cadence) and enter the quantity of packaging placed on the Italian market, broken down by material type and packaging level.
• The portal calculates the fee automatically based on your declared quantities and the current rate schedule.
• Submit the declaration. You will receive a confirmation and an invoice within a few business days.
• Pay the invoice by the due date (typically 30 days from invoice issuance).

The data you need for the declaration comes from two sources: your order management system (which tells you how many units you shipped to Italy) and your packaging Bills of Materials (which tell you how much packaging, by material and weight, goes with each unit). If you do not have structured packaging BOMs, building them is the prerequisite step.

Italy vs. Other Major EU Markets

Understanding how Italy compares to other markets helps prioritize your compliance efforts if you are managing multiple registrations.

Italy stands out for scaling its reporting cadence with contribution volume: small sellers file annually, but larger ones move to quarterly or even monthly declarations, which is more demanding than most other EU markets. For low-volume sellers, the fees themselves are modest relative to the administrative effort of the system.

Non-Italian Companies: Additional Considerations

If your company is registered outside Italy, keep in mind that the CAC ordinarily attaches to the first transfer of packaging on Italian territory — the producer or importer of record. For distance sellers with no Italian establishment, the exact mechanics are not clearly confirmed by CONAI's published sources, so the situations below describe the common practice:

EU companies

Companies registered in other EU member states generally register with CONAI using their home country VAT number. You do not need an Italian entity, though correspondence will be in Italian.

Non-EU companies (UK, US, etc.)

Companies from outside the EU typically designate an authorized representative in Italy (or the EU) to manage their CONAI registration on their behalf. A number of compliance service providers offer this service specifically for CONAI registration.

Amazon marketplace sellers

In practice, marketplace enforcement is the main driver for foreign sellers. Amazon.it requires sellers to demonstrate Italian EPR compliance and will flag or restrict listings from sellers who cannot do so. If you sell via FBA in Italy, your packaging compliance obligation is yours — Amazon handles the physical logistics but not your registration.

Enforcement

Italy has historically been one of the more enforcement-active EU markets for packaging EPR. Companies found to be placing packaging on the Italian market without CONAI membership can face sanctions under Article 261 of Legislative Decree 152/2006, as amended by Legislative Decree 116/2020 (which implemented the EU Waste Framework Directive revisions), and unpaid contributions can be assessed retroactively.

Under the PPWR framework that takes effect in August 2026, enforcement mechanisms across the EU will be further harmonized and strengthened. Companies that have not resolved their Italian EPR obligations before that date will face a tightening enforcement environment.

Putting It Together

The practical checklist for Italian EPR compliance:

• Register via www.conai.org (allow 2–4 weeks)
• Build packaging BOMs for every SKU you sell in Italy, recording material type and weight in grams for each component
• Track Italian orders separately in your order management system (or tag them in your analytics)
• Submit declarations on your assigned cadence — annually for most small sellers; if quarterly, by April 20, July 20, October 20, and January 20
• Pay CONAI invoices within 30 days of issuance
• Keep records (declarations, invoices, sales data, packaging specifications) for at least 5 years

Italy sits alongside Germany, France, and Spain as one of the four highest-priority EPR registrations for any brand selling broadly across Europe. If you have not yet registered with CONAI, every reporting period you delay is another missed filing that creates retroactive liability. For how to run multi-country registrations in parallel rather than one at a time, see the multi-country EPR strategy guide.

Tools like Pack Declare can automate the calculation step — mapping your order volumes to your packaging BOMs and generating CONAI declaration figures for each reporting period automatically — so the remaining effort is purely the submission and payment, not the data work.