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 six 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 800,000 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 six material-specific consortia, each responsible for a different packaging material:

• COMIECO — paper and cardboard packaging
• COREPLA — plastic packaging
• 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 everything.

Who Must Register

The obligation falls on anyone who places packaging on the Italian market for the first time. In Italian EPR law, this means 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)
• Sell directly to Italian consumers from outside Italy via an online store — even if you never hold inventory on Italian soil
• Use service packaging in Italy (restaurants, packaging supplied at point of sale)

The cross-border e-commerce case is important: if you run a Shopify or WooCommerce store based in the UK, US, or another EU country, and you ship orders to Italian addresses, you are placing packaging on the Italian market and you need a CONAI registration.

Italy does not have a meaningful de minimis threshold that exempts small sellers from the registration obligation. There is a simplified declaration path for companies with very low volumes, but registration itself is required regardless of size.

How to Register with CONAI

Step 1: Create an account on conai.org

The CONAI portal (portale.conai.org) handles registrations. 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 six 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
• 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

CONAI requires quarterly declarations for most companies. Reporting periods are January-March, April-June, July-September, and October-December. The declaration for each quarter must be submitted by the end of the following month: April 30, July 31, October 31, and January 31. This is one of the strictest reporting cadences in the EU — most other countries allow annual reporting.

Very small producers (typically defined as companies placing less than 1 tonne of packaging on the Italian market per year) may be eligible for simplified annual reporting. CONAI will confirm whether you qualify 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 indicative rates are:

The rates above deserve explanation. Cardboard and aluminium carry very low per-kg rates because the market for recycled cardboard and aluminium is strong — the value of the recovered material offsets the collection cost. Steel, wood, and glass carry zero environmental contribution in years where collection revenues cover costs independently. Plastic carries the highest rate because plastic recycling is the most cost-intensive.

COREPLA further subdivides plastic by polymer type, with different rates for PET bottles, HDPE containers, LDPE film, expanded polystyrene, and other plastics. For most e-commerce operations, the relevant categories are LDPE film (poly mailers, bubble wrap) and mixed plastics (rigid packaging, blister packs).

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 × €4.00) + (0.075 × €155.00) = €3.60 + €11.63 = €15.23 per year.

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

The CONAI Declaration Process

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

• Log in to portale.conai.org with your member credentials.
• Select the relevant quarter 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 its quarterly reporting cadence, which is more demanding than most other EU markets. On the other hand, Italy's per-kg fees are among the lowest in Europe, particularly for cardboard. The administrative burden is high relative to the financial cost.

Non-Italian Companies: Additional Considerations

If your company is registered outside Italy, CONAI's treatment depends on your situation:

EU companies

Companies registered in other EU member states can register directly with CONAI using their home country VAT number. You do not need an Italian entity. The registration process is the same, though correspondence will be in Italian.

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

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

Amazon marketplace sellers

Amazon.it requires sellers to provide their CONAI registration number. As of 2025, Amazon actively enforces this requirement and will flag or restrict listings from sellers who cannot provide a valid CONAI member number. 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. CONAI shares membership data with the Italian environmental protection authorities (ISPRA) and with municipal waste management bodies. Companies found to be placing packaging on the Italian market without CONAI membership can face fines under Legislative Decree 116/2020 (which implemented the EU Waste Framework Directive revisions). Penalties can reach several thousand euros per violation and 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 on portale.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 quarterly declarations by April 30, July 31, October 31, and January 31
• 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, the quarterly declaration cadence means every quarter 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 quarterly CONAI declaration figures automatically — so the remaining effort is purely the submission and payment, not the data work.