Italy EPR Registration for Cross-Border Sellers: CONAI, WEEE and Packaging Obligations
Updated 2026-08-17
Italy's EPR framework requires any company placing packaged goods, electrical equipment or batteries on the Italian market to register with the relevant national scheme. Packaging: register with CONAI (Consorzio Nazionale Imballaggi) or an alternative PRO (CIAL, COMIECO, COREVE, COREPLA, RICREA, RILEGNO). WEEE: register with the Registro AEE (managed by CdC) and join an AEE producer responsibility scheme. Batteries: register with the Registro Pile e Accumulatori. Non-EU sellers must appoint an Italian-based authorised representative. Annual declarations are due by February 28 (packaging) and June 30 (WEEE/batteries). Non-compliance fines: €10,000-€100,000 for packaging, up to €50,000 for WEEE.
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Primary sources
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FAQ
What is CONAI and do I need to register?+
CONAI (Consorzio Nazionale Imballaggi) is Italy's national packaging consortium. Any company that places packaging on the Italian market — including the packaging around products you sell — must register with CONAI or an alternative PRO. Registration requires your Italian fiscal code (or authorised representative's details), company information, and estimated packaging volumes by material type. The environmental contribution (contributo ambientale) is paid monthly based on actual volumes, with rates varying by material: paper €30-€60/tonne, plastics €80-€350/tonne, steel €20-€40/tonne, aluminium €40-€80/tonne, wood €3-€10/tonne.
Do I need an Italian authorised representative for EPR?+
Yes, if your company is not established in Italy (or the EU). Italian law requires non-EU/EEA companies to appoint an authorised representative (mandatario) with an Italian fiscal code who handles EPR registration, declarations and payments on your behalf. The representative is jointly liable for compliance. You can use a specialised compliance service provider or an Italian law firm. The representative's details must appear on your CONAI, Registro AEE and Registro Pile registrations.
What are the EPR deadlines for Italy?+
Key deadlines: CONAI registration — within 30 days of first placing packaging on the Italian market; monthly environmental contribution — due by the 20th of each month for the previous month; annual packaging declaration (MUD) — due February 28 for the previous calendar year; WEEE annual declaration — due June 30; battery annual declaration — due June 30. Late registration with CONAI incurs a €5,000-€40,000 administrative sanction. Late MUD filing: €2,500-€15,500.
How much does Italy EPR compliance cost?+
Approximate annual costs for a typical cross-border seller: CONAI registration and environmental contribution: €300-€2,000 (depending on packaging volume and material mix); WEEE registration: €300-€800; Battery registration: €200-€500; Authorised representative: €500-€1,500/year. Total: approximately €1,300-€4,800/year. These are base costs; actual environmental contributions scale with volume. High-volume sellers (100,000+ units/year) should budget €5,000-€15,000+.
What is the MUD declaration and who must file it?+
The MUD (Modello Unico di Dichiarazione ambientale) is Italy's annual environmental declaration, filed through the Chamber of Commerce's online portal. Any company that placed packaging, electrical equipment or batteries on the Italian market in the previous calendar year must file a MUD by February 28. The declaration reports: quantities of packaging by material type, quantities of WEEE and batteries placed on the market, and the PRO through which you are registered. Late filing penalties: €2,500-€15,500 for packaging, €2,500-€15,000 for WEEE. If you use a compliance provider, they typically prepare and file the MUD on your behalf, but you remain legally responsible for the accuracy of the data.
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