EPR in Italy: CONAI, CAC Fees & the RENAP Register

If you sell products to customers in Italy, you are legally responsible for the waste your products leave behind under Extended Producer Responsibility rules. Ignoring these duties carries severe consequences for e-commerce merchants: instantly blocked marketplace listings, suspended seller accounts, retroactive fee assessments, and administrative fines from national regulators. You cannot treat Italian environmental compliance as an afterthought, because marketplaces actively gatekeep access to buyers until your producer status is formally verified.

Unlike countries that run a single unified portal, Italy splits compliance across several national consortia and registries, and which ones apply depends on the products and packaging materials you place on the market. That structural division means a distance seller often engages more than one authority at once.

Who has to comply, and the thresholds

Italy operates a zero-threshold environment for packaging. There is no small-seller de-minimis exemption for foreign distance sellers. If you place a single unit of packaging on the Italian market, your financial and reporting liability attaches from that first unit.

If you import packaged goods into Italy or sell directly to Italian end-users through a webshop, you are legally defined as the obligated producer. Online marketplaces are required to verify this compliance and act as strict gatekeepers: if you cannot provide valid registration credentials for your packaging and electronics, they will block your ability to sell into Italy until your status is proven.

The authorised-representative rule varies by register, which is the point international merchants most often miss. For electrical equipment and batteries, a foreign online seller without an Italian establishment appoints a local authorised representative to hold the compliance duties. Packaging works differently: a foreign distance seller either joins the national packaging consortium, arranged through local representation, or seeks approval as an autonomous system, which takes careful administrative setup to be properly covered.

Italy offers no small-seller exemption for packaging. Your reporting and fee liability attaches from the very first unit placed on the market, and marketplaces will block your listings if you have not registered.

Which registers apply in Italy

Because the Italian framework relies on specialised organisations for different material streams, you must identify and engage the correct authority for every category of product you sell.

CONAI: the packaging consortium

Packaging compliance in Italy sits under Law D.Lgs 152/2006, the Environmental Code, and is run by the CONAI packaging consortium under the Environmental Code. CONAI (Consorzio Nazionale Imballaggi) is an umbrella consortium that sits above material-specific consortia for the seven recognised packaging materials: steel, aluminium, paper, wood, plastic, bioplastics, and glass.

Under this system, producers pay the CONAI environmental contribution, the CAC (Contributo Ambientale CONAI). The fee is applied at the first sale or entry onto the Italian market and is differentiated by packaging material. To comply, a producer either joins CONAI and its relevant material consortia or is recognised as an autonomous system by the Ministry, which is rare for a standard e-commerce operation.

Once registered, you follow a periodic CAC declaration cadence. Depending on the volume and value of the packaging you place on the market, you report your packaging weights on a monthly, quarterly, or annual basis. Single-use plastics have been separately regulated since 3 July 2021 under the EU Single-Use Plastics Directive 2019/904, which adds a further layer of material scrutiny to your packaging choices.

RENAP: WEEE, batteries, and tyres

If your catalogue includes electrical and electronic equipment, batteries, or tyres, you comply through rules overseen by the Ministry of the Environment and Energy Security (MASE) together with the Chambers of Commerce. Registration runs through the RENAP national producer register (Registro Nazionale dei Produttori).

For electronics, the current register has been active since 1 January 2018 under Law D.Lgs 49/2014. Batteries are governed by the latest decree, D.Lgs 29/2026, in force from 7 March 2026. Tyre producers (pneumatici fuori uso) complete their RENAP registration from 1 May 2025.

To stay compliant, producers register and submit annual data reports detailing the volumes and categories of equipment placed on the market. A foreign online seller with no established entity in Italy must appoint a local authorised representative to secure the RENAP registration and file the annual reports on their behalf.

CONOU: waste oils

For businesses placing industrial or automotive lubricants on the market, Italy runs an active national scheme under the EU Waste Framework Directive 2008/98/EC, managed through the CONOU used mineral oils consortium. It is a mandatory duty for producers of those specific goods, but a niche stream that sits outside typical consumer e-commerce.

MASE: end-of-life vehicles

Extended Producer Responsibility for vehicles is overseen by MASE under the D.Lgs 209/2003 end-of-life vehicles framework, covering the recovery and recycling of cars and heavy automotive parts. Like waste oils, it is a distinct, specialised scheme and largely out of scope for a standard online seller shipping retail goods.

What it costs

The core of your packaging cost in Italy is the CONAI environmental contribution, the CAC. This levy is applied at the point of first sale onto the Italian market and is calculated per kilogram or per tonne, depending on the material classification of the packaging you introduce.

CONAI does not apply a single flat rate to all materials. The consortium splits the plastic-packaging contribution into recyclability and selectability bands. This means clean, easily recycled mono-materials sit in a lower, cheaper band, while complex, hard-to-recycle composite plastics fall into a higher band that costs more per kilogram. Your choice of packaging material is a direct financial decision that shapes your overall bill.

To remit these fees you follow a periodic CAC declaration schedule. Depending on the total volume and value of the packaging you place on the market, you submit declarations monthly, quarterly, or annually.

For electronics, batteries, and tyres managed through the RENAP national producer register, the cost logic is similar. Producers pay registration costs and fund the ongoing collection and treatment of end-of-life products through annual reporting. Because foreign distance sellers must use an authorised representative for the RENAP streams, you also factor in the commercial cost of retaining that local entity on top of your statutory recycling fees.

On enforcement, the Italian authorities keep close oversight. Failing to pay the CAC or complete your registrations triggers administrative sanctions. Under Law D.Lgs 152/2006 for packaging and Law D.Lgs 49/2014 for WEEE, regulators can levy administrative fines and pursue retroactive payments for unregistered volumes placed on the market.

For most e-commerce sellers, though, the most immediate pressure comes from the sales channels. Marketplaces police these requirements and will pull your listings and suspend your account well before a national regulator issues a formal fine. Without valid compliance credentials, your access to Italian buyers is blocked at once.

The deposit-return system

Unlike some European markets that run a separate collection scheme for drinks containers, Italy does not operate a national statutory deposit-return system for beverage packaging as of 2026.

If you sell beverages into Italy, your obligations stay consolidated. Packaging duties for bottles and cans run entirely through the CONAI framework and the periodic CAC declaration. There is no separate, additive deposit scheme to layer on top of your Extended Producer Responsibility reporting, so your focus stays on accurate material-weight classification within the CONAI bands.

Key dates and upcoming changes

Italy is aligning its national frameworks with the broader EU directives. The milestones that matter to sellers are below.

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Sources:

• CONAI environmental contribution (CAC) by material
• RENAP national producer register
• CONOU used mineral oils consortium
• EU Single-Use Plastics Directive 2019/904
• Packaging and Packaging Waste Regulation 2025/40