Italy Packaging Labelling and EPR Compliance Guide

Italy’s packaging compliance framework combines environmental labelling, Extended Producer Responsibility, packaging-data management, waste collection financing, and future EU packaging requirements.

Companies placing packaging or packaged products on the Italian market may need to:

• Join the Italian packaging consortium system
• Pay and declare the CONAI Environmental Contribution
• Identify packaging materials correctly
• Provide consumer collection instructions
• Maintain data on packaging materials and weights
• Manage packaging imported from other countries
• Control digital and physical environmental labels
• Retain evidence supporting packaging classifications
• Monitor the EU Packaging and Packaging Waste Regulation

The main national framework is contained in Legislative Decree 152/2006, commonly called the Italian Environmental Code. Legislative Decree 116/2020 amended the Environmental Code and introduced the current environmental labelling obligation under Article 219(5). The Ministry adopted operational labelling guidelines through Ministerial Decree No. 360 of 28 September 2022.

Italy’s national rules now operate alongside Regulation (EU) 2025/40, known as the Packaging and Packaging Waste Regulation or PPWR. The PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026, although many individual obligations follow later application dates.

This means businesses need to maintain current Italian compliance while preparing for harmonised EU requirements.

Extended Producer Responsibility, or EPR, makes businesses involved in producing and using packaging financially or operationally responsible for its end-of-life management.

Italy primarily implements packaging EPR through CONAI, the National Packaging Consortium. CONAI coordinates the national packaging recovery and recycling system together with material-specific consortia.

These include consortia covering:

• Steel packaging
• Aluminium packaging
• Paper and cardboard packaging
• Wooden packaging
• Plastic packaging
• Glass packaging
• Certified biodegradable and compostable plastic packaging

CONAI describes itself as the central national system representing packaging producers and users and supporting the achievement of packaging recovery and recycling targets.

Packaging EPR can require companies to:

• Register with CONAI
• Join the appropriate material consortium where applicable
• Identify packaging materials and weights
• Apply the environmental contribution
• Submit periodic declarations
• Maintain invoices and supporting evidence
• Manage imported packaging
• Control exemptions and simplified procedures
• Retain records for reviews or inspections

Under the current framework, packaging producers and users are generally responsible for the correct environmental management of packaging and packaging waste and therefore participate in CONAI.

CONAI identifies packaging producers as including:

• Producers and importers of raw materials intended for packaging
• Producers, processors, and importers of packaging semi-finished products
• Producers of empty packaging
• Importers and traders of empty packaging

Packaging users include:

• Purchasers and fillers of empty packaging
• Importers of packaged goods
• Businesses producing or repairing packaging for their own products
• Traders and distributors of packaged goods
• Traders purchasing and reselling empty packaging in Italy

Producers generally join the relevant packaging material consortium. Recognised alternatives may include independently managing packaging waste or operating an approved return system.

Typical obligated business roles

End users purchasing packaged goods exclusively for internal or personal use may normally be excluded from membership. However, the exclusion may not apply if they conduct commercial activity with the goods, purchase packaged goods directly from abroad, or purchase empty packaging for their own business use.

Italian law allows recognised alternatives to the standard CONAI and material-consortium route.

Packaging producers may:

• Independently organise the management of their packaging waste throughout Italy
• Establish a system for taking back their packaging
• Participate in another recognised autonomous packaging EPR system

These alternatives require formal recognition and evidence that the system can fulfil the applicable collection, recovery, recycling, reporting, and financial responsibilities.

Using an alternative system should not be treated as a simple administrative choice. A business must demonstrate that the selected system covers the relevant packaging flows and legal obligations.

Foreign companies are not generally required to become CONAI members solely because they are located outside Italy. However, they may register voluntarily and manage the environmental contribution for packaging supplied to the Italian market.

Where the foreign supplier does not manage the contribution, the Italian importer or business placing the packaging on the national market generally needs to assess the applicable obligation.

For foreign businesses selling through e-commerce platforms, Italian legislation provides for simplified EPR procedures that may be established through agreements between platforms and EPR systems. If the business does not use the platform’s available compliance service, it may need to join CONAI and fulfil the related obligations directly.

Questions foreign sellers should address

1. Who imports or first places the packaged product on the Italian market?
2. Is the Italian customer acting as importer?
3. Has the CONAI Environmental Contribution already been paid?
4. Is the foreign business voluntarily registered with CONAI?
5. Does an online marketplace provide an EPR compliance procedure?
6. Which party will retain packaging material and weight data?
7. Who will submit declarations and maintain supporting evidence?
8. Will PPWR producer-registration or representative requirements change the arrangement?

Responsibility should be documented contractually, but the contractual wording must reflect the real supply chain.

The CONAI Environmental Contribution, commonly referred to as the CAC, finances packaging waste collection, recycling, and recovery activities.

The contribution is generally calculated according to:

• The total quantity of packaging
• Packaging weight
• Packaging material
• The applicable contribution band or category

The contribution can apply at the first transfer of packaging within Italy and to imported packaging that will generate waste in Italy.

What is the “first transfer”?

The first transfer generally refers to the first transaction in Italy between:

• The last producer or trader of empty packaging and the first actual packaging user
• A raw-material or semi-finished-product producer and a business producing packaging for its own products

The business responsible at the first transfer normally applies, declares, and pays the contribution according to the applicable CONAI procedures.

Packaging imports

Imported packaging materials, empty packaging, and packaging around imported products may be subject to the CAC because the packaging will become waste in Italy.

The responsible Italian business may need to declare and pay the contribution unless a foreign supplier voluntarily registered with CONAI has already handled it.

At the first transfer, the invoice should provide the information needed to identify the environmental contribution.

Depending on the transaction and applicable procedure, this can include:

• Unit packaging weight by material
• Applicable contribution rate or band
• Total contribution amount

For subsequent transactions or certain imports, the invoice may use wording confirming that the CONAI Environmental Contribution has been paid.

Companies should ensure that invoice wording, packaging specifications, and declaration data are consistent. An invoice stating that the contribution has been paid should be supported by valid upstream evidence.

CONAI contribution rates can differ by packaging material and, for some materials, by recyclability or contribution band.

Plastic packaging is divided into contribution bands reflecting factors such as:

• Sortability
• Effective recycling pathways
• Packaging function
• Compatibility with existing collection and recycling systems

Paper packaging and other packaging streams can also have differentiated or specific contribution structures.

Rates can change during the year. For example, CONAI published updated 2026 contribution information and maintains a dedicated 2026 guide covering requirements, procedures, forms, and packaging classifications.

Businesses should therefore use the rate applicable during the relevant transaction or reporting period rather than copying a rate from a previous declaration.

Businesses required to apply and pay the contribution must declare the relevant quantities of packaging transferred or imported into Italy.

CONAI states that:

• During the first year, members submit declarations quarterly
• From the second year, reporting may be annual, quarterly, or monthly
• The frequency depends on the contribution declared during the previous year, assessed by material
• Periodic declarations are generally due by the twentieth day of the month following the reporting period
• Submissions are completed through the CONAI online declaration service

Practical declaration process

Companies should maintain packaging data throughout the year rather than rebuilding it before each deadline.

Environmental packaging labelling has been mandatory in Italy since 1 January 2023.

Article 219(5) of Legislative Decree 152/2006 requires packaging to be appropriately labelled to facilitate collection, reuse, recovery, and recycling and to provide consumers with correct end-of-life information.

The rules distinguish between packaging intended for consumers and packaging intended for commercial or industrial circuits.

The two main labelling scenarios

This distinction should be based on the packaging’s intended final circuit, not merely on the company selling it.

For single-component packaging intended for the final consumer, the Ministry’s guidelines identify two minimum information elements:

1. The material identification code under Decision 97/129/EC
2. Collection instructions for the packaging

The collection wording should identify the relevant material family and guide the consumer toward the appropriate separate collection stream. Companies are also encouraged to remind consumers to check the rules of their municipality, as local collection arrangements can vary.

Common examples of material identification codes

The correct code depends on the actual packaging material and structure. Businesses should not select a code based only on visual appearance.

Practical B2C label structure

A consumer label may contain:

• Packaging component name
• Material identification code
• Material family
• Collection instruction
• Reminder to check local municipal rules
• Optional separation or emptying instruction

For example:

The wording and layout can vary, provided that the mandatory information is clear and effective.

Packaging intended for professional, commercial, industrial, logistics, or transport use follows a simpler minimum labelling model.

B2B packaging must display the material identification code under Decision 97/129/EC. It does not need to carry the consumer collection instructions required for B2C packaging.

Other information remains voluntary. The required material information can also be conveyed through digital systems, transport documentation, or equivalent commercial documents where permitted.

Examples of B2B packaging

• Transport cartons
• Industrial drums
• Pallets
• Stretch wrap
• Intermediate bulk containers
• Industrial sacks
• Shipping crates
• Packaging used only within professional supply chains

Businesses should still maintain full component, material, and weight data even when the physical label only includes the material code.

Multi-component packaging requires an assessment of which parts can be separated manually.

Components that can be separated by hand

Where a consumer can separate a component manually and safely, each separable component should generally carry:

• Its own material identification code
• Its own collection instruction

Components that cannot be separated manually

Where a label, closure, window, coating, or other component cannot be separated by hand:

• The main packaging body should display the identification code and collection instruction
• The non-separable component can display its material code where feasible
• It should not be assigned a separate collection instruction that conflicts with the main body’s waste stream

The Ministry’s guidance uses this distinction to ensure that consumer disposal instructions reflect how the complete packaging will actually be discarded.

Multi-component assessment questions

1. What is the main packaging body?
2. Which components are integrated into it?
3. Which components can be separated using only the hands?
4. Can separation occur safely?
5. What is the material of each component?
6. Which collection stream applies after normal consumer use?
7. Does the printed label reflect the packaging placed on the market?

This analysis should be documented in the packaging technical file or artwork approval record.

Composite or multilayer packaging can be more difficult to label because it contains several materials that cannot always be separated.

Companies should determine:

• The predominant material
• Whether the structure has a specific Decision 97/129/EC code
• The percentage of each material
• Whether the packaging is recyclable in the relevant stream
• Which collection instruction is appropriate
• Whether additional digital information would improve clarity

The Ministry’s guidelines include specific methods and examples for paper-based composites, polylaminates, and multilayer plastic structures.

A generic statement such as “mixed material” should not replace a proper classification where an applicable material code exists.

Yes. Italy allows digital channels to replace or supplement physical environmental labelling information.

Permitted digital methods can include:

• QR codes
• Mobile applications
• Product webpages
• Digital product information pages
• Other accessible electronic systems

The digital information must be easy to access, accurate, clear, and linked to the correct packaging.

Where packaging is intended for final consumers, the packaging or point of sale should provide clear instructions explaining how the mandatory environmental information can be accessed digitally. The point of sale can be physical or digital.

Digital labelling controls

A QR code should not be added without a process for maintaining the destination and content.

Digital solutions are particularly relevant where physical labelling is difficult.

The Ministry’s guidance recognises potential physical or technological limitations for:

• Small packaging
• Multilingual packaging
• Imported packaging
• Neutral packaging
• Packaging with limited printable surfaces

Where mandatory information cannot reasonably be applied physically, it may be communicated digitally or through a company or reseller website. Consumers should still receive clear information on how to access it.

For neutral packaging supplied through B2B channels, mandatory material information may also be communicated through:

• Transport documents
• Delivery notes
• Technical specifications
• Commercial documents
• Supplier portals
• Product information systems

Responsibility for adding or transmitting the environmental information should be agreed between the packaging supplier and customer.

Italy’s consumer labelling model recognises that municipal collection rules can differ.

A label should identify the relevant material family and can advise the consumer to check the rules of the local municipality.

This is important because:

• Collection colours may differ
• Multimaterial packaging may be treated differently
• Organic-waste acceptance may vary
• Local facilities may use different instructions
• Special collection rules may apply to hazardous contents

Companies should avoid excessively specific instructions that are correct in only one municipality unless the product has a limited geographic distribution.

Compostable packaging requires additional controls.

Packaging waste intended for organic collection should meet applicable compostability requirements and be appropriately labelled. The Ministry’s guidance identifies information such as:

• Compliance with the relevant compostability standard
• Identification of the producer
• Identification of the certifying body
• Instructions directing consumers to the correct organic-waste stream

The guidance specifically refers to packaging certified to EN 13432 for recovery through composting or biodegradation.

Companies should not use “biodegradable” and “compostable” as interchangeable claims. The label should identify the actual conditions and evidence supporting the claim.

Italy applies specific requirements to plastic carrier bags.

Permitted formats can include:

• Reusable bags meeting applicable thickness and recycled-content requirements
• Certified biodegradable and compostable bags for carrying goods
• Ultra-light biodegradable and compostable bags used for hygiene or loose food

Qualifying bags may not be distributed free of charge and must meet applicable identification and environmental labelling requirements.

Retailers and packaging suppliers should manage bag specifications separately from ordinary flexible packaging because the legal conditions and supporting evidence differ.

Italian EPR and environmental labelling rely on the same core packaging data.

Recommended packaging master data

One packaging data source should support both the artwork and EPR declaration. This reduces the risk of declaring one material while labelling the packaging as another.

CONAI declarations are driven by packaging quantities and weights.

A basic calculation is:

Packaging weight per unit × units transferred or imported into Italy

Example calculation

Each material should be assigned to the correct CONAI category and contribution band.

Suitable evidence sources

• Supplier specifications
• Packaging bills of materials
• Controlled sample weighing
• Technical drawings
• Manufacturing records
• Packaging converter declarations
• Approved engineering calculations

Estimated weights should be documented and reviewed when the design, supplier, or material changes.

Companies should distinguish between packaging entering, circulating within, and leaving Italy.

CONAI provides special procedures for imports, exports, and specific packaging flows. Companies should use the procedure that matches the actual commercial activity rather than applying one generic calculation to every import.

From 12 August 2026, Italy’s national packaging framework will operate alongside the directly applicable PPWR requirements.

The PPWR introduces or expands requirements covering:

• Substances in packaging
• Design for recycling
• Recyclability performance grades
• Recycled content in plastic packaging
• Compostability
• Packaging minimisation
• Empty space
• Restricted packaging formats
• Reuse and refill
• Technical documentation
• EU Declarations of Conformity
• Harmonised labelling
• EPR registration and reporting

The PPWR applies across packaging materials, sectors, and packaging levels, including household, retail, commercial, industrial, transport, and e-commerce packaging.

CONAI membership and CAC declarations will not, by themselves, prove compliance with these packaging design and documentation requirements.

Italy’s current environmental labelling rules remain important, but the PPWR introduces a future harmonised EU label.

Article 12 of the PPWR provides that packaging will need a harmonised material-composition label from 12 August 2028 or 24 months after the applicable implementing acts enter into force, whichever is later.

CONAI has advised companies that the technical European labelling framework is still developing and that businesses should monitor the implementing specifications before redesigning long-term packaging portfolios.

Practical transition actions

1. Continue complying with current Italian environmental labelling.
2. Maintain accurate packaging material and component data.
3. Avoid producing excessive long-term artwork stock.
4. Identify packaging likely to remain on the market after 2028.
5. Monitor the harmonised EU label and waste-bin label specifications.
6. Review physical and digital label space.
7. Plan how Italian information will transition to the EU format.
8. Keep artwork version histories and effective dates.

Companies should not remove current Italian environmental information before the harmonised EU requirements legally replace or modify it.

Italy has legislated a tax on qualifying single-use plastic products, commonly referred to as the Plastic Tax or MACSI tax.

The implementation date has been postponed several times. The 2026 Budget Law replaced the previous 1 July 2026 date with 1 January 2027.

The Plastic Tax is separate from:

• CONAI membership
• The CONAI Environmental Contribution
• Environmental packaging labelling
• PPWR recycled-content obligations
• Packaging EPR declarations

Companies potentially affected should monitor final administrative instructions and avoid treating CAC payment as compliance with the Plastic Tax.

Step 1: Map the Italian supply chain

Identify:

• Packaging manufacturers
• Packaging users and fillers
• Importers
• Distributors
• Retailers
• Foreign suppliers
• E-commerce platforms
• Italian customers
• Export flows

Step 2: Determine the responsible legal entity

Confirm who produces, imports, purchases, fills, transfers, or places the packaging on the Italian market.

Step 3: Assess CONAI membership

Determine whether the company is a producer, user, importer, trader, self-producer, or excluded end user.

Step 4: Build a complete packaging inventory

Include:

• Primary packaging
• Secondary packaging
• Transport packaging
• E-commerce packaging
• Service packaging
• Labels
• Closures
• Films
• Inserts
• Pallets

Step 5: Create a packaging bill of materials

Record the material and weight of each packaging component.

Step 6: Classify B2B and B2C packaging

Identify the intended destination circuit and the minimum label information required.

Step 7: Prepare environmental labels

Assign:

• Material codes
• Component names
• Collection instructions
• Local collection reminder
• Digital access instructions where used

Step 8: Assess the CAC

Determine:

• Contribution category
• Contribution band
• First-transfer point
• Import procedure
• Upstream payment evidence
• Exemptions or simplified procedures

Step 9: Establish declaration workflows

Set the applicable annual, quarterly, or monthly frequency and assign an internal owner.

Step 10: Control invoices and contribution evidence

Ensure invoice wording agrees with the applicable CONAI procedure.

Step 11: Manage digital labelling

Test QR codes, assign content ownership, and maintain packaging-specific information.

Step 12: Prepare for PPWR

Assess packaging substances, recyclability, recycled content, minimisation, documentation, and future harmonised labels.

Step 13: Monitor the Plastic Tax

Prepare product and packaging data for the currently scheduled 1 January 2027 implementation.

Step 14: Maintain change control

Reassess packaging compliance whenever materials, suppliers, weights, labels, markets, or packaging versions change.

Italian packaging compliance requires businesses to manage connected requirements across packaging materials, products, suppliers, contribution categories, environmental labels, declarations, imports, exports, and EU market rules.

ComplyMarket’s packaging compliance approach supports businesses in identifying packaging obligations, connecting requirements to packaging items, collecting supplier information, maintaining evidence, managing country-specific rules, and preparing structured reports.

ComplyMarket can help companies manage:

• Italian packaging EPR applicability
• CONAI producer and user role assessments
• Packaging inventories and bills of materials
• Packaging material and component data
• Product-to-packaging mapping
• B2B and B2C classification
• Decision 97/129/EC material codes
• Environmental label information
• QR-code and digital-label records
• Supplier specifications and declarations
• Packaging weights and quantity calculations
• CAC contribution evidence
• CONAI declaration inputs
• Import and export packaging data
• Packaging artwork version control
• PPWR sustainability assessments
• Technical documentation and compliance evidence
• Regulatory updates and deadline tracking
• Audit-ready reporting records

ComplyMarket’s EPR management framework also supports jurisdiction-based responsibility mapping, producer master data, packaging quantity management, reporting workflows, warnings, and evidence control.

For companies managing many products, packaging components, suppliers, and markets, this creates one controlled source of packaging data instead of separate spreadsheets for environmental labels, CONAI declarations, PPWR assessments, and customer requests.