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

Packaging compliance in Italy stands on two names: the CONAI consortium, which collects an environmental contribution on every material you place on the market, and RENAP, the single national register that handles electronics, batteries and tyres. Between them they decide what a seller registers for and what they pay.

What makes Italy distinctive is how much it has consolidated - rather than run a separate body for every product stream, the country has spent years folding registers into RENAP one at a time, while packaging stays under the CONAI roof.

Italy's consolidation is uneven, though, and the gaps are where cross-border sellers trip. Packaging sits entirely apart from RENAP, waste oils have their own consortium again, and the rule for appointing a local representative changes depending on which register you are dealing with. Work through the stream you actually sell, not the country as a single portal.

RENAP: the register that keeps absorbing streams

For electrical and electronic equipment, batteries and tyres, compliance funnels through the RENAP national producer register (Registro Nazionale dei Produttori), overseen by the Ministry of the Environment and Energy Security (MASE) together with the Chambers of Commerce. Once registered, a producer receives an entry number that has to appear on commercial documents, and files annual data reports on the volumes and categories placed on the market.

The reason RENAP is worth understanding as a moving target rather than a fixed list is that it has steadily grown. Electrical and electronic equipment has been under its open scope since 15 August 2018 under Legislative Decree D.Lgs 49/2014 on WEEE. Tyre producers were folded in during May 2025. Batteries followed under the D.Lgs 29/2026 battery decree, in force from 7 March 2026, which aligns Italy with the EU Battery Regulation. A seller who registered years ago for electronics alone cannot assume that covers a newer product line - each absorption is a fresh registration duty.

For a foreign online seller with no established entity in Italy, the RENAP streams require a local authorised representative. That representative secures the registration and files the annual reports on the seller's behalf. This is the rule international merchants most often miss, because it does not carry across to packaging.

CONAI and the CAC: what the environmental contribution charges

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

Members pay the CONAI environmental contribution, the CAC (Contributo Ambientale CONAI), applied at first sale or first entry onto the Italian market and set separately for each material rather than as a single flat rate. The plastic contribution in particular is divided into recyclability and selectability bands, so a clean, easily recycled mono-material sits in a lower band than a complex composite that costs more per unit of weight. Packaging choice is therefore a direct cost lever, not just a design one.

Reporting follows a periodic CAC declaration cadence. Depending on the volume and value of packaging placed on the market, a producer submits declarations monthly, quarterly or annually. To comply, a business joins CONAI and its relevant material consortia, or is recognised as an approved autonomous system by the Ministry - rare for a standard e-commerce operation.

Who owes the CAC, and why it turns on how you sell

Italy's packaging model allocates the CAC duty differently from most EU markets, and getting this wrong is expensive. An EU producer with no establishment in Italy usually carries no direct CONAI obligation. In that case the environmental contribution is declared and paid by the Italian importer or first buyer that places the goods on the market.

The picture changes for direct-to-consumer online sellers. A foreign seller takes on CONAI membership directly when it ships packaged goods to Italian buyers by e-commerce, or when it joins voluntarily. For most cross-border webshops shipping straight to Italian households, that is the operative case: the duty is yours, and it runs through CONAI membership rather than an authorised-representative appointment of the kind the RENAP streams use. Confirm which side of that line your fulfilment model falls on before you assume an Italian intermediary is carrying the contribution for you.

Waste oils, vehicles and the streams still forming

Two further streams carry active duties but fall outside typical consumer e-commerce. Industrial and automotive lubricants are covered by a national scheme under the Waste Framework Directive, managed through the CONOU used mineral oils consortium. End-of-life vehicles run under the D.Lgs 209/2003 vehicles framework, overseen by MASE, covering the recovery and recycling of cars and heavy automotive parts. Both are mandatory for producers of those specific goods and largely irrelevant to a seller shipping retail products.

Single-use plastics have been separately regulated since 3 July 2021 under the EU Single-Use Plastics Directive 2019/904, adding a layer of material scrutiny on top of the CONAI classification. Fishing-gear EPR is only partly in force - the duty flows from the Single-Use Plastics Directive, but Italy's implementing decree was still pending, so treat it as coming rather than active. A textiles scheme is on the horizon too: Italy's own national decree remained a draft with no gazette publication in mid-2026, while Directive (EU) 2025/1892 on textile EPR sets a 17 April 2028 deadline for a scheme to be operating.

Costs, enforcement and the marketplace layer

The core packaging cost is the CAC, calculated by weight and material and remitted on the periodic declaration schedule. For the RENAP streams, producers pay registration costs and fund the ongoing collection and treatment of end-of-life products through their annual returns. Because foreign distance sellers must retain a local authorised representative for RENAP, the commercial cost of that entity sits on top of the statutory recycling fees.

On enforcement, failing to pay the CAC or complete a registration triggers administrative sanctions. Under D.Lgs 152/2006 for packaging and D.Lgs 49/2014 for WEEE, regulators can levy administrative fines and pursue retroactive payments for volumes placed on the market while unregistered. For most e-commerce sellers the faster pressure comes from the sales channels: online marketplaces verify producer status and will pull listings or suspend an account well before a national regulator issues a formal penalty, so a missing registration tends to cost you sales before it costs you a fine.

No national deposit-return scheme, as things stand

Unlike several European markets that layer a separate deposit scheme over drinks containers, Italy does not operate a statutory national deposit-return system for beverage packaging as of 2026. If you sell beverages into Italy, the obligation stays consolidated: bottles and cans are covered by the CONAI framework and the periodic CAC declaration, with no additive deposit to administer. The focus stays on accurate material-weight classification within the CONAI bands. A deposit-return system, if one is legislated later, would be a separate regime from EPR rather than part of it.

The compliance calendar at a glance

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Sources:

• CONAI packaging consortium and the CAC contribution
• RENAP national producer register
• CONOU used mineral oils consortium
• Ministry of the Environment and Energy Security (MASE)
• EU Single-Use Plastics Directive 2019/904
• Directive (EU) 2025/1892 on textile EPR