With the aim of simplifying procedures for its EPR Organisation Members and adapting them to the specific needs of different sectors, CONAI has, from its first year of operation, developed a number of special procedures for the declaration, application and/or exemption of the EPR Fee for certain sectors and for particular packaging items or packaging flows.
Simplification is an ongoing process, supported by continuous dialogue with companies and the associations representing them, which – thanks to their operational experience – help identify the most effective practical solutions.
The main special cases are listed below:
- Primary packaging for medical devices (Exemption based on forecast data or based on actual data when used in public or private healthcare facilities.)
- Primary packaging for pharmaceutical products (Exemption based on forecast data or based on actual data when used in public or private healthcare facilities, or disposed of through the ASSINDE system.)
- Aluminium, paper and plastic labels (Simplified procedure for declaration of the EPR Fee with flat‑rate values based on turnover bands.)
- Cork packaging (Simplified procedure for declaration of the EPR Fee.)
- Aluminium foil – Food‑wrap film (EPR Fee exemption for “aluminium” rolls up to 50 metres and “plastic” rolls up to 75 metres, intended for domestic use. EPR Fee applies to rolls exceeding 50 and 75 metres respectively. For both items in professional formats, exemption may be requested from suppliers if the items are unambiguously intended for resale “on the shelf” to consumers.)
- Disposable tableware (plates and cups) (Exemption for the purchase of disposable tableware sold in packs intended exclusively for domestic use.)
- “Small traders” of empty packaging; producers marketing packaging made of other materials to “complete the range or packaging”; processors carrying out minimal work on finished packaging without adding further material that affects its weight (Incentive procedure for application of the EPR Fee.)
- Adhesive tapes and gummed papers (Application of EPR Fee on 50% of the weight of the adhesive tape.)
- Refillable and non‑refillable gas containers of various types (EPR Fee exemption for gas containers, if refillable.)
- Multi-material tanks, and plastic/steel drums that are regenerated and returned to the market within Italy (Simplified procedure providing for a flat‑rate EPR Fee calculated on the number of units transferred.)
- Reusable packaging used within a production cycle or commercial network (EPR Fee exemption for reusable packaging used within the production cycle/commercial network.)
- Reusable packaging used in specific circuits (Incentive formulas whereby the EPR Fee applies at the end of the packaging’s re-use cycle instead of the moment it is first placed on the market, or with a percentage reduction of the packaging weight.)
- Wooden pallets returned to the market and newly manufactured pallets structurally designed for long‑term re-use; repair of pallets belonging to third parties (Incentive formulas providing percentage reductions of the weight subject to the EPR Fee and calculation of the fee based on the standard weight of new wood used for pallet repair.)
- Rolls, tubes and cores on which flexible material is wound (EPR Fee exemption for tubes on which flexible material – as raw material or semi‑finished product – is wound, when used exclusively during the processing/transformation phases of the flexible material, including when performed by parties other than the consumer.)
- Emptyable capsules for beverage dispensing systems (Application of the EPR Fee to capsules for beverage dispensing systems designed to be manually emptied by the consumer, as they fall within the definition of packaging.)
- Shell‑type containers for dishwasher deodorisers and air‑fresheners
- Merchandise displays
- Black annealed wire for packaging
- Small‑sized packaging
- Handle tapes for bundling
- Scrap from self-production of packaging(EPR Fee exemption procedure based on actual data for scrap generated during the self-production/transformation process of packaging, when the scrap is managed as waste for disposal or recovery/recycling, or transferred (by the self‑producer) as a by‑product to companies to be used in making non‑packaging products.)
- Packaging made of “regenerated cellulose” and “chemically modified cellulose” (Application of the bioplastic EPR Fee for packaging made of “regenerated cellulose” certified biodegradable and compostable under EN 13432, and exemption from the EPR Fee for those not compliant with the standard.)