Declaration and payment

How importers calculate the EPR Fee on empty packaging and/or packaged goods

The obligations for importers vary depending on the nature and destination of the imported packaging.

For periodic declarations and payment of the EPR Fee, different procedures apply: for the import of empty packaging, a procedure similar to that used for producers; for the import of packaged goods, an ordinary procedure, a simplified procedure (which is divided into three different options), and for small businesses a flat‑rate procedure.

Each importer must follow different rules (or choose between different options) depending on the materials imported (empty packaging, raw materials, packaged goods) and depending on whether the materials are destined for users, for other operators, or for direct use by the importer.

When the EPR Fee declaration must be submitted

Entities required to apply and pay the EPR Fee must declare to CONAI the quantities of packaging transferred or imported into Italy.

In the first year, EPR Organisation Members must submit the declaration quarterly.

From the second year, the frequency may be annual, quarterly or monthly, depending on the total EPR Fee declared in the previous year, by material (for paper and plastic, the sum of the fee bands).

In specific cases, the EPR Fee declaration is required only annually.

Periodic declarations must be submitted by the 20th day of the month following the reference period.

There is also an exemption threshold for declarations. See the tables showing the quantities and values that fall within the declaration‑exemption threshold for the years 2015–2025.

Declarations must be submitted exclusively through the online declaration service.

When the EPR Fee is paid to CONAI

The amounts resulting from the periodic declaration must be paid upon receipt of the relevant invoices issued by CONAI to the declarant EPR Organisation Members.

CONAI issues invoices on behalf of each of the seven Packaging Material Consortia, with reference to the respective materials. Therefore, Producers or Importers using the ordinary procedure will receive separate invoices for each material. In the case of declarations submitted under the simplified procedure, CONAI issues a single invoice (covering all materials).

Agreements with trade associations

Since the beginning of its activity, CONAI has signed specific agreements with certain trade associations that provide for particular conditions for the declaration, application or exemption of the EPR Fee, depending on the characteristics of the following sectors concerned:

• Fruit and vegetable sector
• Chemical sector
• Distribution sector

In addition, agreements have been entered into with several trade associations representing net exporting companies.