FAQ Conai - Conai

CONAI EPR Fee

Yes, since January 2023 a dedicated tool called “Codice Imballaggio” has been available to users (portal www.codiceimballaggio-conai.org), which, through a series of questions, helps the user to identify, for the main types of packaging, the item and the declaration code, the possible contribution band, and the corresponding unit value of the Environmental Contribution in force at the time of consultation. Through the specific “archiving” function, it is also possible to obtain the same information for previous years, up to 2018. It is also possible to proceed with the creation of a “.pdf” file containing the results of the searches carried out.

No, packaging produced and transferred abroad must not be made subject to the CONAI EPR Fee, since the “first transfer” does not arise. Accordingly, no wording relating to the CONAI EPR Fee must be shown on invoices for exported packaging issued by the producer/trader to foreign customers.

The CONAI EPR Fee shown on invoices relating to “first transfers” of packaging is to be treated as an ancillary supply pursuant to Articles 12 and 13 of Presidential Decree 633/1972. As such, it falls within the scope of VAT and therefore the portion charged (net of the exemption percentage notified by customers through Form 6.5/Suppliers) is subject to the same VAT rate as the packaging or packaging material forming the subject of the “first transfer”.

The amounts resulting from the EPR Fee declaration must be paid after receipt of the relevant invoices issued by CONAI. In the case of a declaration under the ordinary procedure, CONAI sends invoices on behalf of each of the seven Packaging Material Consortia, in relation to the respective materials, whereas, in the case of a declaration under the simplified procedure, CONAI sends a single overall invoice. Payments must be made to the relevant bank accounts indicated on the invoice itself, which also states the relevant deadline.

Yes, when invoicing its goods, the packaging user must build the CONAI EPR Fee into the sale price and must show on the invoice the portion of the fee relating to the packaging. Alternatively, the invoice may include the wording “CONAI EPR Fee paid”, thereby informing the customer that the sale price of the goods also includes the CONAI EPR Fee. The user must not, however, either declare or pay that fee to CONAI, since it has already paid it to its suppliers when purchasing the empty packaging.

When invoicing its goods, the packaging user must build the CONAI EPR Fee into the sale price and must show on the invoice the portion of the fee relating to the packaging. Alternatively, the invoice may include the wording “CONAI EPR Fee paid”, thereby informing the customer that the sale price of the goods also includes the CONAI EPR Fee.

By using this wording, your suppliers certify that the packaging used for the goods invoiced has already been subject to the CONAI EPR Fee at an earlier stage.

If, on the other hand, you purchase empty packaging, the CONAI EPR Fee must instead be shown separately on the invoice from the sale price by the supplier itself, in the manner indicated in Chapter 4 of the CONAI Guide (available in the Documents Download section of www.conai.org).

Information about the new simplified EPR Fee declaration method is set out in the “Special Section” of the CONAI Guide 2023 (available in the Documents Download section of www.conai.org), which includes a description of the service and the format of the request for voluntary participation in the new declaration method (with annexes concerning the operational aspects, deadlines, relationships and commitments between the parties involved, as well as the privacy notice on the processing of personal data).

Scrap reintroduced by the company into the production cycle and/or transferred on a temporary basis (e.g. on a contract processing basis) to third-party companies (in both cases for the production of packaging) does not fall within the scope of the exemption from the EPR Fee.

In other cases, however, the scrap does fall within the scope of the exemption from the EPR Fee (for example, if it is transferred definitively or transferred temporarily in order to be transformed into items that do not constitute packaging).

Yes. The exemption from the EPR Fee provided for in the above Circular covers scrap generated during the following stages, provided that they form part of the packaging self-production process:

machine start-up;
machine stoppage (stop & go);
reel changes;
colour changes.

No. Raw materials/semi-finished products for packaging that have been made subject to the EPR Fee and are dispersed, stolen, destroyed by fire or lost through other accidental events do not fall within the cases of exemption from the EPR Fee provided for in the CONAI Circular of 21 October 2021, because they are not waste/scrap generated during a packaging self-production process.

No. The above Circular does not allow exemption from the EPR Fee for scrap generated during the product packaging stages, including scrap obtained during film sealing and cutting of plastic film. This applies regardless of whether the film was purchased as such or self-produced. In the latter case, the exemption from the EPR Fee nevertheless remains valid for scrap generated during the self-production process of the film, and therefore before the goods are packaged.

Under the CONAI Circular of 21 October 2021, the exemption from the EPR Fee is reserved exclusively for scrap deriving from the self-production/processing of packaging that is managed as waste to be disposed of or recovered/recycled, or transferred (by the self-producer) as by-products to companies in order to be transformed into products that do not constitute packaging. It follows that the exemption does not apply to:

scrap generated after the self-production process of the packaging itself (such as, for example, that obtained during the packaging of goods);
scrap reintroduced into the production cycle to be transformed into packaging at the same company or at other companies.

The exemption from the EPR Fee provided for in the above Circular covers scrap (sawdust and/or pieces of wood, regardless of size) generated during the self-production of wooden crates and pallets. This is provided that such scrap is not reintroduced into the self-production cycle of wooden packaging by the same company or through specifically appointed third parties.

The exemption from the EPR Fee provided for in the above Circular covers scrap generated throughout the entire self-production process of steel cans and tins. This is provided that such scrap is not reintroduced into the self-production cycle of steel packaging by the same company or through specifically appointed third parties. By contrast, scrap generated after the self-production process of the same packaging is excluded (such as, for example, that generated during the filling of the cans/tins, regardless of whether they were self-produced or purchased already finished).

By way of illustration, and without limitation, a number of examples are set out below, separately for trays/containers (example 1) and bottles, preforms and caps (example 2).

Example 1: Scrap from self-production of plastic trays (and/or containers)

The case in question mainly concerns companies operating in the production of food products packaged in plastic trays sealed with “top film” (also made of plastic). The trays may either be purchased as finished products (already thermoformed) or self-produced by the companies through the thermoforming of film reels (“bottom film”). According to current production technologies, once the trays have been filled with the product (e.g. sliced cold cuts), they are sealed (by heat sealing) with the “top film”. The next stage involves cutting/trimming the tray, with the perimeter section being discarded. The waste consists mainly of heat-sealed “bottom film” and “top film” (“skeleton” or perimeter trim waste) in the case of a self-produced tray, whereas it relates only to the “top film” in the case of a tray purchased already thermoformed.

For the purposes of the CONAI Circular of 21 October 2021, scrap relating to the trays (bottom film) falls within the scope of the exemption from the EPR Fee (including the portion generated during the packaging of the goods), since this still forms part of the tray self-production process. However, the following are excluded from the exemption:

top film scrap, because it is generated during the packaging of the goods, regardless of whether the tray to which it is applied (the top film) is self-produced or purchased already formed;
scrap from trays purchased already formed, because it is not related to the self-production process.

Example 2: Scrap from self-production of preforms, bottles and flasks, and any related caps

This mainly concerns companies operating in the production of mineral waters/beverages in plastic bottles, or detergent products in plastic flasks. Depending on the plastic material (PET or HDPE), the following cases may arise in relation to scrap resulting from the self-production of packaging.

From PET granules: self-production of the preforms, blowing of the preforms to produce the bottles/flasks, and subsequent filling.

The exemption from the EPR Fee provided for in the above Circular covers scrap generated throughout the entire self-production process of PET preforms (starting from the granules and typically relating to sprues and purge material, or to self-produced but non-compliant preforms), provided that such scrap is not reintroduced into the production cycle. By contrast, the exemption under the above Circular does not cover scrap generated after the preform self-production process and therefore also that generated during blowing and subsequent filling.

From HDPE granules: self-production of bottles/flasks (without going through the preform stage) and filling.

The exemption from the EPR Fee provided for in the above Circular covers scrap generated throughout the entire self-production process of HDPE bottles/flasks (starting from the granules and typically relating to sprues, purge material and self-produced but non-compliant detergent bottles), again provided that such scrap is not reintroduced into the production cycle. By contrast, the exemption under the above Circular does not cover HDPE bottles/flasks discarded during filling or during any printing/label application stage, if this takes place before filling, nor any other packaging waste generated during filling.

The same principles apply to caps (usually made of PE and/or PP), the scrap from which is covered within the scope of the exemption from the EPR Fee only if generated exclusively during the self-production process and not during subsequent stages.

Yes, a company making purchases from abroad for the first time is required to submit a quarterly EPR Fee declaration to CONAI, regardless of the value of the import and the quantities of packaging involved. However, there is a minimum EPR Fee threshold below which CONAI does not issue an invoice, and the company is exempt from the declaration obligation in subsequent years until that threshold is exceeded (Chapter 5 of the CONAI Guide – available in the Documents Download section of www.conai.org).

The packaging materials of goods of foreign origin (EU and non-EU) placed on the market in Italy must be made subject to the CONAI EPR Fee.

Accordingly, an importer of packaged goods is required to declare the EPR Fee using the relevant forms (provided for each of the materials falling within the scope of the CONAI EPR Organisation) and to pay the EPR Fee on receipt of the resulting invoices issued by CONAI. Simplified EPR Fee declaration formulas are also available where determining the weight and/or the packaging materials is objectively difficult (Chapter 5 of the CONAI Guide – available in the Documents Download section of www.conai.org).

Exported packaging falls outside CONAI’s remit and is therefore exempt from the EPR Fee. CONAI has established various EPR Fee exemption procedures (subject to strict deadlines), described in detail in Chapter 7 of the CONAI Guide (available in the Documents Download section of www.conai.org), including, by way of example and without limitation:

one, based on actual data (“ex-post”), which, through Form 6.6, allows a request to be made to CONAI for a refund of the EPR Fee paid on packaging subsequently exported;
one, based on forecast data (“ex-ante”), which, through Form 6.5, allows a percentage exemption from the EPR Fee on purchases/imports of packaging to be claimed, with a year-end adjustment based on actual exports.

Yes, there are various cases. Chapter 8, “Special Cases”, of the CONAI Guide (available in the Documents Download section of www.conai.org) sets out the cases and the relevant information for managing the EPR Fee, including primary packaging for medical devices and/or pharmaceutical products, cork packaging, disposable tableware, and reusable packaging employed in a production cycle or commercial network.

You must pay the EPR Fee only after receiving the invoice issued by CONAI based on the declaration submitted. The payment deadline is shown on the invoice.

That is correct. CONAI issues invoices in the name and on behalf of the Packaging Material Consortia in relation to the respective materials (Chapter 6 of the CONAI Guide – available in the Documents Download section of www.conai.org).

Yes, if it relates to packaging made of one or more materials falling within the scope of the CONAI EPR Organisation. The CONAI EPR Fee applies at a particular point in the life cycle of packaging, known as the “first transfer”, i.e. the transfer, even temporarily and for whatever reason, within Italy, of the finished packaging by the last producer or trader of empty packaging to the first user, other than a trader of empty packaging.

The EPR Fee must also be shown on invoices relating to transfers of packaging after the “first transfer” (Chapter 4 of the CONAI Guide – available in the Documents Download section of www.conai.org).

For each packaging material, the CONAI EPR Organisation/Packaging Material Consortia system has established an EPR Fee, which provides the funding mechanism for sharing the costs of separate collection, recovery and recycling of packaging between producers and users. Those required to pay the EPR Fee are the parties that first place the finished packaging on the market in Italy, therefore, in general, producers, importers of empty packaging, importers of packaged goods and, from 1 January 2019, traders of empty packaging as well. These are joined by producers/importers of packaging material that supply self-producers, and by self-producers themselves when they import the raw materials used to package their own goods. “Self-producers” are parties that purchase raw materials and packaging materials in order to manufacture/repair packaging used to package their own products (other than the packaging itself).

Definition of “Packaging”

According to the legislation currently in force, packaging is: a product, made of materials of any nature, used to contain certain goods, from raw materials to finished products, to protect them, to allow their handling and delivery from the producer to the consumer or user, and to ensure their presentation, as well as disposable items used for the same purpose. The same legislation also provides for certain clarifications and definitions such as: primary, secondary, tertiary, reusable packaging, etc. The CONAI EPR Organisation covers packaging made of steel, aluminium, paper, wood, plastic, biodegradable and compostable plastic, and glass.

SUP Directive

Tethered caps are plastic caps that remain attached to plastic beverage containers and to cartons for liquids (CPL), preventing their dispersion into the environment and thereby promoting their sorting and recyclability, in accordance with Legislative Decree 196 of 8 November 2021 implementing Directive (EU) 2019/904 of 5 June 2019 (SUP Directive).

In order to verify that the tethered cap in fact remains attached to the neck of the bottle, reference must be made to technical standard UNI EN 17665:2023, which provides guidance on test methods and requirements for demonstrating that plastic caps and lids remain attached to beverage containers.

Cups and glasses made wholly or partly (> 10% of the total weight) of expanded polystyrene cannot be placed on the market, whereas, for other cups and glasses made wholly or partly (>10% of the total weight) of plastic, the consumption reduction measure applies, together with the marking obligations under Commission Implementing Regulation (EU) 2020/2151 of 17 December 2020.

The packaging is used not only for serving the product – consumed directly from the packaging – but also for transporting it to the point of sale, which is why it has a closure. Given its characteristics and the way it is used, it is classified as a food container.

Yes, liquid food supplements are subject to the obligation to be fitted with a tethered cap, since they cannot be regarded as “food for special medical purposes” within the meaning of Article 2, point (g) of Regulation (EU) 609/2013 and therefore cannot benefit from the exclusion provided for in Part C of the Annex to Legislative Decree 196/2021 for “beverage containers intended for and used for food for special medical purposes as defined in Article 2, point (g) of Regulation (EU) No 609/2013 of the European Parliament and of the Council that are in liquid form”.

“Infant formula” and “follow-on formula” are foods and not beverages, according to the legal definition and in view of the chemical/commercial characteristics and purpose of the products. Packaging for these foods therefore does not fall within the scope of Directive (EU) 2019/904 (the SUP Directive), and is not subject to the obligation to use tethered caps.

No, these guidelines describe the provisions in force in Italy, laid down by Legislative Decree 196 of 8 November 2021 implementing Directive (EU) 2019/904 of 5 June 2019. The Directive may have been implemented differently in other Member States; therefore, in the event of exports, it is advisable to check the provisions in force in each country.

Yes, the legislation makes no reference to exclusions linked to the shelf-life performance of the products contained. Therefore, if such packaging falls within one of the cases described in this document, regardless of any further performance or functions it may fulfil during its useful life, it will be subject to the provisions of the legislation.

Yes, stocks of these products may be marketed until they are exhausted, provided that it can be shown that they were placed on the market before 14 January 2022: no deadline is laid down by which such stocks must be exhausted.

No, these caps are not subject to those requirements because they are not made of plastic.

No, these bottles do not fall within the scope of the Decree.

No, glass or metal beverage bottles with plastic caps and lids do not fall within the scope of the Decree.

No, the caps and closures of cups and glasses are not subject to the marking obligation: only the cups and glasses are.

Yes, cups and glasses made wholly or partly (> 10% of the total weight) of biodegradable and compostable plastic are subject to the marking requirements under Commission Implementing Regulation (EU) 2020/2151 of 17 December 2020. However, in order to avoid misleading consumers into placing them in the plastic separate collection, we recommend that cups and glasses made of compostable bioplastic (which should instead be disposed of in the organic waste separate collection) should carry all the information necessary for their correct disposal.

Plates made only partly of bioplastic (or plastic), where that quantity is less than 10% of the total weight of the plate, are not considered single-use plastic items and may therefore always be placed on the market. If, however, the plate is made wholly or partly of bioplastic, where that quantity exceeds 10% of the total weight, the plate may be placed on the market only if it is:

biodegradable and compostable in accordance with UNI EN 13432, and
made of renewable raw material equal to or greater than 40%, and, from 1 January 2024, at least 60%, and only in the following cases:

a) where it is not possible to use reusable alternatives to single-use plastic packaging;

b) where such packaging is used in controlled circuits that send waste to the public service through separate collection, such as canteens and healthcare or social care facilities and residences;

c) where any alternatives do not guarantee adequate performance in terms of hygiene and safety, taking account of the specific circumstances in which they are used;

d) in view of the particular type of food or drink;

e) in circumstances where there are large numbers of people present;

f) where the environmental impact of the reusable packaging is worse than that of biodegradable and compostable single-use alternatives, based on a life cycle analysis by the producer.

Yes, a cup made in this way is considered a single-use plastic item and is therefore subject to the marking obligation under Commission Implementing Regulation (EU) 2020/2151 of 17 December 2020.

Yes, a plate made in this way is considered a single-use plastic item and cannot be placed on the market.

Yes, a cup made in this way is considered a single-use plastic item and is therefore subject to the marking obligation under Commission Implementing Regulation (EU) 2020/2151 of 17 December 2020.

No, oxo-degradable plastic packaging 12 is included within the scope of the Decree.

By 3 July 2024, containers for liquids had to be designed so that their closures remain attached to the container itself throughout its useful life. At the same time, the environmental labelling requirement, under which all components that can be separated by hand must be correctly labelled, has been in force since 1 January 2023.

As companies gradually adapt to the new design requirements, it may happen that some beverage containers designed with closures that cannot be separated by hand still carry label information relating to the cap or, conversely, that containers with separable caps carry the new labelling indicating information relating only to the container. This issue is particularly critical for paper‑based beverage containers, where the disposal instructions for the cap and for the container often follow two different collection streams.

However, it should be noted that the legislation has also provided for the possibility of placement on the national market for stocks of beverage containers that do not comply with the requirements even after 3 July 2024, provided it can be demonstrated that they were placed on the market before the obligation actually took effect. The provision made by the legislator for a stock‑exhaustion period is consistent with the environmental objective of this legislation; this presupposes that, in general, during the transition period it is plausible and possible for companies to continue marketing packaging that does not comply, wholly or in part, with the new requirements.

For the labelling obligation too, for the same reason set out above, the legislator has provided for the possibility of marketing, until stocks are exhausted, packaging that did not comply with the requirements on 1 January 2023. The labelling requirement, besides being a legal obligation, is also a key packaging design requirement and therefore contributes to the overall and complex set of characteristics that identify packaging designed for specific purposes.

This should be borne in mind because, both where the container has an attached cap but is labelled with disposal instructions for the container and the cap, and where the container has a cap that is not yet attached and disposal instructions that refer only to the container itself and not to the cap, these may be regarded as containers that do not meet the design requirements under Legislative Decree 196 of 8 November 2021, but whose stocks may still be marketed until exhausted even after 3 July 2024. It is therefore assumed, also taking into account the environmental significance of the two legal obligations, that such stocks may also be marketed in periods before 3 July 2024, and in particular during the transition phases in which the technical design characteristics of the container may not coincide with the informational ones.

Having clarified that beverage containers not complying with the design and information requirements may be marketed, for limited periods of time and in exceptional transition phases, it is strongly recommended to effectively inform the end consumer, through the website or information campaigns, of the transition that is underway, as well as of the correct disposal instructions for beverage containers and their closures in the two possible cases.

Modulated EPR Fee for paper packaging

This is the first time that the CONAI EPR Organisation has encouraged companies to indicate disposal of their waste as unseparated waste.

It was not an easy decision, but it was taken in the light of two considerations.

The first is that, in paper mills, type D packaging would cause more environmental harm than good, because, once separated out, the large quantities of waste it generates could only end up in landfill.

The second is that, at present, this packaging is estimated to represent very small quantities, equal to around 2% of all polylaminated packaging.

“Paper‑based polylaminated packaging” (or packaging laminated with other materials) means packaging that is structurally made of two or more materials that cannot be separated by hand, where paper is the predominant material by weight and where the weight of the non‑cellulosic material is in any case more than 5% of the total weight of the packaging.

More specifically, Legislative Decree 116 of 3 September 2020, which implemented the new European directives, introduced the term “composite packaging”: packaging made of two or more layers of different materials that cannot be separated by hand and form a single unit, consisting of an inner receptacle and an outer enclosure, and that is filled, stored, transported and emptied as such.

The CONAI Board of Directors decided that fee modulation would also be extended to other paper‑based composite packaging other than containers for liquids from 1 January 2022.

Paper-based composite packaging, other than packaging for liquids, was divided into four types according to the weight of the paper component in the total packaging weight.

The first two types, A and B, with a paper component greater than or equal to 90% and 80% respectively, pay only the paper EPR Fee. No supplement applies.

The third type, C, covers packaging where the paper component is greater than or equal to 60% and less than 80%. The recycling operations of this packaging are complex and costly: out of 100 kg of packaging, more than 60 kg becomes waste that cannot be recycled with current technologies. Packaging in this band pays an EPR Fee Supplement of €110/tonne from 1 January 2022.

The fourth type, D, covers composite packaging where the paper component is less than 60% or in any case is not stated. Such a percentage compromises the recyclability of the packaging, eliminating it, with obvious consequences in terms of environmental impact. In the recycling process, in fact, 100 kg of this packaging produces more than 85 kg of dry waste and almost 150 kg of wet waste to be disposed of in landfill, after consuming water and electricity.

For this packaging, the EPR Fee Supplement is therefore €240/tonne. Band D also includes packaging whose paper component is not stated.

This means that it is packaging that cannot be recycled with paper and cardboard: companies that produce and use it are therefore encouraged to indicate on the label that it should be disposed of in the unseparated waste collection, in order to minimise the environmental impact associated with managing its end of life.

The fee modulation scheme for paper packaging was launched in January 2019, applying exclusively to paper-based polylaminated packaging suitable for containing liquids (CPL).

In October 2020 the trial phase began, with new declaration forms for other types of paper‑based polylaminated packaging, other than CPL, in order to identify the types and quantities of packaging subject to fee modulation.

In January 2022, fee modulation was extended to other paper‑based composite packaging other than liquid containers.

The fee modulation scheme is aimed at developing collection and at funding activities and investments for sorting and recycling operations, through the application of an additional EPR Fee (EPR Fee Supplement), amounting to €20/t from 1 January 2019, for paper-based polylaminated packaging suitable for containing liquids (CPL).

CONAI then extended this fee modulation to other types of composite (or polylaminated) packaging mainly consisting of paper or cardboard (other than CPL). In this case too, the application of an EPR Fee Supplement was introduced – becoming fully operational from 1 January 2022 – in order to correlate the EPR Fee with their actual recyclability and environmental impacts, as well as to the emerging costs associated with managing their end of life.

For the trial phase (which began in October 2020 and ended in December 2021), the declaration forms were updated (Form 6.1 Empty Paper Packaging, Form 6.2 Imports of Filled Packaging, and Form 6.10 Import/Export Compensation), with the EPR Fee remaining unchanged (that is, €55/t until 30 June 2021 and €25/t from 1 July 2021), but with a clear distinction between the types of packaging subject to fee modulation.

Accordingly, the following categories of paper‑based polylaminated packaging, other than CPL, were introduced according to the weight percentage of the cellulosic component present:

Type A polylaminated packaging (paper component >= 90% and < 95%);
Type B polylaminated packaging (paper component >= 80% and < 90%);
Type C polylaminated packaging (paper component >= 60% and < 80%);
Type D polylaminated packaging (paper component < 60%);
Polylaminated packaging with no stated paper component.

During this phase, companies (directly or through their trade associations) were therefore able to request support from CONAI, organise themselves to collect the necessary information, adapt their IT systems and report any critical issues.

If the packaging has been subjected to a test other than UNI 11743, but is able to provide parameters compatible with those used by the Aticelca assessment system, including the assessment of adhesive particles (as in the case of the CEPI complete recyclability test version 2 and subsequent versions), and the test has been carried out by a laboratory qualified by Aticelca, it is possible to ask the laboratory to issue a new test report in which, using the measured data, the recyclability is assessed according to the Aticelca 501 assessment system.

The recyclability assessments carried out using the Aticelca 501 recyclability assessment system from the 2017 version (Aticelca 501:2017) have no expiry date, provided that the packaging maintains the characteristics of the analysed sample. It is therefore not necessary to repeat the test over the years or following revisions of the Aticelca 501 assessment system as long as the packaging retains its technical characteristics.

Yes. In the event that it is not possible to carry out all the stages of the test method in accordance with the UNI 11743:2019 standard or it is not possible to determine one or more measurement parameters due to the nature and/or characteristics of the sample of material or product, the laboratory will report this circumstance in the assessment report. As it is not possible to have all the elements necessary to carry out a complete evaluation including all the required parameters, the assessment report will not express the “general assessment of recyclability” based on levels A+, A, B, C as provided for in chapter 7 point (c) of the Aticelca 501 assessment system.

Examples of these eventualities are:

a) resistance to pulping prevents the pulper from functioning or there is a risk of damaging the equipment;

b) presence of flakes or dense foams prevents the transfer of the mixture to the subsequent phases;

c) presence of metal particles or wet-strength resins that distort the reading of the macrostickies.

In these cases where it is not possible to carry out an assessment, the fee band to which the packaging belongs will be assigned based on the criterion of the weight of the paper component as a proportion of the total weight of the packaging, applying the relevant discounts for that band (B1 and C1), thus rewarding companies that have submitted their packaging for recyclability testing.

Example: packaging with a paper component weight of between 80%–90% subjected to laboratory testing with a “non-evaluable” recyclability result will fall under fee band B1. Packaging with a paper component weight of between 60%–80% with a “non-evaluable” recyclability result will fall under fee band C1.

It is possible to subject paper packaging to a recyclability test according to the Aticelca 501 system without a component that has been designed to be separated by hand by the consumer (for example a window, a handle, a peelable layer, etc.). From 1 January 2024, it is mandatory to prove that this component can actually be separated by hand by the consumer with sufficient ease by carrying out the test according to the Aticelca 502 method. A component is considered separable if it achieves at least Level C according to the Aticelca 502 method.

In the absence of such test, verification of recyclability according to the Aticelca 501 system must be conducted on the entire packaging, including the component designed to be separable. This obligation does not apply to any components that must necessarily be removed by the consumer in order to use the material or product or, in the case of packaging, to access the product it contains.

This obligation also excludes any components that are not physically attached to the paper-based material or product. “Physically attached” means parts that are glued, embedded, stapled, clipped, etc.

Aticelca 501 is a method for assessing the recyclability of materials and products made mainly of cellulose based on laboratory tests conducted according to the UNI 11743:2019 standard, and it guarantees a more accurate and scientific definition of the recyclability of composite packaging, compared to the mere criterion of the percentage by weight of the paper component present in the packaging.

The values of the fee bands for paper packaging in force over the years, together with further information on fee modulation for such packaging, are available on the dedicated “Modulated EPR Fee for paper packaging” page of the website.

From 1 July 2025, there are eight fee bands for cellulose-based packaging.

The fee band for composite packaging made predominantly from cellulose, other than CPL, is determined according to two alternative criteria:

based on the weight of the paper component as a proportion of the total weight of the NON-CERTIFIED packaging;
based on the result of the Aticelca 501 assessment of the packaging (CERTIFIED), in which specific bands are identified offering significant discounts.

The declaration forms prepared for the trial phase (from October 2020 to December 2021) included a specific line, “Polylaminated packaging with no stated paper component”, in which quantities of polylaminated packaging could be indicated where the paper component was not available/known at the time of completing the declaration.

With the entry into force of the new EPR Fee Supplement values from 1 January 2022, quantities of polylaminated packaging (composite packaging) with no stated paper component are treated in the same way as type D packaging with a paper component of <60%, that is, those subject to the highest EPR Fee Supplement.

To calculate the percentage of the cellulosic component present in paper‑based polylaminated packaging, the weight of that component must be considered in relation to the total weight of the packaging itself (including any printing inks, adhesives, etc.). Where paper‑based polylaminated packaging is made up of more than two materials, the percentage of the paper component may be less than 50% of the total weight of the packaging (for example, packaging made up of: 40% paper component, 30% plastic component, and 30% aluminium component).

Since January 2019, only paper-based composite or polylaminated packaging suitable for containing liquids (CPL) has been affected.

This refers specifically to primary paper-based packaging, laminated with plastic and, where applicable, aluminium. This category includes, by way of example, beverage cartons (milk, fruit juice, etc.) and similar types of packaging for other food products (sauces, tomato purée, pulses, etc.). Catering packaging items (plates, cups, trays with their lids) are excluded.

Since January 2022, other types of paper-based polylaminated packaging, apart from CPL, have also been subject to fee modulation, divided into the following types according to the weight of the paper component as a proportion of the total weight of the packaging:

type C covers packaging where the paper component is greater than or equal to 60% and less than 80%;
type D is composite packaging where the paper component is less than 60%. Band D also includes packaging whose paper component is not stated.

The first two types, A and B, with a paper component greater than or equal to 90% and 80% respectively, pay the paper EPR Fee only and no EPR Fee Supplement applies to them.

For the paper supply chain, the fee modulation scheme was initially focused, through its application to paper-based composite or polylaminated packaging suitable for containing liquids, on improving the effectiveness of the recovery process for cellulose-based packaging that is more difficult to recycle, by consolidating and developing collection and sorting activities so as to obtain a homogeneous waste stream to be sent to a dedicated recycling stage.

Packaging platforms

The CONAI–Packaging Material Consortia system offers the possibility of entering into direct agreements with the Packaging Material Consortia, both in relation to the collections covered by the ANCI–CONAI Framework Agreement and within the Secondary and Tertiary Platforms system (the latter limited to packaging waste made of paper, plastic, steel or wood). For administrative, technical and financial details of these opportunities, you should contact the Packaging Material Consortia directly:

RICREA – National Consortium for the Recycling and Recovery of Steel Packaging – Via G.B. Pirelli 27, 20124 Milan, tel. +39 02 66712717, website: www.consorzioricrea.org
CiAl – Aluminium Packaging Consortium, Via P. Litta, 5 – 20122 Milan, tel. +39 02 540291, website: www.cial.it
Comieco – National Consortium for the Recovery and Recycling of Cellulose-based Packaging, Via P. Litta 5 – 20122 Milan, tel. +39 02 550241, website: www.comieco.org
Rilegno – National Consortium for the Recovery and Recycling of Wood Packaging, Via Luigi Negrelli 24/A, Cesenatico (FO), tel. +39 0547 672946, website: www.rilegno.org
Corepla – National Consortium for the Recovery of Plastic Packaging, Via del Vecchio Politecnico, 3 – 20121 Milan, tel. +39 02 760541, website: www.corepla.it
CoReVe – Glass Recovery Consortium, Piazza G.D. Bande Nere, 9 – 20146 Milan, tel. +39 02 48012961, website: www.coreve.it

An up-to-date list of affiliated platforms where secondary and tertiary packaging waste made of wood, paper, steel and plastic can be delivered is available in the “Businesses” section of the website, under “Waste delivery platforms”. Alternatively, you can contact the CONAI offices (tel. +39 02 540441) or the Packaging Material Consortia directly:

Comieco – National Consortium for the Recovery and Recycling of Cellulose-based Packaging, Via P. Litta, 5 – 20122 Milan, tel. +39 02 550241
Rilegno – National Consortium for the Recovery and Recycling of Wood Packaging, Via Luigi Negrelli 24/A, Cesenatico (FO), tel. +39 0547 672946

RICREA – National Consortium for the Recycling and Recovery of Steel Packaging, Via G.B. Pirelli, 27 – 20124 Milan, tel. +39 02 66712717

Corepla – National Consortium for the Recovery of Plastic Packaging, Via del Vecchio Politecnico, 3 – 20121 Milan, tel. +39 02 760541

Absolutely not. Delivering secondary and tertiary packaging waste to platforms affiliated with the Packaging Material Consortia does not incur any payment. This applies where the waste meets the required criteria (limits on the presence of foreign fractions, packaging containing hazardous substances or contaminated by such substances, etc.).

EPR Organisation Member companies can dispose of their secondary and tertiary packaging waste made of wood, paper, steel and plastic, destined for recycling, free of charge at a network of platforms affiliated with the Packaging Material Consortia. Lists of these platforms across the country are available on the CONAI website and on the websites of the relevant Packaging Material Consortia (RICREA, Corepla, Rilegno and Comieco).

The CONAI EPR Organisation and the Packaging Material Consortia have organised a nationwide network of platforms where companies can dispose of secondary and tertiary packaging waste made of wood, paper, steel and plastic free of charge, provided that it meets the basic compliance requirements established for each material (see the FAQs below).

Article 221 provides for a system for the collection and recovery of packaging waste that is not delivered to the public collection service. Companies using packaging are required to deliver secondary and tertiary packaging waste to collection points organised by producers and agreed with them. The CONAI EPR Organisation and the Packaging Material Consortia have put in place a system to meet these obligations by organising a network of platforms across Italy, where companies can dispose of secondary and tertiary packaging waste made of wood, paper, steel and plastic free of charge.

Delivery of packaging waste to platforms affiliated with the Packaging Material Consortia is voluntary. Adoption of this system must not lead to distortions or abnormal pressure on the market for the recovery and recycling of recoverable materials. It is simply an additional option available to companies that are unable to find a recycling destination for their packaging waste. Under this system, producers of packaging bear the costs of receiving and recovering the waste, while users bear the costs of collecting and transporting it. In this way, both parties fulfil the obligations imposed on them by Article 221 of Legislative Decree 152/2006.

ANCI-CONAI call for Local Communication projects

Yes, funding will be disbursed by CONAI only after the issue of an invoice plus VAT, in accordance with the instructions contained in the authorisation to invoice that will be provided by CONAI.

In such cases, it is possible to use, where available from the Region, the Government Authority for the waste management service or the Province, the figure for equivalent population (e.g. the Liguria Region calculates the equivalent population for each municipality each year based on the number of people present over the previous year).

They are not cumulative. Depending on the project, only the main activity is taken into account for scoring purposes.

Both requirements must be met: there must therefore be a grouping of at least five municipalities, and the total population involved must exceed 50,000 or 100,000 inhabitants (to obtain 5 or 8 points respectively).

The figure of 5,000 inhabitants is the minimum population that must be covered, regardless of whether this concerns a single municipality or several associated municipalities.

Applicants to the Call for Local Communication Projects must guarantee coverage of at least 5% of the costs of the communication project. This coverage may also be obtained through other sources of funding (e.g. regional or EU funds), provided that these are not additional CONAI funds.

The creation or updating of websites or web pages in support of communication activities does not fall within the category of innovative technological tools. This category includes, for example, the development of apps for users of the collection service, awareness-raising campaigns promoted through social media, or the creation of blogs dedicated to the launch of the new collection system.

Points are awarded where the change in the waste collection service involves a transition to light multi‑material collection, single-material collection for paper/cardboard and for glass, or where there is a transition to a pay‑as‑you‑throw system.

Additional points are awarded where municipalities are located within Mountain Communities or Small Islands, or where the area has been affected by natural disasters or particularly serious catastrophic events (e.g. earthquakes).

A specific authorisation from the municipality or group of municipalities is required in order to participate in the Call for Local Communication Projects.

Service managers may submit an application provided that it is accompanied by a specific declaration from the municipality or from the lead municipality of a group of municipalities, granting authorisation to submit the application for the Call for Local Communication Projects on behalf of the municipality/municipalities. The authorisation must formally confirm full agreement with the communication project submitted.

Modulated EPR Fee for plastic packaging

The prevailing economic situation led to an increase in the value of the EPR Fee for seven fee bands (out of nine) from 1 April 2024, as shown in the following table:

Fee bands	EPR Fee in force from January 2024 (€/t)	EPR Fee in force from April 2024 (€/t)
A1.1	20.00	24.00
A1.2	90.00	90.00
A2	220.00	220.00
B1.1	20.00	224.00
B1.2	20.00	233.00
B2.1	350.00	441.00
B2.2	477.00	589.00
B2.3	555.00	650.00
C	560.00	655.00

Starting from 1 April 2024, some types of packaging also changed band. Specifically:

XPS trays moved from Band C to Band B2.3, thanks to the development of an experimental recycling chain promoted in recent years;
rigid PP packaging with covering labels in any polymer, regardless of whether or not they have perforations/punching, moved from Band B2.2 to Band B2.1, as a result of improved sorting processes;
opaque PET bottles, jars and flasks and similar containers and/or those with a non‑punched covering label, as well as their related preforms, moved from Band B2.3 to Band B2.2, thanks to consolidation of the recycling chain for these items.

For further information, please refer to the dedicated “Modulated EPR Fee for plastic packaging” page on the CONAI website.

From 1 January 2023, plastic packaging has been classified into nine bands with different EPR Fee values, instead of the five bands used in 2022, continuing the dual commitment to link the value of the EPR Fee ever more closely to: (i) actual recyclability and the destination circuit, and (ii) the chain deficit, i.e. the relationship between the costs and revenues of collection, sorting and recycling activities.

Band B1 remains dedicated to packaging with an effective and established industrial sorting and recycling chain, mainly from the Household circuit, in line with the approach already in place.

For plastic caps compliant with the SUP Directive, which are therefore designed to remain attached to plastic beverage containers up to 3 litres, the move to Band B1 from Band B2 was made subject to the entry into force of the EN technical standard (in the process of being finalised).

The introduction, at first application, of the economic criterion led to the reduction of the EPR Fee for packaging in this band from €208/t to €149/t.

Band B2 encompasses all other sortable/recyclable packaging from the Household circuit and/or the Commerce & Industry circuit. In other words, Band B2 includes packaging with different levels of ease of sorting and recyclability, packaging that has only recently become recyclable and been introduced onto the market, packaging whose recycling is costly and/or from which lower‑quality sorted waste is obtained, and packaging with recycling chains in the process of consolidation and development.

Band B2 also permits expanded polyethylene packaging with a thickness greater than 2 millimetres (previously included in Band C), and barrier layers made of EVOH, up to a limit of 5% of the total weight of the packaging.

The EPR Fee for this band was also reduced, from €560/t to €520/t.

Yes, Band A was split into A1 and A2. Band A1 continues to include all packaging previously included in Band A, excluding flexible polyethylene packaging, which moved to Band A2.

Band A1 therefore continues to include rigid and flexible packaging with an effective and established industrial sorting and recycling chain, managed mainly (and no longer exclusively) in Commerce & Industry circuits.

For this packaging, the EPR Fee fell from €150/t to €104/t.

The new development is Band A2, which includes flexible packaging with an effective and established industrial sorting and recycling chain, coming mainly from the Commerce & Industry circuit but increasingly present in municipal separate collection as well, and therefore with a greater chain deficit.

This band also permits flexible expanded polyethylene packaging with a thickness of 2 millimetres or less (previously included in Band B2).

As regards packaging falling within Band A2, there has been a continuous increase in the volumes present in municipal separate collection, with rising costs for consortium management. Accordingly, it was decided that the fee for this band would remain unchanged at €150/tonne until 30 June 2022, and then increase to €168/tonne from 1 July 2022, in line with the higher costs of sending it for recycling.

For further information, please complete the online form in the “Contact Us” section of our website, selecting “Modulated Fee” from the list of topics, or contact the toll-free number 800 33 77 99 (within Italy).

Assessments carried out by the CTPV have confirmed that, based on the available information, metallisation (of any kind) is a factor that has a negative impact on the recycling of packaging. Although these specific treatments applied to packaging make it possible to achieve better technical performance and improve the product’s appeal to the end consumer, they have a negative impact on the quality of the secondary raw materials that can be obtained from the recycling of flexible packaging. This is especially significant at a time when one of the obstacles to greater use of recycled plastic, as also reported by packaging producers themselves, is the poor quality of recycled plastics available on the market. Consequently, metallised packaging remains in Band C.

The Committee closely followed the work carried out at European level by Plastics Recyclers Europe (PRE), which adopts an approach similar to that of CONAI, namely considering the actual recycling that is possible with existing technologies based on selected homogeneous waste streams. As regards metallisation, whilst acknowledging PRE’s position, at the sorting stage there are currently no industrial technologies that make it possible to distinguish between metallised packaging produced using a non‑impactful technology (provided that the conditions specified in the PRE document are met) and packaging that does not meet those conditions. Since metallised packaging is not accepted by recyclers in the input material sent to plants, both types would be removed at the sorting stage. If, in future, sorting technologies are developed that make it possible to distinguish between metallised packaging produced using recyclable solutions and those produced using non‑recyclable solutions, or if companies were to convert fully to recyclable metallisation solutions so that it would no longer be necessary to remove this type of packaging at the sorting stage, the decision may be reviewed.

These specific treatments applied to packaging make it possible to achieve better technical performance, also ensuring the product’s shelf life and consequently reducing waste of the contents (especially where the packaging is intended to contain food products), but they compromise subsequent recycling.

However, at European level, a number of tests have been carried out by Plastics Recyclers Europe (PRE) on the compatibility of EVOH in the recycling stream for flexible PE packaging, and initial tolerance thresholds have been defined. Accordingly, barrier layers made of EVOH, but limited to 5% of the total weight of the packaging, are permitted in Bands B2.2 and B2.3.

Polylaminated packaging mainly consisting of plastic is subject to the EPR Fee for Band C because, at present, it does not meet the criteria for ease of sorting and recyclability and therefore is not included in the lists of packaging eligible for reduced fees.

Considering developments in the technological context of products and processes (sorting and recycling) and/or reports received from the sectors concerned, CONAI has established a specific Board Working Group, which has taken over the functions of the Standing Technical Assessment Committee (CTPV), and which may from time to time propose to the competent Board of Directors the reallocation of specific packaging types.

Through continuous and productive dialogue with the associations of producers and users, three Guiding Criteria for fee modulation were identified, linking the value of the EPR Fee to the environmental impact of the end‑of‑life/new‑life stages of plastic packaging, in accordance with the “polluter pays” principle:

ease of sorting;
recyclability;
the main destination circuit of the packaging when it becomes waste (“Household” or “Commerce & Industry”).

As early as September 2020, the CONAI Board of Directors had undertaken to review the criteria and logic of the modulated EPR Fee for plastic packaging for 2022. This commitment was made both in the light of developments at European level and with the aim of linking the values of the plastic EPR Fee ever more closely to recyclability and the destination circuit, but also to the chain deficit, i.e. the costs and revenues of collection, sorting and recycling activities.

Protective elements made of foamed material may fall within the following fee bands for plastic packaging (in force from 1 January 2023):

A2, if made of monopolymer expanded PE with a thickness of up to 2 mm;
B2.1, if made of monopolymer expanded PP with a thickness greater than 2 mm and provided that they meet the additional parameters and characteristics set out in the specific description included in the list of plastic packaging;
B2.2, if made of monopolymer expanded PE with a thickness greater than 2 mm, monopolymer expanded PP or multilayer expanded PE/PP (in all cases, with EVOH within the 5% limit), or if made of monopolymer expanded PS, provided that they meet the additional parameters and characteristics set out in the respective descriptions included in the list of plastic packaging;
C, if made of polymers other than those listed above (e.g. polyurethane) or laminated with other materials (e.g. glued to a sheet of cardboard).

To identify the fee band to be assigned to a specific packaging item, you can consult the “Packaging Code” and answer the questions in the questionnaire.

Yes. The changes concerning certain types of plastic caps, effective as of 1 July 2023, are as follows:

tethered plastic caps (*) for cartons for liquids (CPL) are reallocated from Band B2.2 (€477.00/t) to Band B1.1 (€20.00/t);
HDPE caps for bottles and flasks in band B1.1 or B1.2 are reallocated from Band B2.2 (€477.00/t) to Band B1.1 (€20.00/t);
PP caps if used for containers in Band B2.1 are reallocated from Band B2.2 (€477.00/t) to Band B2.1 (€350.00/t).

(*) Plastic caps that remain attached to cartons for liquids (CPL), preventing their dispersion into the environment and thereby promoting their sorting and recyclability, in accordance with Legislative Decree 196 of 8 November 2021 implementing Directive (EU) 2019/904 of 5 June 2019 (SUP Directive).

For further details, please refer to the Circular on the reallocation of fee bands for plastic caps 2023.

Yes. Thanks to CONAI’s commitment to link the value of the EPR Fee ever more closely not only to the actual recyclability of packaging, but also to the relationship between the costs and revenues of collection, sorting and recycling activities, a further segmentation of plastic packaging came into force from 1 January 2023. Specifically:

Band A1 was split into two: A1.1 and A1.2, to separate items for which Corepla makes a payment for regeneration and recycling activities (drums and IBC tanks, which fall under Band A1.2). For A1.2, the EPR Fee remains unchanged. However, for A1.1, it has decreased to €20/t;
Band A2 remains unchanged, and so does its EPR Fee (€150/t);
Band B1 was split into B1.1 and B1.2, with the aim of separating PET items (in B1.2) from HDPE items (which are in B1.1). For both bands, the EPR Fee remains €20/t;
The former Band B2 was split into three bands: rigid polypropylene containers fall within B2.1, so the EPR Fee falls from €410/t to €350/t; recyclable polyolefin‑based items move to Band B2.2, where the EPR Fee remains €410/t. Band B2.3 was created to accommodate packaging with experimental recycling chains and recycling chains in the process of consolidation, therefore moving out of Band C. For this packaging, the fee changes from the Band C fee of €560/t to €555/t;
Band C, though reduced in scope, remains in force for packaging that cannot yet be sorted or recycled with current technologies. For this packaging, the EPR Fee remains unchanged at €560/t.

From 1 July 2023, increases were introduced for three plastic EPR Fee bands (A1.2, A2 and B2.2) in order to align their values more closely with the costs required to send the types of plastic packaging included in those bands to recycling.

Despite these increases, the average fee for plastic packaging in 2023 still decreased compared to 2022.

For further information on the fee bands for plastic packaging, please refer to the dedicated “Modulated EPR Fee for plastic packaging” page on the CONAI website.

Packaging with experimental sorting or recycling activities underway remains in Band C, as does packaging that cannot be sorted/recycled with current technologies.

Although this is the plastic packaging band with the greatest environmental and economic impact, this band also saw a reduction in the EPR Fee, from €660/t to €642/t, thanks to the initial introduction of the chain deficit and as a result of the cost optimisation measures implemented by the Corepla consortium.

Fee modulation is based on the technical analysis of packaging types (polymer composition, shape, compatibility with sorting and recycling processes and recycling technologies available on an industrial scale), and its ultimate criterion is the actual recyclability of the packaging.

Recyclability certifications, on the other hand, concern individual packaging items belonging to a specific company.

These certifications, and the results obtained, are not always consistent with the logic of fee modulation. For example, some technical solutions, such as those involving the presence of metals or barrier polymers below a certain tolerance threshold, may be compatible with the recycling stage but not with the sorting stage. This is because, during the sorting of packaging waste, it is not possible to separate packaging above that threshold (which may therefore be problematic for recycling) from packaging below it.

A further example is provided by many guidelines that make a technical solution conditional on it not exceeding a certain market share. That condition is difficult to monitor and verify across the whole country.

Despite these difficulties, the CONAI EPR Organisation constantly monitors the various European initiatives on the certification of packaging recyclability.

To promote prevention measures and improve packaging recycling performance, guidelines for facilitating the recycling of packaging are available at the following link: https://www.progettarericiclo.com/en

Mechanical dispensers may contain one or more metal components (spring and/or ball bearing), which enable the mechanism to function.

According to the classification approach adopted so far, mechanical dispensers are currently placed in Band B2.2, regardless of whether or not they contain such metal components. In fact, in most recycling plants these components can be removed and separated from the plastic components.

However, with a view to improving packaging recyclability, it would be preferable to replace metal components with plastic ones that are compatible with the recycling process for the polymer making up the bottle body to which the dispenser is attached (PET, HDPE or PP).

Industrial-use sacks means film reels (flat or blown–tubular extrusion) or individual sacks/bags (valve or open-mouth) used to package products that are employed within companies’ production cycles and are therefore not intended for the household circuit.

Plastic sacks containing products intended mainly for the industrial circuit, used for example in the following sectors/product categories, fall within Band A2 as flexible polyethylene packaging:

petrochemicals (polymers);
chemicals (additives, compounds, masterbatch, etc.);
construction (cement, premixes, powdered adhesives, etc.);
sand and gravel;
animal feed (fish, poultry, etc.);
fertilisers;
potting soil and organic fertilisers;
seeds;
food (dextrose, salt).

By contrast, for sacks used, for example, to contain pellets, what matters is the fact that these finished products are intended mainly for the household circuit, since they are used mostly to heat private homes (there do not appear to be significant uses of pellets in industrial sectors). These sacks therefore fall within Band B2.2 if they fully meet one of the following descriptions:

“Flexible monopolymer PE packaging, not metallised/coated with metals, without mineral fillers and/or ‘carbon black’ – other than Band A1.1 and A2 packaging (e.g. garment films, professional‑use films, protective films, ‘fourth‑range’ bags (for fresh-cut produce), etc.). PE foam structures and mineral fillers are permitted provided that the density remains below 1 g/cm³ (grams per cubic centimetre), as are inner barrier layers made of EVOH, up to a limit of 5% of the total weight of the packaging”;
“Flexible monopolymer PP or multilayer PE/PP packaging – not metallised/coated with metals, without mineral fillers and/or ‘carbon black’, other than Band A1.1 and A2 packaging (e.g. bags for pasta, sweets, etc.). PE foam structures and mineral fillers are permitted provided that the density remains below 1 g/cm³ (grams per cubic centimetre), as are inner barrier layers made of EVOH, up to a limit of 5% of the total weight of the packaging”.

In all other cases, sacks used to package pellets fall within Band C under “flexible packaging”.

Regardless of the sector in which they are used, industrial sacks combined with other materials, where plastic is the predominant material by weight, fall within Band C under “polylaminated packaging mainly consisting of plastic material”.

If, from the “first transfer” of the packaging, the sack producer has the information needed to classify it in a reduced fee band (for example based on the sector in which it will be used and the characteristics of the customer and/or of the product to be packaged), it will apply the corresponding EPR Fee on the invoice. In all other cases, it will apply the Band C EPR Fee, unless the user customer provides a self‑certification by means of forms 6.25 and 6.26, available on this website in the “Document downloads” / “Forms” section.

1) Labels (covering and non‑covering) are in themselves packaging and, as such, are subject to the CONAI EPR Fee independently, regardless of the container to which they are affixed.

For the purposes of fee modulation, labels are classified in Band C, except in the following cases:

non‑glued labels – “made of monopolymer PE, monopolymer PP or multilayer PE/PP, without mineral fillers (mineral fillers are permitted provided that the density remains below 1 g/cm³) and/or ‘carbon black’ and not metallised/coated with metals, provided with perforations/punching to facilitate removal and accompanied by instructions inviting the consumer to remove them” – are subject to Band B2.2;;
labels mainly consisting of PP (>50% by weight) applied to rigid monopolymer PP packaging in Band B2.1 are, from 1 January 2023, considered an integral part of that packaging and may therefore be subject to the same Band B2.1.

2) As regards the containers to which the labels (covering or non‑covering) are affixed, a distinction must be made between:

rigid containers included in Band B1.1 and Band B1.2, for which those bands are confirmed only if the labels are non‑covering or, if covering, are “provided with perforations/punching to facilitate removal and accompanied by instructions inviting the consumer to remove them”;
rigid containers included in Band B2.1, for which that band applies regardless of whether or not they have non‑removable covering PP labels, and only if covering labels made of other polymers are provided with perforations/punching. From 1 April 2024, any covering labels made of polymers other than PP are also permitted, regardless of whether or not they are provided with perforations/punching;
rigid containers included in Band B2.2, for which that band applies regardless of whether or not they have non‑removable covering labels;
PET bottles, jars and flasks and similar containers in Band B2.3, for which that band applies if they have covering labels that are not punched. From 1 April 2024, these packaging items were reallocated to Band B2.2.

In order to facilitate sorting and recycling operations, companies are in any case encouraged to minimise the use of covering labels, verifying their compatibility with existing sorting and recycling processes.

In verifying actual recyclability, for trays the “glue/adhesive” element has not so far been considered a distinguishing factor in the recycling stages. The tray and the pad must therefore be assessed individually, regardless of whether or not the pad is glued in place. Specifically:

The tray is subject to the EPR Fee for Band B2.1 or Band B2.2 where it meets the specific requirements laid down for rigid packaging in those bands. If it does not meet those requirements, it is subject to the EPR Fee for Band C;

The “absorbent pad” is subject to the EPR Fee for Band B2.2 where it has the characteristics laid down for flexible packaging in that Band. If it does not have those characteristics, it is subject to the EPR Fee for Band C;

In any case, it is recommended to adopt solutions that do not involve the use of glues to position the absorbent pad at the bottom of the tray.

The presence of glues compromises the quality of recycling and may therefore be the subject of future assessments by the Board Working Group for redefining the lists, potentially precluding access to the reduced fee bands.

Packaging types made of the same polymer may have different characteristics and therefore respond differently to the sorting and recycling technologies available nationwide. It is therefore possible to find packaging made of the same material in different fee bands, such as transparent PET bottles compared to opaque PET bottles. The former, if they meet the required characteristics, fall within Band B1.2, whereas the latter are subject to the EPR Fee for Band B2.3, which since 1 January 2023 has included packaging with experimental recycling chains or recycling chains in the process of consolidation.

Even where experimental sorting and recycling circuits exist, the applicable EPR Fee remains Band C until the entire collection, sorting and recycling chain takes on industrial characteristics broadly similar to those of other packaging eligible for reduced fees.
The trials currently underway are indicated on a dedicated page of the CONAI website. Where, following positive trial outcomes, a genuine industrial sorting and recycling chain is established, the Consortium will then submit any possible reallocation to a more favourable band to the competent consortium bodies, providing appropriate information to the companies concerned.

In order to fall within a reduced fee band, packaging must actually be recycled and not merely theoretically recyclable. In defining the fee bands, the definition of recyclability set out in UNI technical standard 13430 was adopted, according to which actual recycling in industrial plants must be verified.

The general criteria for fee modulation, reflecting the current way in which packaging waste is managed at national level, provide that packaging waste, if disposed of through urban separate collection, must first of all be compatible with the sorting technologies available nationwide – a fundamental step in creating homogeneous waste streams that can then be sent for recycling. The second step is actual recycling, i.e. the real possibility of transforming homogeneous post-sorting packaging waste streams into secondary raw materials, which are then used by other plants to be processed into new products. At this stage, the technical characteristics of the packaging, the existence of critical masses and market demand for secondary raw materials on the market all come into play. For these reasons, fee modulation stipulates that allocation to reduced fee bands is conditional upon the actual ease of sorting and actual recycling of the types of packaging waste concerned. Since 1 January 2022, moreover, the criteria and logic behind fee modulation for plastic packaging have been updated, linking the values of each band not only to the recyclability and destination circuit of the specific types of packaging, but also to the chain deficit.

If the packaging is not expressly indicated among the entries included in the reduced fee bands, it necessarily falls into Band C, regardless of whether or not the specific type is mentioned by way of example.

If the packaging meets the criteria for ease of sorting and recyclability, allocation to the correct fee band depends on the main destination circuit in which the packaging is intended to become waste.

Packaging belonging to the Household circuit is packaging intended to become waste mainly at household premises and consequently to be disposed of through separate collection. Packaging belonging to the Commerce & Industry circuit is packaging intended to become waste mainly at industrial premises and consequently to be disposed of through dedicated circuits.

Following the introduction, from 2022, of the new criterion of the chain deficit, i.e. the costs and revenues of collection, sorting and recycling activities, the following are included in the GROUP:

A1 rigid and flexible packaging with an effective and established industrial sorting and recycling chain, mainly managed in the “Commerce & Industry” circuit;
A2 flexible packaging with an effective and established industrial sorting and recycling chain, mainly from C&I but also significantly present in municipal separate collection;
B1 packaging with an effective and established industrial sorting and recycling chain, mainly from the “Household” circuit;
B2 other sortable/recyclable packaging from the “Household” and/or “Commerce & Industry” circuit.

Yes, two lists of plastic packaging in the nine fee bands were published, one in force from January 2023 and the other from July 2023, available at the following links:

List of plastic packaging in the fee bands valid until 30 June 2023: List of plastic packaging in the fee bands valid until 30 June 2023:
List of plastic packaging in the fee bands from 1 July 2023, incorporating the changes concerning certain types of plastic caps: List of plastic packaging in the fee bands valid from July 2023:

CONAI Membership

At present, the penalty for failure to join CONAI is €5,000. That penalty is imposed by the Province, which is also responsible for establishing the specific infringement.

Each EPR Organisation Member may correct its position in relation to infringements committed – such as, for example, failure to make the periodic declaration of the EPR Fee – by making use of the “self‑reporting” procedure. In that case, while default interest remains due, no penalty applies, except where the checks referred to in Article 12 of the CONAI Regulation have already been formally initiated.

Yes, a trader of packaged goods is an operator that purchases packaged goods in Italy or abroad and resells them both wholesale and retail. In other words, they act as a simple commercial intermediary.

The trader must register with CONAI in the users category, under “traders and distributors”. For packaged goods purchased abroad, the trader must also declare and pay to CONAI the EPR Fee on the packaging placed on the market in Italy.

Yes, producers and importers of empty packaging must join CONAI and the Packaging Material Consortia, according to the packaging materials produced or imported. Alternatively, Article 221, paragraph 3, points (a) and (c), of Legislative Decree 152/2006 allows Producers to manage packaging and packaging-waste compliance independently. We would underline that, in addition to the obligation to join, producers and importers of empty packaging must always show the CONAI EPR Fee on the invoice when the packaging is transferred (at the first transfer) to customers and must then declare and pay that EPR Fee to CONAI.

Joining CONAI, and any other change to company details, must be carried out exclusively through the Online Registration service, which can be accessed from , through the blue box at the bottom right of the homepage.

In order to access the Online Registration service, it is necessary to register using an Italian CNS (National Services Card) with an active PIN or SPID credentials, unless the person is already a registered user of the portal. A third party may also access the service, provided that they hold a power of attorney or a copy of the identity card of the legal representative of the company on whose behalf they intend to act (PDF format). The fee consists of a fixed amount of €5.16, plus a variable amount (if, in the last financial year closed at the time of joining, the company recorded total revenues of more than €500,000). Registration is a one-off payment, so it only has to be paid once. However, the EPR Organisation Member may adjust the amount annually if its costs or revenues have increased by at least 20%.

Companies producing or using packaging (whose total sales and service revenues in the previous financial year did not exceed €500,000 at the time of registering) may also opt to join CONAI through the their trade association (simplified admission).

A foreign company, unless it places packaged products on the market in Italy by means of an e-commerce platform, currently has no obligations towards CONAI, but it may choose to join the Consortium and comply with all the provisions laid down by the consortium rules, by electing a special domicile in Italy with a natural or legal person specifically appointed by means of the form attached to the application for membership for foreign companies (which can be requested from aziendaestera@conai.org). A foreign company with a secondary establishment and permanent representation in Italy may elect a special domicile at that premises.

For foreign companies that place packaged products on the market in Italy through e-commerce platforms operated by third parties, Article 178-quater of Legislative Decree 152/2006 provides that they may also fulfil their extended producer responsibility obligations by making use of the simplified procedures governed by agreements signed between the platform operators and the EPR systems. If the foreign company decides not to use the services offered by the platform, it is nevertheless required to join CONAI and comply with all the necessary obligations.

For foreign companies established in another Member State of the European Union, these provisions remain valid until the National Register of Producers (RENAP) is effectively operational under the Ministry of the Environment and Energy Security, pursuant to Article 178-ter, paragraph 8, of Legislative Decree 152 of 3 April 2006.

Companies whose registered office is outside the territory of the European Union, with the exception of those whose registered office is in the Republic of San Marino, that wish to join CONAI and do not have a secondary establishment with permanent representation in Italy must provide suitable guarantees covering the EPR Fee presumably due over the following 12 months, to be renewed on each expiry date, possibly with an updated amount, for the same period.

Companies whose registered office is in the Republic of San Marino may join CONAI under the same conditions established for companies whose registered office is in Italy, assuming the same rights and obligations as the latter.

Under Article 11, paragraph 2 of Law 154/2016 (“Agricultural Annex”), agricultural companies are not required to join CONAI or pay the related registration fee. They may still join voluntarily and independently. Regardless of membership, these companies remain subject to the EPR Fee on empty and/or filled packaging (packaged goods) purchased in Italy and/or imported.

End users of packaging are excluded from the obligation to join CONAI – that is, entities that purchase packaged goods for their business activity or for personal use, but do not carry out any marketing or distribution of the packaged goods purchased. Those same parties are, however, required to join CONAI if they:

carry out a commercial activity with the packaged goods purchased, even if only marginally in relation to their main activity;
purchase packaged goods or empty packaging directly from abroad for use in their activity;
purchase empty packaging in Italy for use in their activity.

Under the legislation currently in force, producers and users are responsible for the correct environmental management of packaging and of the packaging waste generated by the consumption of their products and, for that reason, they participate in CONAI. Producers are: suppliers of packaging material, manufacturers, processors and importers of empty packaging and packaging material. Users are: traders, distributors, fillers, users of packaging and importers of “filled packaging” (that is, packaged goods).

FAQ

CONAI EPR Fee

Definition of “Packaging”

SUP Directive

Modulated EPR Fee for paper packaging

Packaging platforms

ANCI-CONAI call for Local Communication projects

Modulated EPR Fee for plastic packaging

CONAI Membership

Useful contacts

Contact us

FAQ

CONAI EPR Fee

Tool “Codice Imballaggio” to identify the CAC and the declaration code of packaging – is it true that a tool is available that helps identify the CAC and the declaration code of packaging?

We produce packaging, some of which is exported. Do we have to apply the EPR Fee also to the portion of packaging transferred abroad?

One of our habitual exporter customers makes use of VAT exemption. At the same time, it has requested a 67% exemption from the EPR Fee through the relevant Form 6.5 – Suppliers. Is the remaining 33% of the EPR Fee charged subject to VAT?

I recently sent my EPR Fee declaration to CONAI. How should the EPR Fee resulting from the declarations be paid?

I have purchased packaging that my supplier has made subject to the CONAI EPR Fee on the invoice and I will use it to package my products. Am I also required to show the CONAI EPR Fee on my sales invoices? If so, how?

I am a trader and I often find the wording “CONAI EPR Fee paid” on my suppliers’ invoices for goods. What exactly does this mean?

Where can I find information about the new simplified EPR Fee declaration method?

If scrap generated during the self-production process of packaging is reintroduced into the production cycle and/or transferred to third parties on a contract processing basis, can it benefit from the exemption under the CONAI Circular of 21 October 2021?

Does scrap generated during particular stages of the self-production process of packaging (e.g. start-up, stop & go, colour change and reel changes) fall within the scope of the exemption from the EPR Fee provided for in the CONAI Circular of 21 October 2021?

Do raw materials for the self-production of packaging (on which the EPR Fee has been paid) that, due to accidental events, are not used in the self-production process fall within the scope of the exemption from the EPR Fee provided for in the CONAI Circular of 21 October 2021?

Does packaging scrap (in this case plastic film already subject to the EPR Fee) generated during the packaging stages of goods fall within the scope of the exemption from the EPR Fee provided for in the CONAI Circular of 21 October 2021?

Our company self-produces cardboard cores/tubes. Which scrap generated in the self-production process falls within the scope of the exemption from the EPR Fee provided for in the CONAI Circular of 21 October 2021?

Our company self-produces wooden crates and pallets. Which scrap generated in the self-production process falls within the scope of the exemption from the EPR Fee provided for in the CONAI Circular of 21 October 2021?

Our company self-produces steel cans/tins. Which scrap generated in the self-production process falls within the scope of the exemption from the EPR Fee provided for in the CONAI Circular of 21 October 2021?

I am an EPR Organisation Member. This year, for the first time, I imported small quantities of packaged goods, of only modest value. Am I still required to submit declarations to CONAI?

I would like to know what obligations relating to the EPR Fee arise in connection with the import of packaged products.

Is the CONAI EPR Fee also payable on empty packaging that I purchase or import in order to package goods for export?

Special cases – Are there sectors or packaging items for which specific procedures are provided for exemption from, application of or declaration of the EPR Fee, in addition to the ordinary procedures?

We have not yet received the invoice relating to the most recent EPR Fee declaration submitted to CONAI. Should I wait for the invoice from CONAI before making payment, or must I make payment in any case?

We have received an invoice from the Steel Packaging Material Consortium (Ricrea). We were wondering why we send our declarations to CONAI, but receive invoices from a Packaging Material Consortium?

I am a business owner and I have purchased packaging to package my products. My supplier has shown an amount on the invoice as the CONAI EPR Fee in addition to the price of the packaging. Am I required to pay it?

What is the CONAI EPR Fee (CAC)?

Definition of “Packaging”

I am a business owner who purchases various packaging materials for my goods. What should I understand by “packaging” for the purposes of CONAI obligations?

SUP Directive

When can a cap be defined as “tethered” under the rules currently in force?

Can single‑use cups and glasses made wholly or partly of plastic be placed on the market?

Can single‑portion, single‑use food containers made wholly or partly of plastic be placed on the market?

Are service companies and professional practices required to join CONAI?

Is packaging containing liquid food supplements subject to the obligation to use tethered caps?

Is packaging containing liquid “infant formula” and “follow-on formula” as defined by Regulation (EU) 609/2013 subject to the obligation to use tethered caps?

Do the provisions contained in this document apply throughout Europe?

Is plastic packaging/container/wrapping designed to preserve the shelf life and food safety of perishable products that are more susceptible to deterioration, and designed for immediate consumption directly from the packaging/container, included within the scope of the Decree?

Can cups and glasses produced before 14 January 2022 and not meeting the marking requirements be marketed until stocks are exhausted?

Must a cap made predominantly of metal, with plastic seals or elements, used in combination with a single-use plastic bottle, be designed to remain attached to the containers for the intended use period of the product?

Are beverage bottles intended and used for food for special medical purposes also subject to the eco-design requirements (the cap remaining attached to the bottle and recycled content)?

Are glass or metal bottles with plastic caps also subject to the eco-design requirements (the cap remaining attached to the bottle)?

Are the caps and closures of cups and glasses also subject to the marking requirements?

Are cups and glasses made of compostable bioplastic subject to the marking requirements?

Is packaging used for the transport and subsequent serving of food in canteens (for example hospital or school canteens), fitted with a lid/heat-sealed film or with a cover, and which does not show what product it contains, considered a plate or a food container?

Can plates made wholly of biodegradable compostable plastic, or partly where that part accounts for more than 10% of the total weight of the plate, be placed on the market?

Is a cup made of a material other than plastic (e.g. paper), and laminated with a plastic material (in a quantity exceeding 10%), considered a single-use plastic item?

Is a plate made of a material other than plastic (e.g. paper), and laminated with a plastic material (in a quantity exceeding 10%), considered a single-use plastic item?

Is a cup made of a material other than plastic (e.g. paper), laminated with varnishes, inks or adhesives (in a quantity exceeding 10%), considered a single-use plastic item?

Is a plate made of a material other than plastic (e.g. paper), laminated with varnishes, inks or adhesives (in a quantity exceeding 10%), considered a single-use plastic item?

Is oxo-degradable plastic packaging excluded from the application of the Decree?

Modulated EPR Fee for paper packaging

In the press release, CONAI and Comieco encourage companies to indicate on the label that type D packaging should be disposed of in the unseparated waste collection. Why is that?

What is meant by “paper‑based polylaminated packaging”?

When did the extension of fee modulation for other paper‑based polylaminated packaging come into full effect?

When did fee modulation enter into force?

How does fee modulation work?

What does the trial phase entail?

What should I do in the case of imported empty packaging that has undergone a laboratory test other than the UNI 11743 test?

If I already have an Aticelca certification, can I use it? Are the tests carried out using the Aticelca method before it became the UNI 11743 standard valid, or do they need to be repeated?

Is it possible for the recyclability assessment using the Aticelca 501 assessment system to be inconclusive?

Is it possible to perform the separability test before the recyclability test?

What is meant by the ATICELCA 501 system?

Where can I find the values of the fee bands for paper packaging?

How do I determine which band my paper-based composite packaging falls into?

What should I do if I do not know the percentage of the paper component?

How should I calculate the percentage of the cellulosic component (CA)?

Which types of paper packaging are affected by fee modulation?

What is the purpose of fee modulation for paper packaging?

Packaging platforms

We manage a storage / recovery / sorting / compaction (volume reduction) facility. What opportunities does the CONAI–Packaging Material Consortia system offer? How can we join?

Where is the affiliated platform closest to me that accepts secondary and tertiary packaging waste? / How can I obtain a list of affiliated platforms that accept secondary and tertiary packaging waste?

Is there a fee for delivering packaging waste to affiliated platforms?

We are an EPR Organisation Member company. How can we dispose of packaging waste that is not collected by the public service?

What service is provided, in return for payment of the EPR Fee, that also applies to secondary and tertiary packaging, for companies that need to dispose of their packaging waste?

How do producers and users of packaging comply with the obligations imposed on them by Article 221 of Legislative Decree 152/2006?

ANCI-CONAI call for Local Communication projects

Is the payment made only after an invoice has been issued?

For small municipalities with a strong tourist presence, can the higher number of people present be taken into account when calculating per‑capita packaging waste collection?

Are the 20+10 points awarded for the change in service and the additional 5 points for the separate collection communication campaign cumulative, or is only one of them applied?

With regard to the scoring criteria, must at least five municipalities be grouped together if a single municipality does not reach 50,000 or 100,000 inhabitants?

If a project has received co‑funding from a supra‑municipal body (e.g. regional or provincial), is it still eligible? In other words, can a project still be submitted even if it is not funded 100% by municipal resources?

What can be included under “innovative and intelligent technological tools”? Do websites in general qualify?