EPR Fee

The CONAI EPR Fee is the funding mechanism through which CONAI distributes the cost of separate collection, recycling and recovery of packaging waste between producers and users. These costs, based on the provisions of Legislative Decree 152/06, are allocated “in proportion to the total quantity, weight and type of packaging material placed on the national market”.

The EPR Fee is determined by the CONAI Board of Directors and has been in effect since 1 October 1998.

In 2016, the Board of Directors approved the project for EPR Fee modulation, beginning with plastic packaging, with the aim of using the fee as a lever to encourage the use of more recyclable packaging.

Fee modulation entered into force on 1 January 2018 for plastic packaging and on 1 January 2019 for paper packaging.

EPR Fee values:

* Modulated fee of €120.00/t (€12.00/t base EPR fee + €108.00/t Extra-EPR fee) applicable to aluminium item “capsules, pods and sachets for tea, coffee or other beverages”  from 1 October 2026.

See the table showing changes in the EPR Fee from 1998 to 2025: Variazioni_CAC_1998_2025*

When the EPR Fee applies, how and to whom:

Consortium regulations stipulate that the amounts due from all EPR Organisation Members, Producers and Users must always be levied based on a specific indication on the invoice of the amount due, calculated according to the weight and type of packaging material in the first transfer of ownership.

“First transfer” means the transfer, even if temporary and for any reason, within Italy:

• of finished packaging from the last producer or trader of empty packaging to the first user other than a trader of empty packaging;
• of packaging material from a producer of raw material (or semi-finished product) to a “self-producer” who is or declares itself as such.

From 1 January 2019, following amendments to the Statute and Rules of CONAI, the “first transfer” also includes transfer of packaging from the last trader of empty packaging to the first actual user (the party that purchases or receives the packaging to pack its own goods). To assist “small traders” of empty packaging handling packaging flows that are not significant in terms of weight, CONAI introduced an incentive procedure, which was also implemented on 1 January 2019. This procedure has been updated, introducing an additional incentive (effective 1 January 2024) for small traders who purchase empty packaging abroad. See the Circolare CONAI del 29.11.2018 aggiornata.

In the case of transfers between producers/traders of empty packaging, it is the last producer/trader transferring packaging to the first user who must apply, declare and pay the EPR Fee, after sending the specific EPR Fee exemption certificate (Form 6.23) to the supplier (and to CONAI).

The Rules of CONAI also stipulate that packaging materials and packaging imported from abroad are subject to the EPR Fee, since their use will generate waste within Italy.

In this case, the EPR Fee is due, declared and paid by the company that places the packaging on the market, regardless of when or under what arrangement the packaging was acquired, unless the EPR Fee has already been paid by the foreign company registered (voluntarily) with CONAI.

How the EPR Fee is calculated and shown on the invoice:

The EPR Fee is calculated based on the weight of the packaging produced (broken down by material/fee band), imported or marketed.

The invoice relating to the first transfer must indicate, in addition to the description of the goods:

• the unit weight, by material, of the packaging supplied;
• the EPR Fee applicable to each material/fee band;
• the total value of the EPR Fee.

On invoices issued by the importer or on invoices following the “first transfer”, the EPR Fee must be shown for each item, or the wording “CONAI EPR Fee paid” may be used.

Tax aspects

The CONAI EPR Fee shown on the invoice is considered a payment for an ancillary service under Articles 12 and 13 of Presidential Decree 633/1972 and therefore:

• it falls within the scope of VAT;
• it must be taken into account for the purposes of mandatory electronic invoicing, introduced by Article 1, paragraphs 909 et seq. of Law 205 of 27 December 2017.

For further information, see: Aspetti_fiscali