EPR Fee exemption for exports

Packaging that is exported (and whose waste is managed abroad) falls outside CONAI’s remit and is therefore exempt from the EPR Fee.

To make use of the exemption, EPR Organisation Members who are exporters can use one of several procedures established by CONAI and described in the following sections.

Exemption procedure based on actual data (“ex-post”)

This procedure consists of documenting, after the fact, the share of packaging exported and requesting reimbursement of the portion that has already been subject to the EPR Fee at the time of purchase or import (and declared under the ordinary procedure).

To request reimbursement, the EPR Organisation Member must complete and submit Form 6.6 by no later than the last day of February of the year following that in which the packaging was exported.

For requests submitted up to thirty days after the deadline, a reimbursement of 75% of the amount due will be granted.

Exemption procedure based on forecast data (“ex-ante”)

This procedure consists of determining in advance the expected export share for each material during the calendar year and avoiding payment of the EPR Fee on that share. When determining the exemption ceiling, instead of calculating based on weight (total exported/sold) for each material, it is also possible to use the percentage ratio of the euro value of exports in relation to total turnover (based on the VAT return) as a reference basis.

The exemption ceiling must be communicated to CONAI using Form 6.5, and to suppliers (before the transfer of the packaging) using Form 6.5 / Suppliers, by no later than the last day of February each year.

Import/export compensation procedure

For companies that are both importers and exporters of packaging/packaged goods, an alternative “import/export” compensation procedure is available, using Form 6.10, to be submitted by the 20th day of the month following the reference period (monthly, quarterly or annually).

If the annual balance is payable by the EPR Organisation Member, CONAI will issue an invoice. If the annual balance is in credit for the EPR Organisation Member, it will be paid only after the Member submits the 6.10 Refund form.

Exemption procedure based on actual data (“ex‑post”) for export of filled packaging declared under simplified procedures

Companies that have declared the EPR Fee to CONAI under simplified procedures (based on value or tare weight of imported goods), for an annual amount up to €50,000, for filled packaging exported from 1 January 2025, are eligible for reimbursement of the EPR Fee. The reimbursable amount is calculated based on the percentage of foreign turnover out of total turnover (Italy + foreign), applied to the EPR Fee declared in the same year under the aforementioned simplified procedures.

For this reimbursement, the EPR Organisation Member must submit Form 6.6-Bis to CONAI by no later than the last day of February of the year following that in which the packaging was exported.

Exemption procedure based on forecast data (“ex‑ante”) reserved for EPR Organisation Member Users purchasing packaging (empty or filled) exclusively for export

Packaging (empty or filled) intended from the time of purchase/import to be fully exported may be granted total exemption from the EPR Fee. The request must be submitted using Form 6.5 / Suppliers-Bis, to be sent to CONAI and to the suppliers (before the transfer of the packaging). For further information, please refer to the circular:

Circolare_Conai_1_12_2021_Nuova-procedura-di-esenzione-per-EXPORT_agg.to 2023

Procedure for net exporting companies.

Net exporting companies may use an incentive procedure with the following conditions:

• exemption from declaring the EPR Fee for imported filled packaging;
• obligation to pay the EPR Fee on empty packaging purchased in Italy or abroad;
• no exemption from the EPR Fee for exported packaging.

The request must be submitted using Form 6.22, to be sent to CONAI by 30 April each year.