Frequently Asked Questions (FAQ)
What is the ANCI-CONAI Framework Agreement?
The ANCI-CONAI Framework Agreement is a national agreement signed by ANCI – National Association of Italian Municipalities – and CONAI – the National Packaging Consortium of Packaging Producers and Users. The Agreement is used by CONAI to guarantee that most costs are covered for the separate collection of packaging waste, which gives each Italian Municipality the opportunity to sign an agreement for each type of packaging goods – an agreement which should be signed with their relative Industry Consortium. In fact, the Framework Agreement is formed of a General Section containing the general principles of the Agreement and six technical annexes, one for each material, governing the relative agreements. By signing the agreement, the Municipality agrees to recycle the packaging waste covered by the agreement and to send it to the Industry Consortium, following the procedures set out in the relevant technical annex. At the same time, the Municipality is guaranteed that the material sent will be recycled and a fee will be paid depending on the quantity and quality of the material provided. Additional fees following a different structure for each material are also set out for any extra services provided under the agreement, such as volume reduction, transportation, etc.Chiudi
When did the existing framework agreement come into effect? When will it end?
The new Framework Agreement was signed on 1 April 2014 and runs until 31 March 2019.Chiudi
Where are the operating methods and procedures of the agreements with the Industry Consortiums set out?
First of all, the operating methods and procedures of the agreements are set out in the relative Technical Annexes of the Framework Agreement (there is a technical annex for each material). The operating details can be found in the General Conditions for each agreement, which are provided by the Industry Consortiums following an agreement request from a Municipality. Certain Industry Consortiums – CiAl, Comieco and Corepla – have specific documents governing quality checks for the material provided.Chiudi
Are there organisations that control and monitor the implementation of the Framework Agreement and the relative agreements?
Yes. There are two Committees, both formed by an equal number of representatives from ANCI and CONAI. The Coordination Committee is the political body which ensures that the agreements are in force and promotes, implements and coordinates initiatives for the continuous improvement of packaging waste management. The Audit Committee is the technical body which receives reports from the parties under agreement and checks that the provisions of the technical annexes and General Conditions are being applied properly, approving the appropriate decisions in order to resolve any failure to comply with the conditions laid down.Chiudi
Who should be notified of any complaints on the application of the agreements?
The ANCI-CONAI Audit Committee should be notified as the technical body in charge of checking that the provisions of the technical annexes and General Conditions are being applied properly. You can write to the secretary’s office of the Audit Committee at CONAI’s headquarters in Milan (Via Pompeo Litta, 5 – 20122 Milano).Chiudi
Are Municipalities the only ones that can access the agreements governed by the technical annexes of the CONAI Framework Agreement?
In principle, Municipalities are the intended recipients of the agreements and payments for the material sent to the Industry Consortiums. However, the Municipality may delegate a third party – a legitimate group of Municipalities which it belongs to, the collection service manager, the processing plant for the material, etc – which is consequently authorised to sign the agreement in the name and on behalf of the Municipality and therefore collect the payments for any material collected within the Municipality.Chiudi
Is there a default proxy model?
Yes, a proxy model is supplied by the Industry Consortiums following an agreement request.Chiudi
How is an agreement concluded?
You must contact the individual Industry Consortiums to sign an agreement. Here are their contact details: RICREA - National Consortium for the Recycling and Recovery of Steel Packaging, Via Pirelli, 27 - 20124 Milano; tel. 02/66712717; website: www.consorzioricrea.org; CIAL - Aluminium Packaging Consortium, Via P.Litta, 5 - 20122 Milano; tel. 02/540291; website: www.cial.it; COMIECO - National Consortium for the Recovery and Recycling of Cellulose-Based Packaging, Via P.Litta 5 - 20122 Milano; tel.- 02/550241; website: www.comieco.org; RILEGNO - National Consortium for the Recovery and Recycling of Wooden Packaging, Via Aurelio Saffi, 83- 47042 Cesenatico (FO); tel. 0547/672946; website: www.rilegno.org; COREPLA - National Consortium for the Recovery of Plastic Packaging, Via del Vecchio Politecnico, 3 - 20121 Milano; tel. 02/760541; website: www.corepla.it; COREVE - Glass Recovery Consortium, Via Sardegna, 19 - 20146 Milano, tel. 02/48012961, website: www.coreve.it.Chiudi
What do you have to do to sign an agreement with CONAI? Is there a specific office or contact person?
The agreements under the ANCI-CONAI Framework Agreement are not signed with CONAI, but rather with the Industry Consortiums. Therefore to access the individual agreements all you need to do is contact the relevant Consortium asking for the necessary documentation.Chiudi
How does the ANCI-CONAI Framework Agreement guarantee municipal administrations a financial return?
By signing agreements with the industry consortiums under the technical annexes, the framework agreement guarantees a certain payment depending on the quantity and quality of the packaging waste provided. These payments are invoiced by the parties holding an agreement. If a proxy has been appointed, this delegated party shall collect the payments and not the Municipality. Therefore, if the Municipality chooses to grant a proxy to a third party to sign the agreement, the Municipality must be aware that the third party shall collect the payments by proxy. The Municipality can implement what it believes necessary to carry out periodic checks on the amount of payments collected by the delegated party and then take these into account in any contractual relations with the party.Chiudi
Are any adjustments organised over time for the payments made as part of the agreements under the ANCI-CONAI Framework Agreement?
The agreement is sent every year to all interested parties, i.e. the Municipalities and parties holding an agreement, since the ANCI-CONAI Framework Agreement requires that the payments made by the Industry Consortiums to parties holding an agreement are adjusted each year. In particular, the new Framework Agreement requires that the payments set forth in each of the six Technical Annexes are reassessed on a yearly basis at 95% of the annual inflation index (NIC index) compared with the previous calendar year.Chiudi
How are interested parties notified of any changes to the payments?
All interested parties, i.e. the Municipalities, parties holding an agreement, Federambiente and FISE, are sent a communication every year indicating the adjusted payments and how any potential balances were made (the adjustment will be made in the first months of the relevant calendar year).Chiudi
If a Municipality has entrusted the management of separate waste collection to a private company and wishes to make an agreement for this company, does it have to appoint a formal delegate?
Yes. In this case, the Municipality must grant a formal delegate to the company in charge of the service. The proxy model is provided by the Industry Consortium as part of the preparatory documentation for the agreement.Chiudi
If the Municipality has entrusted the service to a private company through a tender can the Municipality sign the agreement itself?
Yes. The municipal administration is always entitled to sign the agreements itself with Industry Consortiums and it can therefore directly manage the counting operations of the quantities provided and the invoicing procedures to the Consortiums. In this case, the Municipality must take into account that direct access to the agreement involves administrative and practical commitments. For example, certain consortiums require minimum amounts before material can be collected and the Municipality must be able to pick up these amounts within an appropriate timeframe to prevent it from signing an inactive agreement.Chiudi
Where is the packaging waste sent to the Industry Consortium taken?
Each Industry Consortium manages the materials in its own way, which varies depending on the specific nature of the material and the subsequent recycling phase and can also have a bearing on identifying the actual place – the recycling centre – where the collected material is taken. Generally speaking, however, the relevant recycling centre is shared between the parties, i.e. between the Industry Consortium and the party holding an agreement.Chiudi
Do the Industry Consortiums pay for all the material provided?
Do the Industry Consortiums pay for packaging waste? Similar types of materials do not accrue payment (for paper and cardboard waste, financial compensation is paid by the recipient paper mill). In certain cases (for Corepla and Coreve), similar types of materials may be considered foreign materials.Chiudi
Where can I get the list of “CONAI Recycling Centres?
There are no “CONAI recycling centres”. The relevant recycling centres are not even owned by the Industry Consortiums, let alone by CONAI. They are private or public plants, or sometimes mixed, with which Industry Consortiums or the parties holding an agreement themselves (depending on the management methods of each individual Industry Consortium) enter into a contractual relationship to manage the material sent there. In principle, any plant authorised for waste management can be considered a recycling centre and sent materials by the Municipality. However, it should be borne in mind that Industry Consortiums require specific features at the plants (storage, pressing and sorting capacities) in relation to the material processed, which may restrict the choice of plant.Chiudi
Are similar types of materials paid?
The Industry Consortiums only pay for packaging waste. However, in certain cases, financial compensation may also be paid for similar types of materials. CNA and CiAl allow similar types of materials up to the percentages set out in their respective general conditions and in any case they never consider them foreign materials. Rilegno recognises different agreements depending on whether the collected packaging contains similar types of materials or not. The agreement on paper and cardboard waste also pays financial compensation for similar types of materials. This payment does not come from the Consortium but from the paper mill which recycles the material. Finally, Corepla and Coreve consider similar types of materials to be foreign materials (not only are they not paid, but they will actually deteriorate the quality of the material and consequently reduce the payment made for the packaging waste).Chiudi
What are similar types of materials?
Similar types of materials refer to any material which, while still solid material partly made from packaging waste, is not actually packaging per se. For example: newspapers and magazines are similar types of materials in a collection of paper and cardboard packaging. Steel or aluminium pots and cutlery are similar types of materials in a collection of steel or aluminium packaging. Tables and furniture are similar types of materials in a collection of wooden packaging.Chiudi
How do Industry Consortiums handle similar types of materials?
Each Industry Consortium handles similar types of materials differently depending on the materials’ specific features. We should reiterate that consortiums pay for packaging waste. Industry Consortiums will therefore not pay for similar types of materials. A payment is indeed made for similar types of materials for combined paper/cardboard collections which, although in practice comes from the Consortium, is in fact paid by the relevant paper mill. Finally, please remember that for the Corepla and Coreve Consortiums similar types of materials are considered foreign materials.Chiudi
What is a CSS?
CSS is the acronym for a Sorting Centre, i.e. the polymer sorting plants where the Corepla Consortium sorts the packaging waste from separate collection services under agreement for different polymers (the individual “types” of plastics that are then recycled). The party holding an agreement may decide to send just one collected material to the CSS. Corepla then draws up a “simplified” agreement with payments just for packaging waste, minus the costs incurred to separate and recover the foreign materials. Parties holding an agreement. The party holding an agreement may also decide to press and pre-sort any collected materials at a recycling centre operating as a District Centre (CC), which the party chooses and manages (the CC may also be managed by another party working on behalf of the party holding an agreement). The material from the CC is then sent to a CSS identified by the Corepla Consortium. The party holding an agreement may decide to send its various collected materials straight to the CSS, without a preliminary stop at a CC. In this case, Corepla shall sign an “ordinary” agreement making payments for plastic packaging, while it is up to the party holding the agreement to agree upon the payments with the CSS for sorting any packaging handled by the other consortiums.Chiudi
Who pays to sort the different types of materials for multi-material collections?
The party holding an agreement is always responsible for sorting the different types of materials involved in a multi-material collection (whether it is a plant that does the sorting, or a CSM or a CC).Chiudi
What is a CC?
CC is the acronym for a District Centre, i.e. an authorised plant, agreed beforehand, at which the party holding an agreement makes the plastic packaging and packaging waste available to Corepla. Please remember that Corepla considers all material that comes out of the CC as a single material.Chiudi
Who pays to sort the different types of materials for multi-material collections?
The party holding an agreement is always responsible for sorting the different types of materials involved in a multi-material collection, whether it is a plant that does the sorting, or a CSS or a CC. Please remember that it is up to the party holding an agreement to agree upon the payments with the recycling centre for sorting packaging handled by other consortiums.Chiudi
Does the Municipality that sends the materials from the separate waste collection service to the Industry Consortium have to pay a fee?
No. The Industry Consortium must pay the Municipality for sending materials to the Industry Consortium and not the other way round! However, the party holding an agreement might have to pay fees for certain preliminary operations before the materials are sent to the Industry Consortium. In this case, given that the commercial relationship between the sending party and the plant takes place after the materials have been sent to the Consortium, it has nothing to do with the Framework Agreement.Chiudi
How do packaging producers and users fulfil their obligations under Article 221 of Legislative Decree No 152/06?
Article 221 provides for a system for the collection and recovery of any packaging waste that is not sent to the public waste collection service: companies that use packaging must deliver any secondary and tertiary packaging waste to a collection centre organised by the producers and agreed with the centres. CONAI and the Industry Consortiums have identified a system that fulfils these commitments, having organised a network of recycling centres across Italy at which companies may send their secondary and tertiary wooden, paper and plastic packaging waste for free. The sending of packaging waste to the recycling centres agreed by the Industry Consortiums is voluntary. In fact, the adoption of this system does not have to involve any unusual changes or requests for the recovery and recycling market of re-usable materials. It is simply another option for any companies that cannot find a recycling centre for their packaging waste. In this way, packaging producers shall bear the costs of receiving and recycling the waste, while users shall pay the costs of collecting and transporting the waste: both parties shall therefore fulfil their obligations under Article 221 of Legislative Decree No 152/06.Chiudi
What services are provided, in return for payment of the Environmental Contribution which also applies to secondary and tertiary packaging, for any companies that have to dispose of their packaging waste?
CONAI and the Industry Consortiums have organised a series of recycling centres across Italy where companies can send their secondary and tertiary wooden, paper and plastic packaging waste for free, provided that they comply with the simple requirements for each individual material (see the FAQ below).Chiudi
Our company is a member of the consortium. How can we dispose of packaging waste not collected by the public service?
Consortium companies can send their secondary and tertiary wooden, paper and plastic packaging waste free of charge for recycling to the network of recycling centres agreed with the Industry Consortiums. The lists of the recycling centres in Italy can be found at CONAI and at the Industry Consortiums involved (Corepla, Rilegno and Comieco).Chiudi
Does a fee have to be paid to send packaging waste to the agreed recycling centres?
Absolutely not. No fee has to be paid to send secondary and tertiary packaging waste to the recycling centres agreed with the Industry Consortiums. This applies if the waste in question meets certain requirements (limitations on foreign materials, packaging made from or contaminated by dangerous substances, etc).Chiudi
Can any type of packaging waste be sent to the agreed recycling centres?
First of all, it is worth pointing out that only secondary and tertiary wooden, paper and plastic packaging waste can be sent for free to the agreed recycling centres. Furthermore, this waste must meet certain requirements. For paper waste, cardboard boxes are allowed and so are pure cellulose bags (CER 150101) with a maximum impurity of 1.5% of the weight, excluding packaging containing any dangerous waste that has not been decontaminated. For plastics, the following are allowed: film, sacks, bags, jerry cans, buckets, baskets, stands, caps, boxes, straps, big bags and other plastic packaging. The maximum foreign material content (any metals, glass, paper, wood, soil or plastic not considered post-consumer packaging) is 5% of the weight. Hospital waste packaging is also not allowed, nor is any packaging made from or contaminated by dangerous substances, foul-smelling packaging, or packaging production waste and cut-offs. Lastly, for wood packaging, fruit and vegetable crates, pallets, boxes, cages and reels are allowed with a maximum non-wood foreign material content of 1% of the weight.Chiudi
The affiliated recycling centre where I wanted to send my secondary and tertiary packaging waste asked me for payment. Is this right?
Generally speaking, it might happen if the waste you want to send does not meet certain requirements. For paper waste, cardboard boxes are allowed and so are pure cellulose bags (CER 150101) with a maximum impurity of 1.5% of the weight, excluding packaging containing any dangerous waste that has not been decontaminated. For plastics, the following are allowed: film, sacks, bags, jerry cans, buckets, baskets, stands, caps, boxes, straps, big bags and other plastic packaging; the maximum foreign material content (any metals, glass, paper, wood, soil or plastic not considered post-consumer packaging) is 5% of the weight. Hospital waste packaging is also not allowed, nor is any packaging made from or contaminated by dangerous substances, foul-smelling packaging, or packaging production waste and cut-offs. Lastly, for wood packaging, fruit and vegetable crates, pallets, boxes, cages and reels are allowed with a maximum non-wood foreign material content of 1% of the weight. However, if your waste meets the established requirements, the manager of the affiliated recycling centre cannot ask you for any payment.Chiudi
Which is the closest affiliated recycling centre to me that will accept my secondary and tertiary packaging waste? How do I get a list of the affiliated recycling centres that will accept my secondary and tertiary packaging waste?
An updated list of the affiliated recycling centres where you can send your secondary and tertiary wooden, paper and plastic packaging waste is available in the “Businesses” section of the website under the “Waste Collection Recycling Centres” tab. Alternatively, you can contact the CONAI offices (mail: firstname.lastname@example.org) or the Industry Consortiums directly at: Ø COMIECO - National Consortium for the Recovery and Recycling of Cellulose-Based Packaging, Via P.Litta, 5 - 20122 Milano; tel.- 02/550241; Ø RILEGNO - National Consortium for the Recovery and Recycling of Wooden Packaging, Via Luigi Negrelli 24/A Cesenatico (FO); tel. 0547/672946; Ø COREPLA - National Consortium for the Recovery of Plastic Packaging, Via del Vecchio Politecnico, 3 - 20121 Milano; tel. 02/760541.Chiudi
We run a storage/recovery/sorting/volume compression plant. What opportunities does the CONAI-Industry Consortium system offer us? How do we join?
The CONAI-Industry Consortium system offers direct agreements with the Industry Consortiums as part of waste collection under the ANCI-CONAI Framework Agreement and as part of the Secondary and Tertiary Recycling Centre system (the latter is limited to paper, plastic and wooden packaging waste). To find out the administrative, technical and financial details of these opportunities, you need to contact the Industry Consortiums directly: Ø RICREA - National Consortium for the Recycling and Recovery of Steel Packaging - Via G.B. Pirelli, 27, 20124 Milano; tel. 02/66712717; website: www.consorzioricrea.org; Ø CIAL - Aluminium Packaging Consortium, Via P.Litta, 5 - 20122 Milano; tel. 02/540291; website: www.cial.it; Ø COMIECO - National Consortium for the Recovery and Recycling of Cellulose-Based Packaging, Via P.Litta 5 - 20122 Milano; tel. 02/550241; website: www.comieco.org; Ø RILEGNO - National Consortium for the Recovery and Recycling of Wooden Packaging, Via Luigi Negrelli 24/A Cesenatico (FO); tel. 0547/672946; website: www.rilegno.org; Ø COREPLA - National Consortium for the Recovery of Plastic Packaging, Via del Vecchio Politecnico, 3 - 20121 Milano; tel. 02/760541; website: www.corepla.it; Ø COREVE - Glass Recovery Consortium, P.zza G.D. Bande Nere, 9 - 20146 Milano, tel. 02/48012961, website: www.coreve.it.Chiudi
What is the Environmental Contribution (CAC)?
QUESTION: What is the CONAI Environmental Contribution? ANSWER: The CONAI-Industry Consortium system has established an Environmental Contribution for each packaging material, which serves as a form of financing for sharing the costs among producers and users of the biggest expenses for separate waste collection and for packaging recovery and recycling. The parties who have to pay the Contribution are the ones who put the finished packaging onto the Italian market for the first time, so generally speaking, producers, empty packaging importers and packaged goods importers. It also includes producers/importers of packaging materials that supply self-producers or the self-producers themselves at the time they import raw materials to package their own goods. Self-producers are any parties that purchase raw materials and packaging materials in order to manufacture/repair packaging for their own products.Chiudi
Meaning of “CONAI Environmental Contribution fulfilled”
QUESTION: I am a retailer; I often see “CONAI Environmental Contribution fulfilled” on invoices from my goods suppliers. What does this sentence mean exactly? ANSWER: Your suppliers use this sentence to certify that the packaging used for the invoiced goods has been subject to the CONAI Environmental Contribution at an earlier date. However, please remember that, when empty packaging is transferred from a producer to a user, the CONAI Environmental Contribution must be indicated separately from the sales price through certain information that cannot be replaced by the sentence “CONAI Environmental Contribution fulfilled.Chiudi
First supply and CAC notification on the invoice
QUESTION: I run a business and I have purchased packaging for my products. The supplier’s invoice displayed an amount for the CONAI Environmental Contribution. Do I have to pay it? ANSWER: The CONAI Environmental Contribution is applied at a particular time in the packaging’s lifecycle, known as the “first supply”, which is when the finished packaging is transferred, including temporarily or under any capacity, within Italy by the final producer to the first user. Your supplier is therefore correct to apply the CONAI Environmental Contribution to the invoice, which must be paid when the full amount on the invoice is paid. Please remember that if the packaging supplier omits or provides insufficient indication of the CAC, the CONAI Regulations state that the user/customer shall be held jointly liable.Chiudi
CAC notification methods on the invoice
QUESTION: I have purchased packaging to which my supplier has applied the CONAI Environmental Contribution; I will use this packaging for my products. Do I also have to indicate the CONAI Environmental Contribution on my sales invoices? If so, how do I do this? ANSWER: When invoicing for their own goods, packaging users must “internalise” the CONAI Environmental Contribution into the sales price of their goods and must clearly specify the amount of the Contribution for the packaging on the invoice. Alternatively, the sentence “CONAI Environmental Contribution fulfilled” can be indicated on the invoice, informing the customer that the sales price of the goods also includes the CONAI Environmental Contribution.Chiudi
QUESTION: I am a tax adviser and I would like to know who has to join CONAI? ANSWER: According to existing legislation, producers and users are responsible for the proper environmental management of any packaging and packaging waste produced by the consumption of their products and consequently they have to join the CONAI Consortium. Producers shall mean: any suppliers of packaging materials, manufacturers, processors and importers of empty packaging and packaging materials. Users shall mean: any retailers, distributors, fillers, packaging users and importers of “full packaging” (i.e. packaged goods).Chiudi
QUESTION: Do service companies, craft businesses and professional offices have to register with CONAI? ANSWER: End users of the packaging do not have to join CONAI, i.e. any parties that have purchased packaged goods to run their business or for their own consumption but do not sell or distribute any of these purchased packaged goods. However, these parties are obliged to join CONAI if: • they run a commercial business with the purchased packaged goods, including alongside their main business; • they directly purchase packaged goods or empty packaging abroad to run their own business; • they purchase empty packaging in Italy to run their own business.Chiudi
Membership procedure and costs
QUESTION: I am the Director of a new company that has to join CONAI. How do I join CONAI and how much does it cost? ANSWER: To register with CONAI, you need to download the membership application form from www.conai.org, then fill in every section of this form, pay the membership fee and send it to CONAI by fax or registered mail with proof of receipt. The fee is a set amount of 5.16 Euros to which a variable amount is added (depending on whether during the financial year prior to joining the company generated total revenue of over 500,000 Euros). The registration fee is a one-off payment. However, the consortium member is entitled to adjust its membership fee each year if its costs or revenue increase by at least 20%.Chiudi
Penalties for failing to register
QUESTION: Are penalties imposed for failing to register? What procedure must be followed to rectify previous years? ANSWER: The penalties for failed/delayed registration range from 10,000 to 60,000 Euros and are the responsiblity of the Province (not CONAI), if the Province has to check whether the registration has been omitted/delayed. The company may regularise its own position with regard to any infringements committed - for example, failed submission of the Contribution declaration over the years - by using the “Self-Declaration” procedure. In this case, there would be no penalties, notwithstanding any default interest owed.Chiudi
Registration to Industry Consortiums
QUESTION: Does the company that produces or imports various empty packaging materials have to register with the Industry Consortiums, as well as with CONAI, which handle all the packaging materials produced or imported? ANSWER: Yes, producers and importers of empty packaging must register with CONAI and with the Industry Consortiums, according to the packaging materials produced or imported. Please remember that, in addition to their membership obligation, producers and importers of empty packaging must always apply the CONAI Environmental Contribution to their invoice when transferring packaging to customers and they must then declare and pay this Contribution to CONAI.Chiudi
Packaged goods retailers
QUESTION: Is it true that packaged goods retailers have to register with CONAI? ANSWER: Yes, the packaged goods retailer is the operator that purchases packaged goods in Italy or abroad and resells them wholesale or retail. It is therefore operating as a simple commercial broker. The retailer must register with CONAI under “retailers and distributors” in the users category. For any packaged goods purchased abroad, the retailer must also declare and pay the Environmental Contribution to CONAI for any packaging placed onto the Italian market.Chiudi
Obligations of empty packaging retailers
QUESTION: What do CONAI’s Regulations essentially specify about empty packaging retailers? ANSWER: First of all, you need to determine whether the empty packaging has been purchased in Italy or abroad. • For purchases in Italy, the retailer must register with CONAI under the users category, then pay the CONAI Environmental Contribution to the Italian suppliers and inform its customers that the CONAI Environmental Contribution has been paid through a specific notification on the invoice. • However, for purchases abroad, CONAI deems the importers/retailers of empty packaging as packaging producers and requires that they fulfil all their obligations under that category.Chiudi
Tax representatives in Italy of a foreign company
QUESTION: I am a tax representative in Italy of a foreign company that supplies packaged goods to various Italian customers. Do I have any obligations to CONAI as a tax representative? ANSWER: A foreign company may act on behalf of Italian customers in fulfilling the obligations provided for by the consortium’s regulations by nominating a tax representative pursuant to Article 17 of Presidential Decree 633/72 (VAT regulation). Please remember that this is optional and not compulsory. In the absence of a tax representative, these obligations can be fulfilled through direct identification for VAT purposes in Italy, i.e. through an established organisationChiudi
CONAI invoice registration
QUESTION: We have received an invoice from the Steel Industry Consortium (Ricrea). We were wondering why we send declarations to CONAI but receive invoices from Industry Consortiums? Also which information do we have to put in our books for invoice registration purposes? ANSWER: CONAI issues invoices in the name and on behalf of the Industry Consortiums. The information to indicate in the company books is the VAT number and the tax code on the invoice that the company receives, which in this case would be the National Steel Consortium (Ricrea). RISPOSTA: Il CONAI emette fatture in nome e per conto dei Consorzi di Filiera. I dati da riportare nei libri contabili dell'azienda sono la partita IVA e il codice fiscale della fattura che l'azienda riceve, in questo caso del Consorzio Nazionale Acciaio (Ricrea).Chiudi
QUESTION: I am a packaging user, that is to say, I purchase empty packaging (paper bags), fill them and then sell them to retail stores. According to the CONAI Regulations, Article 7, paragraph 8, do I have to write the unit amount of the Environmental Contribution on the invoice? Do I then have to account for the Contribution and pay the relevant amount to CONAI? ANSWER: Pursuant to Article 7, paragraph 8 of the CONAI Regulations, the sentence “CONAI Environmental Contribution fulfilled” or “(...) including CONAI Environmental Contribution of €...” must be included on the invoice for every subsequent supply following the first sale (between the Packaging Producer and the User), excluding supplies to end consumers (with a tax receipt being issued) by the User. The Packaging Producer and the Importer of empty and/or full packaging is responsible for calculating the Contribution and sending the relevant periodic declarations to CONAI.Chiudi
CONAI Environmental Contribution payment
QUESTION: We have not yet received the invoice(s) for the declaration from the final quarter ‘01 for a total of 16.19 Euros. Do I have to wait for the invoice from CONAI before I pay or do I have to pay regardless? ANSWER: You only have to settle the Contribution when you receive an invoice from CONAI.Chiudi
CONAI Environmental Contribution for exporters
QUESTION: We do not apply the levy on purchases of packaging we produce for one of our regular exporter customers and this customer has a 67% exemption from the contribution. Do I have to apply VAT to the amount not exempt from the contribution? ANSWER: The CONAI Environmental Contribution shown on the packaging sales invoice should be considered an ancillary service pursuant to Articles 12 and 13 of Presidential Decree No 633/1972: as such, it falls within the scope of VAT. Included as part of the first supply, the Contribution is subject to the same VAT rate as the packaging or packaging material covered by the sale. Therefore, when supplying packaging to customers who have submitted a declaration of intent under Article 8, paragraph 1 (C) of Presidential Decree No 633/72, the CONAI Environmental Contribution shall be applied (following the potential percentage indicated by the upper limit for customer exports) without VAT.Chiudi
CAC exemption procedures for exports,QUESTION: Is the empty packaging that I purchase in Italy to package and then export my products also subject to the CONAI Environmental Contribution?
ANSWER: Exported packaging is outside of CONAI’s jurisdiction and therefore exempt from the Environmental Contribution. CONAI has established two procedures: one ordinary (ex-post through form 6.6) which involves documenting the exported amounts in the final balance and requesting reimbursement for the Environmental Contribution paid to suppliers directly from CONAI; and one simplified procedure (ex-ante through form 6.5) which involves determining the export percentage amount beforehand (upper limit) for each individual material throughout the calendar year and not paying the Contribution on this amount.Chiudi
First supply exemption
QUESTION: Do we have to indicate the Environmental Contribution on our packaging we sell abroad? ANSWER: No, any packaging sold abroad, which does not involve a first supply within Italy, should not be subject to the CONAI Environmental Contribution. No information on the Contribution should be indicated on any export invoices and no declaration to CONAI should be made by the manufacturing company for these sales.Chiudi
Deadline for submitting a new upper limit
QUESTION: I am a packaging producer; last year, I received an exemption upper limit from some of my exporting customers. From the first of January this year, do I have to apply the full Environmental Contribution? ANSWER: Your exporting customers may set a new upper limit each year, which should be sent (through form 6.5) to CONAI and to you, as the supplier, by 31st March. While waiting for the new upper limit, the producer may apply the upper limit from the previous year. Please remember that, from 2013, when the deadline for submitting form 6.5 falls on a public holiday, the deadline shall be extended to the first working day after that public holiday.Chiudi
CONAI obligations for importing companies
QUESTION: I would like to know the CONAI obligations for a company that imports packaged products. ANSWER: Any packaging materials for goods from abroad (within and outside the EU) released onto the Italian market fall entirely within CONAI’s jurisdiction and, as such, they must be subject to the CONAI Environmental Contribution. Therefore, in addition to registering with CONAI under the users category, an importer of packaged goods must make a periodic declaration through the special forms and pay the Environmental Contribution, for each single material, on all packaging which, after being imported, is released onto the Italian market. Simplified declaration systems are also provided for when it is particularly complicated to determine the weight and/or packaging materials of goods from abroad.Chiudi
QUESTION: In the last few days, I sent CONAI the Environmental Contribution declaration. How do I pay the Contribution resulting from the declarations? ANSWER: The amounts resulting from the Environmental Contribution declaration must be paid after the relevant invoices issued by CONAI have been received. For any ordinary procedure declarations, CONAI shall send an invoice on behalf of each of the six Industry Consortiums for their respective materials, while for simplified procedure declarations, CONAI shall send one single overall invoice. The payments should be made to the relevant accounts indicated on the invoiceChiudi
Definition of “packaging"
QUESTION: I am a business owner who purchases various packaging materials for my own goods. What does packaging mean for the purposes of CONAI’s obligations? ANSWER: According to existing legislation packaging is: any products made of any materials to be used for the containment, protection, handling, delivery and presentation of goods, from raw materials to finished products, from the producer to the user or the consumer, including non-returnable items used for the same purposes. The same legislation provides certain clarifications and definitions, such as: primary, secondary, tertiary and re-usable packaging, etc. The CONAI consortium system covers steel, aluminium, paper, wood, plastic and glass packaging.Chiudi
As collection service managers of the municipality XX, can we apply for participating on the Competition?
You can participate in the Competition if there has been given a specific mandate by the City / aggregation of municipalities over 5,000 inhabitants and if an application by the Government of the waste service (eg. ATO) hasn’t been submitted or if the municipality / aggregation of municipalities are not included in the submitted application.Chiudi
For the waste collection service managers of the municipality is the delegation under the Framework Agreement for the subscription of conventions enough for participating on the Competition?
No, you need a specific declaration by the municipality or by the city aggregation of municipalities’ leader, with which you will delegate to the submission of the application for the Competition for and on behalf of the joint / s. The delegation must formally specify the full sharing of the draft presented.Chiudi
With " particularly and objectively suffering territorial systems" do you mean only mountain communities and small islands, or there are other possible parameters?
The extra score of 4 points is related to the municipalities falling within mountain communities and smaller islands.Chiudi
Regarding the modifications on the collection system addressed to the models preferred by CONAI, is the score assigned only if just one part of the collection system changes?
The scoring is assigned if the changes on the collection service includes the transfer to the collection of lightweight multi-material, single material for paper / cardboard and glass.Chiudi
Regarding the "innovative and intelligent technology tools", what can be included? Internet websites in general?
The construction / renovation of sites / web pages as the communications’ activities support are not among the innovative technological tools. The latter undertakings include, for example, the development of Apps to direct users of the collection service, awareness campaigns promoted through social networks or blogs creation which are dedicated to the starting of new collection system.Chiudi
Submissions should necessarily be started after the 1st of January 2015?
Yes, the communication projects which are financed by the Competition must be started as of 1 January 2015.Chiudi
If a project has been co-financed by some supra-municipal entity, eg. regional or provincial, it is equally eligible? Or, in another way, if the 100% coverage is not only guaranteed by municipal funds, you may also nominate the project?
The participant in the Competition must have a coverage of 65% of the Communication project cost. Nothing precludes that such coverage is also provided by other financing from regional funds, European funds, etc.Chiudi
Among the eligibility prerequisites, where noted "by individual or associated municipalities, with a population of at least 5,000 inhabitants, where the governing body of the previous point is not formed or, even constituted, did not approve the plan field in the term of indicated", is the reference to the 5,000 inhabitants considered for each municipality or associated municipalities?
It's the least total number of 5,000 inhabitants that must be considered, regardless of whether it’s one municipality or more municipalities associated.Chiudi
Regarding the reward requirements, there must be at least 5 municipalities associated if the individual municipality does not reach 50,000 or 100,000?
Both required specifications must be met, meaning that it has to be an aggregation of at least 5 municipalities that exceed a total of 50 thousand or 100 thousand inhabitants (5 or 8 points).Chiudi
The 20 + 10 points that are given in exchange of service as well as the 5 point regarding the communication campaign on recycling are both cumulative or alternative instead?
They are alternative. Depending on the project the reward is given to the main action.Chiudi
Regarding the small, highly tourist towns, is it possible to take into account the larger number of inhabitants in the calculation of per capita collection of packaging waste?
In such cases you can use when available by the Region, Body of waste or Province government service, the data of the equivalent population (ex.: every year the Liguria region elaborates the figure for the equivalent population by municipality according to appearances recorded in the previous year).Chiudi
Is the financial assistance exclusively following the issue of an invoice?
Yes, funding will only be provided by CONAI by following the issue of the invoice plus VAT, in accordance to the instructions contained in the authorization to charge that will be transmitted by CONAI itself.Chiudi
How were the diversification criteria chosen?
With constant and fruitful dialogue with producer and user Associations, three Guiding Principles were identified for contribution diversification, useful for linking the value of the CAC to the environmental impact of the end-of-life/new-life phases of plastic packaging according to the "polluter pays" principle:
• the main target circuit of the packaging once it becomes waste.
The target circuit can be "Household" or "Commerce & Industry". "Household" circuit packaging also includes that from "Commerce & Industry" systematically treated as household waste.Chiudi
What is the difference between the Household Circuit and the Commerce&Industry Circuit?
If the packaging meets the sortability and recyclability criteria, allocation of the correct contribution level depends on the prevailing destination circuit in which the packaging will become waste.
Packaging belonging to the Household circuit is that which will become waste mainly at households and consequently be disposed of with separate collection. Packaging belonging to the Commerce&Industry circuit is that which will become waste mainly at industries and consequently be disposed of via dedicated circuits.
- packaging mainly intended for the C&I circuit with an effective and consolidated industrial sorting and recycling chain is that in Level A;
- packaging mainly intended for the household circuit with an effective and consolidated industrial sorting and recycling chain is that in Level B1;
- packaging of both circuits with an industrial sorting and recycling chain in the process of consolidation is that in Level B2.
What do I do if I can't find my packaging in the lists of the various contribution levels?
If the packaging is not expressly indicated in the items in the lists of levels A, B1, B2 and C, it necessarily falls in level C, regardless of whether or not the specific type is mentioned by way of example.Chiudi
Can the lists of reduced CAC packaging change?
Considering the evolution of the product and process technological context (sorting and recycling) and/or the indications coming from the sectors concerned, Conai has set up a specific Permanent Technical Assessment Committee that can also make recourse to the support of industry experts, which from time to time proposes reallocation of specific types of packaging to the competent Board of Directors.Chiudi
Must packaging be Recyclable or Recycled to be subject to a reduced CAC?
In order to be included in a reduced CAC level, the packaging must be actually recycled and not just theoretically recyclable. Indeed, the definition of recyclability envisaged by the UNI 13430 technical standard has been adopted in the definition of contribution levels, so actual recycling in industrial plants must be verified.
The general contribution diversification criteria, reflecting the current way of managing packaging waste at the national level, envisages that packaging waste, if disposed of in municipal SC, must first be compatible with sorting technologies currently existing in throughout the country, a fundamental step to create homogeneous waste flows that can be sent for recycling. The second step is actual recycling, i.e. the real possibility of transforming the homogeneous flows of post-sorting packaging waste into secondary raw materials which are then used by other plants to be transformed into new products. This is where the technical characteristics of the packaging, the existence of critical masses and the existence of a demand for secondary raw materials on the market come in. For these reasons, contribution diversification envisages that allocation to levels A - B1 and B2 is linked to the actual sorting and actual recycling of the various types of packaging waste.
What happens to packaging that is subject to recycling trials?
Even if there are experimental sorting and recycling circuits, the CAC is still subject to that of Level C, until the entire collection, sorting and recycling chain takes on industrial connotations, substantially similar to those of other reduced CAC packaging.
The trials in progress will be indicated in a dedicated page of the Conai website. If, as a result of the positive outcome of the trials, a veritable industrial sorting and recycling supply chain is created, Conai will then submit any reallocation in a more facilitated level to the competent consortium bodies, giving adequate information to the companies concerned.
Why is the same Polymer in different levels?
Packaging types comprising the same polymer may have different characteristics, and therefore respond differently to the sorting and recycling technologies in existence throughout the country. It is therefore possible to find packaging made of the same material in different contribution levels, such as transparent PET bottles compared to opaque PET bottles. Indeed the former, if they meet the required characteristics, are allocated to Level B1, while the latter are subject to the CAC of Level C, since there is currently no industrial recycling chain.Chiudi
What contribution level should be applied to biodegradable and compostable plastic packaging?
Biodegradable and compostable bags are included in the reduced CAC-level B2, while other packaging made of biodegradable and compostable polymers is allocated to level C, since there is currently no consolidated sorting and recycling chain. This packaging is therefore aggregated with similar types of packaging made of other polymers present in level C.Chiudi
What contribution level should be applied to mainly plastic polylaminated packaging?
Mainly plastic polylaminated packaging is subject to the CAC of level C since it does not currently meet the criteria of sortability and recyclability and, therefore, is not included in the reduced CAC packaging lists.Chiudi
To which level is packaging with barrier layers (EVOH) allocated?
These specific treatments applied to packaging provide better technical performance, also guaranteeing a shelf life of the product with consequent reduction in waste of the contents (especially if intended to contain food products); however, they compromise subsequent recycling and as a consequence are currently included in level C.
At the European level, the European Recyclers' Association (PRE) recently completed a number of tests on EVOH compatibility in the recycling flow of flexible PE packaging. In this context, the first tolerance thresholds were therefore defined which, where consistent with the envisaged guidelines, such as sortability and effective recycling, will be submitted to the competent consortium bodies for possible reallocation to a lower CAC level.
Which level is metallic packaging allocated to?
The evaluations carried out by PTAC confirmed that metallic treatment (of whatever type) is, based on the available information, a factor that has a negative impact on packaging recycling. Although these specific treatments applied to packaging provide better technical performance and improve product appeal vis-a-vis the end consumer, they have a negative impact on the quality of secondary raw materials that can be obtained from recycling flexible packaging. This is at a time when one of the obstacles to a greater use of recycled plastics, also raised by packaging producers themselves, is the poor quality of recycled plastics available on the market; as a result, metallic packaging for 2020 will remain in level C.
The Committee is closely following the work promoted at the European level by the European Recyclers’ Association (PRE), which adopts an approach similar to that of CONAI, i.e. it considers the actual recycling possible with existing technologies, based on homogeneous sorted waste flows. As regards metallic treatment, while acknowledging that asserted by PRE, there are currently no industrial technologies at the sorting level able to discriminate between metallic packaging implemented with a non-impacting technology (provided that the conditions specified in the PRE document are met) and one that does not meet such requirements and, since metallic packaging is not acceptable to recyclers in the material fed into their plants, both would be removed during sorting. If, in the future, sorting technologies are developed that can discriminate between metallic packaging implemented with recyclable and non-recyclable solutions, or if all companies convert to recyclable metallic treatment solutions, avoiding the need to remove this type of packaging at the sorting level, the decision could be reviewed.
What is meant by black packaging?
Packaging is considered to be black when the inner and/or outer surface is black. For black printing, the entire packaging is considered black when at least half or more of its surface is printed. It is not considered black when the black layer is inserted between two layers of a different colour.Chiudi
Who to contact for clarification?
For any clarification, please fill in the online form on our website in the “Contact us” section, selecting "Diversified Contribution" from the list of topics or contact the Toll-free Number 800337799.Chiudi