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Packaging EPR in Italy
RENAP is being set up under MASE. CONAI membership is mandatory but is not the EPR registration.
Checked 2026-09-13 · 4 sources · 4 open questions
- Register
- no PPWR producer register live yet — RENAP is being set up. CONAI membership is NOT the EPR registration.
- Authority
- Ministero dell’Ambiente e della Sicurezza Energetica (MASE); CONAI is the consortium, not the register
- Law
- D.Lgs. 152/2006, art. 178-ter; environmental labelling under D.Lgs. 116/2020THE TRAP: the CONAI member code (codice socio) is NOT an EPR registration number. CONAI membership stays mandatory for producers and importers of packaging, and it runs in parallel with the coming register — it does not replace it. During 2026 CONAI asked members to check and update their details in view of RENAP. ROLES: Italy splits them in a way no other member state does. A produttore makes, converts or imports EMPTY packaging or packaging raw material. A utilizzatore fills it, trades filled packaging or imports already-packed goods — and that is what a manufacturer of goods usually is here. So the party the Italian scheme calls the producer is NOT the party every other country calls it, and the PPWR manufacturer is a third definition again. A produttore must also join the material consortium (COREPLA, COMIECO, CIAL, RICREA, RILEGNO, COREVE, Biorepack); for a utilizzatore that is usually voluntary. Membership fee: a fixed 5.16 EUR plus a variable part above a turnover threshold.
- Who registers
- No register is live yet
- Household packaging schemes
- CONAI; Aliplast; CONIP; CORIPET; ERION Packaging
- Industrial packaging schemes
- CONAI; Aliplast; CONIP; CORIPET; ERION Packaging
What is not settled
- Register No register yetNo PPWR producer register is live yet — RENAP is being set up under MASE. CONAI membership is mandatory but is NOT the EPR registration, and the CONAI member code is not an EPR number.
- Reporting Not established at sourceReporting cadence and thresholds under the coming register are not established.
- Authorised representative Not established at sourceNo authorised-representative rule was established: the PPWR producer register is not live and the sources read do not address a representative for producers established abroad.
- Authorised representative Sources disagreeThe authorised-representative duty is under review. On 10 December 2025 the Commission published COM(2025) 982, part of the Omnibus VIII environmental simplification package, whose Article 2 would suspend Art. 45(3) until 1 January 2035; COM(2025) 983 proposes the same for the Single-Use Plastics Directive. The suspension as drafted covers producers ESTABLISHED IN THE UNION selling cross-border directly to end users. Producers established in third countries are not covered — member states may still require a representative or ensure traceability by other means. European Parliament committee reports of May 2026 would narrow the relief to micro and small enterprises. PROPOSAL, AND NOW LARGELY STOPPED: on 24 June 2026 the Council decided not to proceed with the suspension, opposed by a large majority of member states. A Parliament committee vote is expected around October 2026, and even the Parliament's narrower approach would keep the framework for producers outside the EU. Article 45(3) applies as written today, and for a producer established in a third country nothing in this proposal ever applied.
The same in every EU country
- PPWR Art. 44 — registration is a precondition for placing packaging on that market
- PPWR Art. 45(3) — a producer under Art. 3(1)(15)(c)/(d), i.e. one making packaging available in another Member State DIRECTLY TO END USERS, must appoint an authorised representative there. From 12 Aug 2026.
- set nationally, Art. 68; national rules due by 12 Feb 2027
- Art. 44(14) implementing act still pending; central EU register not before 1 Jan 2029
Sources
Countries with the same answer
We do not register you, we are not your authorised representative, and we do not pay a scheme. This is public information gathered in one place and checked on the date shown. Confirm with the national authority before acting.
Tarafex
The number these registers ask for is kilograms by material for one year of deliveries. If your shipments are recorded as they go out, that number already exists.
See what Tarafex does →
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