Grouped by subject. Every answer states the rule, the source and the date it was last checked. The whole library as one file: answers.md · answers.json
Marketplace sellers 6
I sell on Amazon.it. Do I need an EPR number for Italy?
Yes. Since 12 August 2026 Amazon asks sellers of packaged products for a packaging EPR registration number for each EU country, Italy included, even if they use Pay on Behalf. For Italy the number is the one CONAI gives you when you join. Listings without a valid number can be deactivated.
Which number do I enter in Seller Central for Italy?
Your CONAI number. In Seller Central go to Settings › Account Info › Extended Producer Responsibility, select Italy and the packaging category, and enter the number CONAI gave you. Entering your partita IVA or codice fiscale instead is a common reason for rejection.
I use Amazon Pay on Behalf. Do I still need a CONAI number?
Yes. Amazon's own notice for Italy says sellers must submit an EPR registration number even if they use Pay on Behalf. Pay on Behalf pays the contribution for the Amazon units it covers, for €25 per category a year; it does not give you a CONAI number and does not cover your other channels. You can keep it and declare only the rest to CONAI.
Amazon support told me Italy does not need EPR yet. Is that right?
No. On the Amazon.it seller forum a seller reported being told by Amazon support that Italy did not need EPR yet; the Amazon moderator replied that this information was not correct and that the requirements apply to Italy from 12 August 2026.
My listings were deactivated for EPR. Do they come back once my number is accepted?
No. Amazon's notice says that if offers are deactivated for an EPR violation, resolving the compliance issue does not reactivate them automatically. Once your number is validated, reactivate them in Manage All Inventory, ASIN by ASIN, or in bulk with the Inventory Loader.
I sell to Italy only from my own shop. Do I need CONAI?
CONAI says a foreign company that does not sell through an e-commerce platform has no obligation towards CONAI today, but may join by electing an Italian address. Separately, the PPWR has required an authorised representative since 12 August 2026 for producers selling directly to end users in a member state where they are not established. Italy's decree on how that works is still pending.
Who needs a representative 3
I only sell a few items to Italy. Is there a threshold?
No. Neither the PPWR nor Italian law sets a minimum volume for being a producer. CONAI's thresholds decide whether you declare monthly, quarterly or annually, and very small contributions may need no periodic declaration, but they do not take you out of scope or replace the number Amazon asks for.
I have an Italian VAT number and stock in an Amazon warehouse in Italy. Am I established in Italy?
No. An Italian VAT registration, OSS, or stock in an Amazon or other Italian warehouse does not make your company established in Italy. With stock in Italy you may also count as an importer of filled packaging for CONAI, which is one more reason to have a membership.
Does an Italian representative cover other EU countries?
No. PPWR Article 45(3) requires a representative in each member state where you sell and are not established. Italy is one appointment; Germany, France and Spain each need their own. We cover all four through EPR Germany Rep, EPR France Rep and EPR Spain Rep.
CONAI and the domicilio speciale 3
What is the domicilio speciale, and why does CONAI want one?
CONAI admits a foreign company as a member if it elects a special domicile in Italy with a natural or legal person appointed for the purpose. It is the address CONAI writes to. A company with an Italian branch can use that; most foreign sellers use a representative's address.
How does a foreign company join CONAI?
Italian companies join online with an Italian digital identity (SPID or CNS). A foreign company uses CONAI's dedicated membership form for foreign companies instead, with its company documents, VAT number, the signatory's ID, a mandate, the election of a domicilio speciale and its packaging data, and pays the €5.16 joining share.
How long does CONAI registration take?
Weeks, and the time is CONAI's. Amazon's own notice warns that registration can take weeks and announced extra time for Italy for that reason. Providers publish between six and sixteen weeks. We file the day your details and signed mandate are in, but cannot guarantee CONAI's timing.
The contribution and declarations 3
How much does CONAI cost a small seller?
A €5.16 joining share, once, plus the environmental contribution on what you place on the market: €0.045/kg for mono-material paper and cardboard and €0.051 to €0.922/kg for plastic, by band, from 1 October 2026. A seller shipping 50 kg of cardboard a year owes about €2.25.
How often do I declare to CONAI?
It depends on the size of your contribution: annual, quarterly or monthly, with each declaration due by the 20th of the month after the period. Very small contributions may need no periodic declaration under the ordinary procedure. CONAI assigns the frequency.
Can I use CONAI's simplified procedure for imported goods?
Importers of filled packaging can in some cases declare by a simplified procedure: a flat €131 per tonne of packaging (“per tara”), or a share of the value of the goods — 0.25% for food, 0.11% for non-food (“a valore”) — from 1 October 2026. Eligibility has conditions, and the choice holds for the calendar year.
Who is the producer 2
Amazon ships my goods (FBA). Am I still the producer in Italy?
Yes. With FBA or FBM, the seller places the goods on the Italian market and is the producer of their packaging. Amazon's fulfilment does not change that, which is why Amazon asks you for the registration number.
I sell to an Italian retailer who resells. Who is the producer?
Generally the Italian business that buys on its own account and resells: it places the goods on the Italian market. Get it confirmed in writing. Amazon applies the same logic: a seller whose supplier already met the obligation upstream may enter the supplier's number. Your direct sales remain yours.
Other obligations 1
I also sell electronics or batteries. Does CONAI cover them?
No. CONAI covers the packaging. The electrical products and batteries themselves register separately, in the Registro AEE and the batteries register, through a compliance scheme, and a seller without an Italian establishment needs an authorised representative there too. We quote them separately.
Sellers by country 2
I am a seller from outside the EU (UK, US, Switzerland, China…). What do I need for Italy?
If you sell packaged goods directly to end users in Italy: a CONAI number, which Amazon asks for; an Italian address (domicilio speciale) to join CONAI; and, under PPWR Article 45(3), an authorised representative in Italy. One provider can be all three.
I am a seller from another EU country. Does my registration at home cover Italy?
No. Your registration at home covers your home market only. Selling packaged goods directly to Italian end users, you need a CONAI number for Italy, an Italian address to get it, and an authorised representative under PPWR Article 45(3). OSS VAT registration does not establish you in Italy.