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Do I need an Italian EPR representative?
Italy asks whether you are established there, how your goods reach Italian buyers, and who receives them. Four questions, and the answer is sometimes no — a check that always says yes is a sales form, not a check.
This follows the producer definition in the PPWR and CONAI's rules for foreign companies. We are not lawyers; where Italian practice is unsettled, this is our reading, not legal advice. Sources (2)Regulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR), Article 45CONAICONAI — FAQ: imprese estere
Questions people actually ask
Is there a minimum volume below which I can ignore this?
No. Neither the PPWR nor Italian law sets a volume threshold for being a producer. CONAI's declaration thresholds decide how often you declare, not whether you are in scope.
What if I only sell through Amazon?
You still need your own number. Amazon asks every seller for a packaging registration number for Italy, even with Pay on Behalf. For Italy that is your CONAI number.
My Italian customer resells the goods. Am I still the producer?
Generally not for those goods: the business that first places them on the Italian market carries the obligations. Get it confirmed in writing, and remember any direct sales remain yours.
Can you tell me I do not need you?
Yes, and we do. The check returns “no representative needed” where that is the right answer, and we will read an unclear arrangement for you without charging.
Selling into Italy without an Italian company?
Amazon.it asks for your CONAI number, and CONAI asks a foreign company for an Italian address. We are both, for €199 a year.