Who needs a representative
Do I need an Italian EPR representative?
If you have no company in Italy and your packaged goods reach end users there, PPWR Article 45(3) requires an authorised representative established in Italy, since 12 August 2026. In practice today, compliance in Italy runs through CONAI membership, and CONAI admits a foreign company only with an Italian address, the domicilio speciale. We provide both.
What number does Amazon.it ask for?
Your CONAI number. Since 12 August 2026 Amazon asks every seller for a packaging registration number for each EU country, even if you use Pay on Behalf. For Italy that is the number CONAI gives you when you join. Entering your partita IVA or tax code instead is a common reason for rejection.
I use Amazon Pay on Behalf. Do I still need this?
Yes, if you want to keep selling. Amazon's own notice says you must submit a registration number even if you use Pay on Behalf. Pay on Behalf pays the contribution for the units it covers; it does not give you a CONAI number, and it does not cover your own shop or other marketplaces.
How much will I pay CONAI?
A €5.16 joining share, once, and the environmental contribution on the weight you place on the market. From 1 October 2026 mono-material paper and cardboard costs €0.045/kg and plastic from €0.051 to €0.922/kg, depending on its band. A seller shipping 50 kg of cardboard a year owes about €2.25. We pass CONAI's costs on at cost, with no markup.
What does €199 include?
Representation, our Italian address as your domicilio speciale, your CONAI membership and CONAI number, and your declarations. CONAI's costs are separate and passed through at cost.
Is Italy's PPWR law in force?
The PPWR itself applies directly since 12 August 2026. Italy's decree adapting national law is still pending: L. 36/2026 gives the Government until about December 2026. Until then CONAI's existing rules apply, and we keep you aligned with both. We are not lawyers; this is our reading of the rules, not legal advice.
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.
Prices and CONAI costs
Can I use you alongside Amazon EPR Pay on Behalf?
Yes. Pay on Behalf only pays the contribution for the units Amazon covers. It does not give you a CONAI number, which Amazon asks for anyway. We get your CONAI number and file your declarations. Units Amazon has already paid for are left out of what we declare, so nothing is paid twice.
Why is €199 cheaper than the rest of the market?
Because the work is a fixed annual job — one membership, one address, the declarations — and we price it that way rather than by your weight. Every other published price we found is higher; check them in the dataset.
Are CONAI's costs included?
No, and no honest provider includes them without a cap. CONAI charges a €5.16 joining share once and a contribution per kilo by material; we pass both through at cost and publish CONAI's rates so you can check them.
Do I need an Italian partita IVA?
Not for us to act. A foreign company joins CONAI with its own company details and VAT number. If you hold stock in Italy, for example through Amazon's Pan-European programme, you may need Italian VAT registration for tax reasons, which is a separate matter.
How long until I get my CONAI number?
CONAI issues the number when it accepts your membership. We file the application the day your details and signed mandate are in. CONAI's processing time is its own: Amazon itself warns that Italian registration takes weeks, and other providers quote between six and sixteen. We cannot guarantee CONAI's timing.
What if I have been selling into Italy for a while already?
Then past periods may have to be declared, which is quoted separately because the work depends on how far back it goes. It is cheaper handled deliberately than discovered later.
Is the fee really flat?
Yes. No volume tiers, no setup fee, no charge per marketplace. The one thing that varies is what CONAI charges for your kilos, and that is CONAI's, not ours.
I sign up in October. Do I pay again on 1 January?
Yes. €199 covers the calendar year you join in, to 31 December, whatever the date you start, and renews at €199 on 1 January. There is no pro rata.
Is VAT added to the €199?
€199 is before VAT. A business in another EU country that gives its VAT number, or a business outside the EU, is invoiced without VAT. The invoice states the VAT treatment.
Are these prices comparable?
Only with the second table. One provider's price includes 250 kg of paper and 50 kg of plastic, another's entry price is limited to Amazon and 500 kg a year, a third adds a setup fee. The year-one column and the inclusions table exist to make the comparison honest.
How often is this checked?
Each figure carries the date it was read. A price reported by a third party rather than read at the provider's own page is marked as such.
Can I reuse these tables?
Yes, with attribution to epritalyrep.com. They exist to be quoted.
Why publish competitors' prices?
Because a buyer's first question is what this costs, and the honest answer requires the whole market, not one row. We sell representation, so check every competing figure at its source — each row links to it.