Last checked: 14 October 2026 — the date every statement on this page was checked against the sources below.
No, not on its own. Pay on Behalf pays the contribution for the units it covers, but since 12 August 2026 Amazon asks for your own packaging registration number for Italy even if you use Pay on Behalf. For Italy that is the CONAI number. You can keep Pay on Behalf for Amazon units and declare only the rest to CONAI, so nothing is paid twice. Sources (4)Amazon.it Seller ForumsAmazon.it Seller Forums — “EPR ITALIA”, Amazon moderator reply, 4 August 2026Amazon Seller CentralAmazon Seller Central — EPR Pay on Behalf in ItalyEPR RatesEPR Rates — Amazon pay-on-behalf vs provider vs doing it yourself (checked 1 Sep 2026)D.Lgs. 152/2006, art. 178-quD.Lgs. 152/2006, art. 178-quater — e-commerce platforms
What Pay on Behalf does
Amazon's EPR Pay on Behalf (“Paga per conto mio”) pays the EPR contribution for the units it covers, for a fee: €25 per EPR category per year since 1 January 2026, on top of the contribution itself. It relies on the simplified arrangements that art. 178-quater D.Lgs. 152/2006 allows between platforms and EPR systems.
What it does not do
- It does not give you a CONAI number — and Amazon asks for one anyway.
- It does not cover your own shop, eBay, Kaufland or any other channel.
- It does not make anyone your representative under the PPWR.
Using both without paying twice
Keep Pay on Behalf for Amazon units if you like it. We get your CONAI number, enter what Amazon has already paid for as covered, and declare to CONAI only what Amazon did not. If you drop Pay on Behalf, we declare everything.
We are not lawyers. Where Italian practice is unsettled, this is our reading of the rules, not legal advice.
Sources
Every claim above comes from one of these. Primary law and the competent authority first; no provider marketing pages.
- Amazon.it Seller Forums — “EPR ITALIA”, Amazon moderator reply, 4 August 2026 — read 2026-10-14
- Amazon Seller Central — EPR Pay on Behalf in Italy — read 2026-10-14
- EPR Rates — Amazon pay-on-behalf vs provider vs doing it yourself (checked 1 Sep 2026) — read 2026-10-14
- D.Lgs. 152/2006, art. 178-quater — e-commerce platforms — read 2026-10-14
- CONAI — Soggetti obbligati e modalità di adesione — read 2026-10-14
