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Amazon Pay on Behalf in Italy: is it enough?

Pay on Behalf pays the EPR contribution for the units Amazon covers. Since 12 August 2026 Amazon still asks for your own registration number for Italy. How the two fit together without paying twice.

Last checked: 14 October 2026 — the date every statement on this page was checked against the sources below.

Quick answer

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.

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.

Razvan Toma
Who wrote thisRazvan Toma

Razvan Toma is the founder of EPR Italy Rep, and of EPR France Rep, EPR Germany Rep and EPR Spain Rep. Every page here is written from CONAI, the law or the marketplace's own page, never from another provider's marketing.

Razvan on LinkedIn ↗

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.