Last checked: 14 October 2026 — the date every statement on this page was checked against the sources below.
CONAI says a foreign company selling to Italy from its own shop has no obligation towards CONAI today, but may join. The PPWR now requires a producer selling directly to Italian end users without an Italian establishment to appoint an authorised representative. Joining CONAI with a representative's address covers both, and gives you the number to show buyers and marketplaces. Sources (4)CONAICONAI — FAQ: imprese estereD.Lgs. 152/2006, art. 178-quD.Lgs. 152/2006, art. 178-quater — e-commerce platformsRegulation (EU) 2025/40 (PPWRegulation (EU) 2025/40 (PPWR), Article 45Legge 17 marzo 2026, n. 36 (Legge 17 marzo 2026, n. 36 (legge di delegazione europea 2025), art. 14
No platform, no simplified route
Art. 178-quater D.Lgs. 152/2006 gives marketplace sellers the option of the platform's simplified arrangement. A Shopify store has no such arrangement: you either join CONAI voluntarily or rely on the position that, under CONAI's current rules, a foreign own-shop seller has no CONAI obligation.
What the PPWR changes
Since 12 August 2026 the PPWR requires an authorised representative for producers selling directly to end users in a member state where they are not established. Italy's decree on how that works in Italian law is still pending. A representative appointed now, with a CONAI membership in place, is ready for it.
If you sell both on Amazon and from your shop
One CONAI membership covers both channels. If you keep Pay on Behalf for Amazon units, only your own-shop volumes are declared to CONAI. See Pay on Behalf.
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.
- CONAI — FAQ: imprese estere — read 2026-10-14
- D.Lgs. 152/2006, art. 178-quater — e-commerce platforms — read 2026-10-14
- Regulation (EU) 2025/40 (PPWR), Article 45 — read 2026-10-14
- Legge 17 marzo 2026, n. 36 (legge di delegazione europea 2025), art. 14 — read 2026-10-14
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 ↗