Who is the producer of packaging in Italy?

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

Quick answer

Whoever first makes the packaged product available in Italy. If you ship to Italian consumers, that is you, whether Amazon ships for you (FBA) or you ship yourself. If an Italian business buys from you and resells, that business is. A business that uses the goods itself is an end user, so you remain the producer.

The marketplace seller

Selling on Amazon.it, FBA or FBM, you are the one placing the goods on the Italian market. Amazon ships them; that does not make Amazon the producer. Amazon asks for your registration number for exactly that reason.

The reseller

If you buy goods already placed on the Italian market by your supplier, the supplier carries the obligation for that packaging. Amazon lets such a seller enter the supplier's number. The same is true in reverse: if your Italian customer buys and resells, they are the producer for those goods.

The B2B supplier

A business that uses your goods itself — in its own production, office or shop fit-out — is an end user. You place the goods on the Italian market, so the obligation stays with you.

Your own shipping box

The box, tape, filling and labels you add count too. They are packaging you place on the Italian market with the goods.

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.

Regulation (EU) 2025/40 (PPWR), Article 45 — read 2026-10-14
CONAI — Soggetti obbligati e modalità di adesione — read 2026-10-14
Amazon.it Seller Forums — “EPR ITALIA”, Amazon moderator reply, 4 August 2026 — read 2026-10-14

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 ↗