Who needs an Italian EPR representative?

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

Two rules, one practical answer

Two sets of rules meet in Italy, and it helps to keep them apart.

• The PPWR. Since 12 August 2026, Article 45(3) of Regulation (EU) 2025/40 requires a producer to appoint an authorised representative in every member state where it sells directly to end users and is not established. That includes Italy.
• Italian packaging law. Article 221 of D.Lgs. 152/2006 makes producers and users of packaging join CONAI, the national packaging consortium, and pay its environmental contribution.

Italy has not yet adopted the decree that adapts its law to the PPWR: L. 36/2026, art. 14, gives the Government eight months from 9 April 2026, so until about December 2026. Until then CONAI's existing rules decide the practical steps.

What CONAI says about foreign companies

CONAI's own FAQ: a foreign company, “salvo che immetta prodotti imballati sul mercato nazionale mediante piattaforma di commercio elettronico, a oggi, non ha obblighi nei confronti del CONAI ma ha la facoltà di aderire allo stesso Consorzio” (“unless it places packaged products on the national market through an e-commerce platform, has at present no obligations towards CONAI but may join the Consortium”), electing a special domicile in Italy. And for marketplace sellers, under art. 178-quater D.Lgs. 152/2006: they may use the platform's simplified arrangement, and if they do not, they must join CONAI.

• You sell on Amazon.it or another marketplace. Use the platform's arrangement, such as Pay on Behalf, or join CONAI. Amazon asks for your own registration number either way — see the Amazon guide.
• You sell from your own shop. No CONAI obligation today, but the PPWR now requires a representative for direct sales to end users, and joining CONAI is how you get the number marketplaces and buyers ask for.

What is not an establishment

None of the following makes you established in Italy:

• an Italian VAT registration, or an OSS registration covering Italy;
• stock held in an Italian warehouse, including an Amazon fulfilment centre;
• an Italian bank account, a .it domain or an Italian-language shop;
• an Italian agent, distributor or customer.

Who receives the goods decides the rest

• You ship to consumers or end users in Italy. You place the goods on the market, so the obligations are yours.
• You sell to an Italian business that buys on its own account and resells. That business places the goods on the Italian market. Get it confirmed in writing; any direct sales you also make remain yours. See who is the producer.

There is no threshold

Neither the PPWR nor Italian law sets a minimum volume for being a producer. CONAI's thresholds decide how often you declare, not whether you are in scope.

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
• D.Lgs. 3 aprile 2006, n. 152 (Testo unico ambientale), art. 221 — read 2026-10-14
• D.Lgs. 152/2006, art. 178-quater — e-commerce platforms — read 2026-10-14
• CONAI — FAQ: imprese estere — read 2026-10-14
• CONAI — Soggetti obbligati e modalità di adesione — read 2026-10-14
• Legge 17 marzo 2026, n. 36 (legge di delegazione europea 2025), art. 14 — 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 ↗