EPR fee

The CONAI EPR fee constitutes a form of funding via which CONAI distributes the cost for separate collection, recycling and recovery of packaging waste charges between producers and users. These costs are distributed “in proportion to the total quantity, weight and the type of packaging material placed on the national market” based on the provisions set out in Legislative Decree 152/06.

The EPR Fee is determined by the Board of Directors of CONAI and has been in effect since 1 October 1998.

In 2016, the Board approved the fee modulation project starting with plastic packaging with the aim of using the fee leverage to encourage the use of more recyclable packaging.

Fee modulation came into effect on 1 January 2018 for plastic packaging and on 1 January 2019 for paper and cardboard packaging.

In the past, some incentivised procedures were introduced for reusable packaging in controlled and particularly virtuous circuits from the environmental point of view.

EPR Fees for 2025:

* With reference to paper material, the following are considered:

• Single-material paper packaging, packaging consisting exclusively of cellulose material, as well as those laminated with other materials, in which the weight of the non-cellulose material is, in any case, lower or equal to 5% of the total weight of the packaging.
• Type A Composite Packaging, packaging laminated with other materials, where the weight of the paper component is ≥ 90% and < 95% of the total weight of the packaging;
• Type B Composite Packaging, packaging laminated with other materials, where the weight of the paper component is ≥ 80% and < 90% of the total weight of the packaging;
• Type C Composite Packaging, packaging laminated with other materials, where the weight of the paper component is ≥ 60% and < 80% of the total weight of the packaging;
• Type D Composite Packaging, packaging laminated with other materials, where the weight of the paper component is < 60% of the total weight of the packaging or non-explicit;
• CPL, mainly paper-based composite containers suitable for containing liquids.

** The EPR Fee for glass packaging will increase to €40.00/t from 1 January 2026.

Consortium regulations state that the sums owed by all Consortium members, producers and users are always collected on the basis of the specific invoiced amount due according to the weight and type of packaging material covered by the first transfer.

The first transfer shall mean the transfer, however temporary and in whatever capacity, within Italy of:

• finished packaging by the last producer or empty packaging trader to the first user, other than the empty packaging trader;
• packaging material performed by a “producer of virgin raw material (or semi-finished products)” to an existing or self-declared “self-producer”.

From 1 January 2019 – as a result of certain changes to the Consortium’s Articles of Association and Regulations, the “first transfer” also encompasses transfers of packaging from the last empty packaging trader to the first effective user (i.e. the subject who purchases/receives the packaging for their own goods), thus transferring the CONAI EPR fee collection point.

In order to assist empty packaging traders managing packaging flows that are not significant in weight terms, referred to as “small traders”, CONAI introduced a incentivised procedure on 1 January 2019. This procedure was updated, introducing an additional facilitation (effective 1 January 2024) for “small traders” that purchase empty packaging abroad. Please consult the CONAI Circular dated 29.11.2018.

Moreover, the Consortium regulations state that any packaging materials and packaging imported from abroad shall be subject to the EPR fee on the grounds that their use will produce waste in Italy.

Taxation issues

The CONAI EPR fee shown on the invoice shall be considered a fee for additional services, pursuant to articles 12 and 13 of Italian Presidential Decree 633/1972 and as such:

• VAT is applicable;
• it is to be assessed for the purposes of mandatory electronic invoicing brought in by article 1, paragraph 909 and subsequent of law 205 dating to 27 December 2017.

For further information consult the Guide to CONAI membership and EPR fee application