Export exemptions

Exported packaging (whose waste is managed abroad) are not covered by CONAI and are therefore exempt from the EPR fee. CONAI has set out various exemption procedures:

• an ordinary procedure (ex post) that consists of documenting the final total of exported quantities (by single material) and requires refund of the EPR fee paid for these quantities;
• a simplified procedure (ex ante) that determines export quantities per single material over the course of the calendar year in advance and does not require payment of the EPR fee on this amount. For the purposes of determining the exemption ceiling, as an alternative to the existing calculation method based on quantities by weight of each individual material (total exported/sold), percentage ratios of export values in Euros over turnover (drawn from VAT declarations) can be taken as the basis of reference.
• Companies which both import and export packaging/packaged goods, can also use an import/export compensation procedure as an alternative to the two previous procedures.

Companies using the simplified procedures for their EPR declaration to Conai (based on the value or tare of the imported goods) for a yearly total of up to 25,000 Euros, for filled packaging exports undertaken from 1.1.2024, can apply for an EPR fee refund. The sum to be refunded is calculated on the basis of the percentage of total turnover (Italian and foreign) accounted for by foreign turnover, to be applied to the EPR fee declared in the same year with the aforementioned simplified procedures.

Net exporting companies can take advantage of simplified procedures which entitle them to specific exemptions from Conai EPR fee declarations.

Empty or filled packaging (packaged goods) intended, from the time of their purchase/import, to be fully exported, can be subject to full exemption of the CONAI EPR Fee.

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