Special cases
In order to simplify its Consortium members’ procedures, with a view to adapting them to specific sector needs, CONAI developed a number of special procedures for EPR fee declaration, application and/or exemption for special sectors, as well as for specific packaging items or packaging flows, listed as follows:
- Primary packaging for medical devices
(exempt if used in public or private healthcare facilities).
- Primary packaging for pharmaceutical products
(exempt if used in public or private healthcare facilities or products disposed of through the ASSINDE circuit).
From 2018 onwards new ex-post exemptions are planned (in addition to the ex-ante procedures) for companies buying primary packaging for direct contact with the above products.
- Flat rate for the CONAI EPR fee on labels (simplified EPR fee declaration procedure).
Warning: The methods of application of the simplified procedure and lump sum fees for the year 2025 will be communicated as soon as they are defined by the Consortium Bodies.
- Flat rate for the CONAI EPR fee on cork packaging
(simplified EPR fee declaration procedure).
- Aluminium foil – cling film for foods
(from 1 January 2020 changes are planned for the EPR fee application, exemption and declaration for rolls of aluminium foil and cling film, intended exclusively for domestic use).
- Disposable tableware (plates and cups)
(exemptions for purchase of disposable tableware in packages exclusively for domestic use).
- “Small traders” of empty packaging, producers selling packaging in other materials to “complete ranges or packaging” and transformers performing minimal processing on finished packaging purchased without adding further materials which impacts on its weight
(incentivised procedure for application of the EPR Fee)
- Adhesive tapes and gummed paper
(application of the EPR fee on 50% of the weight of the adhesive tape).
- Refillable and non-refillable containers used for various kinds of gas
- Valves for aerosol tanks and dispensers
- Mechanical dispensers
- Multi-material tanks, plastic or steel drums regenerated and returned to the Italian market
(simplified procedure – flat rate fee on number of pieces)
- Reusable packaging employed in production cycles or commercial networks
- Reusable packaging employed in special circuits
(incentivised formulas)
- Wooden pallets returned to the market and new pallets structurally designed for multi-year reuse. Repair of pallets owned by third parties
(incentivised formulas)
- Rolls, tubes and cylinders around which flexible material is wound
- Emptiable beverage system capsules
- Simplified procedure for the application of the CONAI EPR fee for companies that handle items classified as packaging and non-packaging, like flower pots, garment hangers, beverage system capsules, cake doilies, etc., examples outlined in Annex E of Legislative Decree 152/2006
- Dishwasher and air freshener shells-containers
- Goods display stands
- Black annealed wire for packaging
- Small packaging
- Bundle handle straps
- Self-produced packaging waste scraps
- Plastic flower/plant pots functioning as packaging (The effects of the CONAI Circular of 14/12/2022 were suspended from 1 July 2023 until 28 February 2025)
- Packaging made of “regenerated cellulose” and “chemically modified cellulose”
In fact, simplification involves ongoing development of more effective criteria that can be applied on a case-by-case basis, preventing involuntary penalizations, or distortions and evasions within a system that is under constant transformation.
This takes the form of constant discussion with companies and the associations representing them, whose own management experiences become the direct expression of the most effective operative criteria. For this reason it is important that companies contribute to the honing of procedures by providing economic-statistical analyses representing markets of reference, periodically updated and redrafted on the basis of concrete experience.
For further information please consult the Guide to CONAI membership and EPR fee application.