CONAI importazione imballaggi: procedure, aliquote 2026 e scadenze

Italy packaging EPR: CONAI rules, 2026 rates and deadlines for importers

FRIDAY, 13 NOVEMBER 2026

Companies importing goods already packed must declare the packaging to CONAI: form 6.2, the ordinary weight-based procedure or the simplified 0.11% of value, exemption thresholds, deadlines, voluntary disclosure and an example on 400,000 euro of promotional items.

Italy packaging EPR: a company that buys goods abroad already packed and sells or uses them in Italy must declare to CONAI the packaging that enters with the goods and pay the environmental contribution. It can be calculated on the actual weight by material or, under a simplified procedure, on the value of the goods (0.11% for non-food products from 1 October 2026) or on the total weight of the packaging (131 euro per tonne).

For companies importing consumer goods, promotional items or components from China and Asia, it is an obligation often discovered late, sometimes during an audit. This guide explains who is liable, the difference between empty and filled packaging, how the ordinary and simplified procedures work, the exemption thresholds, the deadlines, a worked example with figures and what happens to those who do not declare.

Italy packaging EPR: who is liable

Italy's Environmental Code, Legislative Decree 152/2006 in Article 221, requires producers and users of packaging to join the national packaging consortium, CONAI, or a recognised alternative scheme. The CONAI guide starts from a simple point: almost every import of goods is also an import of packaging, because the goods arrive in boxes, bags, film, pallets and straps that in Italy will become waste to be collected and recycled.

This is why an importer of filled packaging is treated as the party that first places that packaging on the Italian market. It applies in both cases CONAI describes: when the goods are resold together with their packaging, and when the company uses them directly and throws the packaging away at once. The importer registers in the users category, stating its sector (food, chemical or other), and from then on files periodic declarations and pays the contribution for each material.

Empty and filled packaging: form 6.1 and form 6.2

The distinction decides which form to use. A company importing empty packaging, for example boxes or bags it will fill in Italy, declares it on form 6.1. A company importing filled packaging, meaning goods already packed in primary, secondary and tertiary packaging, uses form 6.2. A company doing both files both forms. The simplified procedures described below apply only to filled packaging: empty packaging is always declared by actual weight.

Ordinary procedure: weight by material

The ordinary procedure is the general rule. The packaging that entered during the period is weighed, split by material (steel, aluminium, paper, wood, plastic, compostable plastic, glass) and, for paper and plastic, by contribution band, then each weight is multiplied by the contribution in euro per tonne. For 2026 the CONAI guide sets 5 euro per tonne for steel, 12 for aluminium, 40 for glass and 45 for single-material paper packaging such as corrugated board.

Plastic is the most expensive material and the one that changes most. There are nine bands, depending on how recyclable the packaging is and which stream collects it: in the table in force at the start of 2026 they ranged from 40 to 790 euro per tonne, and from 1 October 2026 the contribution rose in all nine. The exact weight comes from the supplier's product sheets or from weighing a sample of packs, and it is the figure needed to handle the other packaging obligations properly as well.

Simplified procedures: by value or by tare

When weighing the packaging is genuinely difficult, CONAI allows a flat-rate calculation. The conditions are precise: filled packaging only, and only where there are objective technical reasons, such as a large number of product codes or foreign suppliers, or the impossibility of obtaining product sheets. The guide explicitly rules out that the mere difficulty of separating plastic packaging flows is enough to justify them. The rates in force are these:

simplified by value, non-food products: 0.11% of the value of imported goods from 1 October 2026, against 0.10% until 30 September;
simplified by value, food products: 0.25% from 1 October 2026, against 0.19% until 30 September;
flat rate by tare: 131 euro per tonne on the total weight of the packaging from 1 October 2026, against 110 euro from 1 July and 109 euro from January;
basis of the value procedure: the purchase value of the packed goods net of VAT and transport costs;
basis of the tare procedure: gross weight minus the net weight of the goods, with no split by material or between primary, secondary and tertiary packaging.

The chosen procedure applies to the whole calendar year and cannot be changed midway. CONAI checks that the simplifications are used correctly: applying them to imports of a single product or a single material in order to pay less than due is treated as a serious breach of consortium obligations.

The flat fee for small companies

There is a third route, reserved for companies with turnover up to 2 million euro: a fixed contribution by turnover band of the previous year, with an annual declaration only. Below 200,000 euro of turnover the exemption is total. The amounts for each band are set in that year's CONAI guide and should be checked every year, because they change along with the other contributions.

Thresholds, declaration classes and deadlines

Not everyone has to file monthly. The frequency depends on the previous year's contribution. Under the ordinary procedure no declaration is due up to 200 euro of contribution per material; under the simplified procedures up to 300 euro of total contribution. Up to 3,000 euro the declaration is annual and is filed by 20 January of the following year; above that it becomes quarterly and, for higher amounts, monthly.

Periodic declarations are due on the 20th of the month after the period: for quarterly filers on 20 April, 20 July, 20 October and 20 January. The class is checked at the end of each calendar year and does not change during the year. Even companies within the exemption must check every year that they have not crossed the threshold.

Worked example: 400,000 euro of imported promotional items

Take a hypothetical case. An Italian company imports promotional items from China during the year, non-food products, worth 400,000 euro net of VAT and transport. The packaging weighs 5.5 tonnes in total: 4 tonnes of cartons and 1.5 tonnes of plastic bags and film.

Under the simplified value procedure the contribution is 400,000 x 0.11% = 440 euro. Under the flat rate by tare it is 5.5 x 131 = 720.50 euro. Under the ordinary procedure the cartons cost 4 x 45 = 180 euro; for the plastic we assume, for this example only, a band of 300 euro per tonne, so 1.5 x 300 = 450 euro, for a total of 630 euro.

Here the value procedure costs least, but it can only be used if the technical reasons above apply, and it holds for the whole year. With a contribution below 3,000 euro the declaration is annual, by 20 January. The result changes a lot with the type of goods: a light, expensive item weighs little but has a high value, while a bulky, cheap item is the opposite.

Mistakes and penalties: what non-declarers risk

A liable company that joins neither CONAI nor an alternative scheme faces the 5,000 euro administrative fine under Article 261 of Legislative Decree 152/2006, and must still pay the membership fee and the back contributions. On top of this come the consortium's own penalties for missing or incorrect declarations, calculated in proportion to the sums due and heavier for repeat breaches.

There is, however, a way to regularise: voluntary disclosure. If the company informs CONAI of its position on its own initiative before an audit starts, declares the contribution due within 30 days and pays it by the due date of the consortium's invoices, no penalties apply, only late-payment interest. For a company that discovers the obligation after years of imports, it is almost always the cheaper choice.

Italy packaging EPR in brief

Before the next order from abroad it is worth checking these points:

whether the company is registered with CONAI as a user, and under which sector;
which forms are needed: 6.1 for empty packaging, 6.2 for goods already packed;
which procedure to use for the year: ordinary by weight, simplified by value or by tare, or the flat fee if turnover is below 2 million;
whether the supplier can state, for each item, the weight and material of the box, bag and outer packaging;
which declaration class and deadlines apply, starting from the previous year's contribution.

With La Merce, an order of promotional items from China arrives with the weight and material of every piece of packaging already stated by the supplier on the packing list, so the choice between 0.11% of value and the actual-weight calculation is made with the figures in hand.