Packaging EPR in Italy: CONAI and importer roles

The direct answer

First identify who imports and supplies the packaged goods in Italy. CONAI obligations depend on the actual supply and sales model.

What to check

Assess roles individually

CONAI distinguishes producers and packaging users, including importers of packaged goods. It describes specific routes for foreign companies and platform models. CONAI · membership and obligated entities

Declaration and contribution

Reporting depends on the import type and applicable conditions. CONAI describes ordinary and simplified procedures and material-dependent reporting frequency. CONAI · declaration and payment

Account for PPWR separately

Use CONAI materials alongside a current PPWR assessment. Earlier national procedures alone do not resolve every cross-border sales question. European Commission · PPWR FAQ, 3 August 2026

Your action plan

The following steps are our suggested way to organise your project.

Map the supply chain through to the Italian customer.
Clarify importer, brand owner and platform model before selecting contracts.
Prepare material weights per item and document the calculation.
Set a reporting cycle and reconcile it with invoices.

Prepare your records

Supply contracts, import records, packaging materials, weights and existing CONAI documents.

Frequently asked questions

Is a German LUCID number sufficient?

No. Assess the Italian supply chain and its obligations separately.

Does SINNO quote a universal fee?

A reliable quotation needs the sales model, product stream and volumes. Scheme contributions and external services are assessed separately.

Sources and scope

This guide covers the product stream described. Check other EPR streams separately; your supply chain and sales model determine the specific obligations.

SINNO GmbH is your contact in Germany. We can consolidate tasks and coordinate suitable external providers. Local representation, approved schemes and any required guarantees are agreed separately for each project.