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Italy EPR in 2026: CONAI, CDC RAEE and Battery Compliance for Marketplace Sellers

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Italy EPR in 2026: CONAI packaging, Registro AEE filing by 3 July, the new battery decree 29/2026 and PPWR marketplace checks from 12 August 2026.

By Operator One Editorial — 2026-06-14

Key takeaways

  • Italy's battery law changed in 2026: Legislative Decree 29/2026, in force from 7 March 2026, repealed Legislative Decree 188/2008 (with transitional exceptions) and created a new battery producer register at the Chambers of Commerce, with annual data due by 31 March.
  • The Italian Registro AEE annual communication for electrical and electronic equipment placed on the market in 2025 was due by 3 July 2026, and placing equipment on the Italian market without enrolment is fined EUR 30,000 to EUR 100,000 under Article 38 of Legislative Decree 49/2014.
  • From 12 August 2026, Article 45(4) to (6) of the EU Packaging and Packaging Waste Regulation (EU) 2025/40 requires online platforms to obtain a producer's EPR registration number and a self-certification, and to make best efforts to assess them, before letting that producer sell to EU consumers.
  • Article 45(3) of Regulation (EU) 2025/40 requires a producer that sells packaged products directly to end users in a member state other than its own to appoint, by written mandate, an authorised representative for extended producer responsibility in that member state.
  • CONAI declaration frequency in Italy follows the prior year's environmental contribution: under the ordinary procedure it is exempt up to EUR 200 per material, annual up to EUR 3,000 (due 20 January), quarterly up to EUR 31,000 (due 20 April, 20 July, 20 October and 20 January), and monthly above EUR 31,000 (due by the 20th of each month).
  • Under Article 13 of the EU Battery Regulation (EU) 2023/1542, capacity and general information labels apply from 18 August 2026 (or 18 months after the implementing act, if later), and the battery QR code applies from 18 February 2027.

Italy's Extended Producer Responsibility (EPR) regime is, in 2026, one of the more demanding in the EU. Two things changed this year: Italy replaced its battery law with Legislative Decree 29/2026, and the EU Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) started to apply on 12 August 2026, putting a legal duty on online platforms to collect packaging EPR registration data before a producer can sell. A non-resident seller can no longer treat CONAI, the Registro AEE and the battery register as paperwork to chase after the first invoice. This article walks through the three pillars of Italian EPR (packaging, electrical and electronic equipment, and batteries), what a foreign brand has to produce, in what order, and where the most expensive mistakes sit.

The packaging pillar: CONAI

CONAI, the Consorzio Nazionale Imballaggi, is Italy's national packaging consortium under Legislative Decree 152/2006. Producers and users of packaging in Italy must either join CONAI and the material consortia or run an approved alternative system. Article 261(2) of Legislative Decree 152/2006 sets an administrative fine of EUR 15,500 to EUR 46,500 for a packaging producer that neither organises its own system, joins a consortium under Article 223, nor adopts a return system. Article 261(3) adds a fine of EUR 5,000 to EUR 25,000 for placing packaging on the Italian market without the environmental labelling required by Article 219(5).

The contribution itself, the Contributo Ambientale CONAI (CAC), is calculated per packaging material on quantities declared to CONAI. According to CONAI's 2026 Guide, under the ordinary procedure the frequency depends on the total contribution per material in the previous calendar year:

  • Exempt: prior-year CAC of up to EUR 200 per material, with no declaration to file.
  • Annual: prior-year CAC of up to EUR 3,000 per material, with one declaration due by 20 January of the following year.
  • Quarterly: prior-year CAC of up to EUR 31,000 per material, with four declarations due 20 April, 20 July, 20 October and 20 January.
  • Monthly: prior-year CAC above EUR 31,000 per material, with twelve declarations due by the 20th of each month.

From 12 August 2026 the EU layer sits on top of the Italian one. Article 44 of Regulation (EU) 2025/40 obliges producers to register in each member state where they first make packaging or packaged products available, and Article 44(4) prohibits making them available where the producer (or its authorised representative) is not registered. Under Article 45(3), a producer that makes packaging or packaged products available directly to end users in a member state other than the one where it is established must appoint, by written mandate, an authorised representative for extended producer responsibility in that member state, and member states may require producers established in third countries to appoint one as well. Article 44(1) gives member states 18 months from the Commission's first implementing act on registration to set up their national registers.

The WEEE pillar: Registro AEE and CDC RAEE

For sellers of electrical and electronic equipment (EEE), Italian compliance involves two bodies that are often confused.

  • Registro AEE is the national register of EEE producers under Article 29 of Legislative Decree 49/2014, operated through the registroaee.it portal and the Chambers of Commerce. Producers must enrol before they start operating in Italy, and the registration number must appear on all commercial documents within thirty days of issue. The Chamber of Commerce of Turin lists enrolment costs of EUR 30 in secretarial fees, EUR 16 stamp duty and EUR 168 government concession tax.
  • CDC RAEE, the Centro di Coordinamento RAEE under Article 33 of Legislative Decree 49/2014, is a consortium that collective and individual WEEE management systems must join. It coordinates the collection of WEEE from collection points across Italy. Producers do not enrol with it directly; they enrol in the Registro AEE and meet take-back obligations through a management system that is a member of the Centro di Coordinamento.

Under Article 30(1) of Legislative Decree 49/2014, a producer with its registered office in another EU member state may designate, by written mandate, an authorised representative established in Italy, who is then responsible for meeting the producer obligations under the decree.

The annual communication of EEE placed on the Italian market is not fixed by statute to a single calendar day. For equipment placed on the market during 2025, the Chambers of Commerce set the deadline at 3 July 2026, with the portal open from 30 March 2026. The communication is required even when the quantity placed on the market was zero, and no secretarial fee is due for it. Article 38 of Legislative Decree 49/2014 fines a producer EUR 30,000 to EUR 100,000 for placing EEE on the market without enrolment, and EUR 2,000 to EUR 20,000 for failing to communicate data within the deadline. A catalogue in which variants carry a plug, battery, sensor or wireless component should be screened SKU by SKU for EEE scope.

The battery pillar: Legislative Decree 29/2026

Italy's battery regime was rewritten in 2026. Legislative Decree 29 of 10 February 2026, published in Gazzetta Ufficiale no. 54 on 6 March 2026 and in force from 7 March 2026, adapts Italian law to the EU Battery Regulation (EU) 2023/1542. Article 37 repeals Legislative Decree 188/2008, with transitional exceptions.

  • Register. Article 20 creates the Registro dei produttori di batterie, which replaces the register under Legislative Decree 188/2008. Producers that first make batteries available on the Italian market, including batteries incorporated in appliances, light means of transport or other vehicles, must enrol online at the competent Chamber of Commerce. Under Article 35(4), the old register stays active until the new one is fully implemented.
  • Annual data. Article 21(3) requires producers to communicate the batteries placed on the Italian market in the previous calendar year by 31 March each year. For 2025 volumes that deadline was 31 March 2026.
  • Distance sellers. Article 25(4) requires a producer that sells batteries (including embedded ones) by distance contract directly to end users in Italy while established in another member state or in a third country to designate, by written mandate, an authorised representative for extended producer responsibility.
  • Coordination centre. Article 22 establishes the Centro di coordinamento batterie, which under Article 35(2) continues to operate under the previous rules until its statute is approved. As with CDC RAEE, it coordinates the collection systems; it is not the producer register.

Article 34 of Legislative Decree 29/2026 sets the sanctions: EUR 36,000 to EUR 120,000 for placing batteries on the market without enrolment in the producer register (Article 34(5)(b)); EUR 2,400 to EUR 24,000 for failing to file, or filing late, the annual communication, halved for inaccurate or incomplete data (Article 34(3)(c)); and EUR 10,000 to EUR 150,000 for labelling breaches (Article 34(1)).

Labelling follows Article 13 of Regulation (EU) 2023/1542. The separate collection symbol has applied since 18 August 2025. The general information label, capacity labels for rechargeable portable, LMT and SLI batteries, and minimum average duration labels for non-rechargeable portable batteries apply from 18 August 2026 or 18 months after the implementing act on labelling specifications, whichever is later. The QR code applies from 18 February 2027.

For a seller of, say, a wireless headset, three Italian EPR families apply at once: the carton triggers CONAI, the device triggers the Registro AEE, and the lithium-ion cell triggers the battery producer register.

Marketplace verification: what the law now requires

Since 12 August 2026, Article 45(4) of Regulation (EU) 2025/40 requires providers of online platforms that let consumers conclude distance contracts with producers to obtain, before allowing a producer to use the service:

  • the producer's registration details and registration number in the packaging producer register of the member state where the consumer is located (for Italian consumers, Italy); and
  • a self-certification that the producer only offers packaging for which the EPR requirements are met in that member state.

Under Article 45(6), the platform must make best efforts to assess whether that information is complete and reliable. Articles 45(7) and 45(8) extend a similar check to fulfilment service providers at the moment the fulfilment contract is concluded. For textiles, Directive (EU) 2025/1892 inserts an equivalent platform duty in Article 22a(13) of the Waste Framework Directive, with member states required to establish textile EPR schemes by 17 April 2028.

In Operator One's experience, Italian marketplace onboarding for electronics and battery-containing products also asks for the Registro AEE and battery register numbers. The documents each marketplace requests are set by the marketplace, not by Italian law, and vary between platforms.

Common compliance gaps

  • Treating CONAI as one-off. Membership is ongoing, but the contribution is declared periodically (annually, quarterly or monthly by prior-year CAC), so missed declarations are an ongoing breach, not a historical one.
  • Confusing Registro AEE with CDC RAEE. Joining a compliance system is not enough: the producer must also be enrolled in the Registro AEE under Article 29 of Legislative Decree 49/2014, and it is the registration number that must appear on commercial documents.
  • Forgetting embedded batteries. Toys, garden tools, beauty devices, scooters and fitness equipment often contain batteries. Article 20(4) of Legislative Decree 29/2026 expressly covers batteries incorporated in appliances, light means of transport and other vehicles.
  • Using a VAT fiscal representative as an EPR representative. For EEE (Article 30 of Legislative Decree 49/2014) and batteries (Article 25(4) of Legislative Decree 29/2026), the authorised representative carries EPR obligations under a specific mandate. A fiscal representative appointed only for VAT does not automatically discharge them.
  • Working to stale deadlines. The Registro AEE communication for 2025 volumes was due 3 July 2026, not 30 April; battery data is due 31 March under Article 21(3) of Legislative Decree 29/2026; CONAI periodic declarations are due by the 20th of the following month.
  • Ignoring the textile pipeline. Directive (EU) 2025/1892 must be transposed by 17 June 2027 and requires textile and footwear EPR schemes by 17 April 2028, so apparel and footwear sellers in Italy should plan for a fourth stream.

How to register for Italian EPR, step by step

  1. Map the catalogue to Italian EPR streams. Classify every SKU for packaging (CONAI), electrical and electronic equipment (Registro AEE) and batteries (battery producer register), including batteries built into products.
  2. Identify the producer and any authorised representative. Establish which legal entity first makes the goods available in Italy, and whether it must appoint an Italian EPR authorised representative under Article 45(3) of Regulation (EU) 2025/40, Article 30 of Legislative Decree 49/2014 or Article 25(4) of Legislative Decree 29/2026.
  3. Join CONAI and set the declaration frequency. Adhere to CONAI and declare the Contributo Ambientale annually, quarterly or monthly according to the prior year's contribution, by the 20th of the following month.
  4. Enrol in the Registro AEE before selling EEE. Register through registroaee.it (EUR 30 secretarial fee, EUR 16 stamp duty, EUR 168 concession tax), join a WEEE management system and show the registration number on commercial documents within thirty days.
  5. Enrol in the battery producer register before selling batteries. File the online application at the competent Chamber of Commerce under Article 20(4) of Legislative Decree 29/2026 and meet take-back obligations individually or through a collective system.
  6. Give registration data to platforms and fulfilment providers. Provide the Italian registration number and self-certification required by Article 45(4) and 45(7) of Regulation (EU) 2025/40 before trading.
  7. Calendar the recurring filings. Diary CONAI declarations, the battery communication by 31 March and the Registro AEE communication on the date set each year (3 July 2026 for 2025 volumes).

Frequently asked questions

Do I need to join CONAI to sell packaged goods into Italy?

In most cases, yes. Under Legislative Decree 152/2006, packaging producers and users in Italy must join CONAI or run an approved alternative system. Article 261(2) sets an administrative fine of EUR 15,500 to EUR 46,500 for a packaging producer that neither organises its own system, joins a consortium, nor adopts a return system. From 12 August 2026, Regulation (EU) 2025/40 also requires registration in each member state where packaging is first made available.

How often are CONAI declarations filed?

CONAI sets declaration frequency by the Contributo Ambientale declared for the previous year. Under CONAI's 2026 Guide (ordinary procedure, per material), up to EUR 200 is exempt, up to EUR 3,000 the declaration is annual and due by 20 January of the following year, up to EUR 31,000 it is quarterly with declarations due 20 April, 20 July, 20 October and 20 January, and above EUR 31,000 it is monthly, due by the 20th of each month.

Is CDC RAEE the same thing as the Registro AEE?

No. In Italy, producers of electrical and electronic equipment enrol in the Registro AEE through registroaee.it and the Chambers of Commerce before operating, under Article 29 of Legislative Decree 49/2014. The Centro di Coordinamento RAEE under Article 33 is a consortium that collective and individual WEEE management systems must join, and it coordinates collection from collection points. Producers do not enrol with CDC RAEE directly.

What is the deadline for the Italian AEE annual communication in 2026?

For electrical and electronic equipment placed on the Italian market during 2025, the Chambers of Commerce set the Registro AEE annual communication deadline at 3 July 2026, with the portal open from 30 March 2026. The filing is required even if the quantity placed on the market was zero. Failing to communicate data is fined EUR 2,000 to EUR 20,000 under Article 38 of Legislative Decree 49/2014.

Which law governs batteries in Italy in 2026?

Legislative Decree 29/2026 of 10 February 2026, published in Gazzetta Ufficiale no. 54 on 6 March 2026 and in force from 7 March 2026, adapts Italian law to the EU Battery Regulation (EU) 2023/1542. Article 37 repeals Legislative Decree 188/2008 with transitional exceptions. Article 20 creates a new battery producer register at the Chambers of Commerce, and the old register stays active until the new one is fully implemented.

Do batteries built into my product trigger Italian battery registration?

Yes. Article 20(4) of Italy's Legislative Decree 29/2026 requires producers that first make batteries available on the Italian market, including batteries incorporated in appliances, light means of transport or other vehicles, to enrol in the battery producer register at the competent Chamber of Commerce. Placing batteries on the market without enrolment is fined EUR 36,000 to EUR 120,000 under Article 34(5), and annual data is due by 31 March.

What changes for battery labelling on 18 August 2026?

Under Article 13 of Regulation (EU) 2023/1542, the general information label, capacity labels for rechargeable portable, LMT and SLI batteries, and duration labels for non-rechargeable portable batteries apply from 18 August 2026, or 18 months after the labelling implementing act if later. The separate collection symbol has applied since 18 August 2025 and the QR code applies from 18 February 2027. Italy fines labelling breaches EUR 10,000 to EUR 150,000.

What happens if I sell into Italy with no EPR registration at all?

Italy fines the producer directly: EUR 15,500 to EUR 46,500 under Article 261 of Legislative Decree 152/2006 for packaging, EUR 30,000 to EUR 100,000 under Article 38 of Legislative Decree 49/2014 for unregistered electrical equipment, and EUR 36,000 to EUR 120,000 under Article 34 of Legislative Decree 29/2026 for unregistered batteries. From 12 August 2026, Article 45 of Regulation (EU) 2025/40 also requires online platforms to obtain packaging registration data before a producer can sell.

Who carries the Italian EPR obligation when a Merchant of Record is the seller?

In Italy, EPR obligations attach to the producer that first makes packaging, electrical equipment or batteries available on the Italian market. Where a Merchant of Record imports and sells goods in its own name, it is that producer for those units and registers in its own name or, where required, through an authorised representative for extended producer responsibility. The brand, as manufacturer, keeps CE marking and the technical file, and remains separately obliged for any units it ships into Italy itself.

Where a Merchant of Record carries the Italian EPR obligation

When Operator One acts as Merchant of Record, it is the legal seller: listings show the brand as the client's brand and Operator One as the seller. Where Operator One imports goods into the EU, it is the importer and the responsible economic operator, and for the units it first makes available in Italy it carries the producer obligations for packaging, EEE and batteries. EPR registrations are per country and per stream and do not transfer between legal entities, so a brand's own registrations do not cover Operator One's units, and vice versa. Where Italian rules require a locally established authorised representative, Operator One commonly arranges one during onboarding, though this is not the case in every market. CE marking, conformity assessment, the technical file and the EU Declaration of Conformity stay with the manufacturer. As importer, Operator One checks the file exists, adds its name and postal address, keeps the Declaration of Conformity for 10 years and handles any corrective action. Terminology is explained in the compliance glossary.

Sources: Regulation (EU) 2025/40 (PPWR), EUR-Lex; Regulation (EU) 2023/1542 (Batteries), EUR-Lex; Directive (EU) 2025/1892 (textile EPR), EUR-Lex; Legislative Decree 29/2026, Gazzetta Ufficiale; Legislative Decree 152/2006, Article 261, Normattiva; Legislative Decree 49/2014, Article 38, Normattiva; Legislative Decree 49/2014, Article 33, Normattiva; Legislative Decree 49/2014, Article 30, Normattiva; Registro AEE, Chamber of Commerce of Turin; Registro AEE 2026 portal opening, Chamber of Commerce of Bari; CONAI Guide 2026 to membership and the Environmental Contribution.

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