compliance teamEPR in Italy: a practical guide for foreign sellers
Step 1
Map the entity and channel
Step 2
Identify each EPR stream
Step 3
Prepare official evidence
Step 4
Maintain labels, data and filings
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
Start with the legal entity and sales route
Italian EPR is not decided by a brand name, warehouse or checkout page alone. Record the seller, establishment country, customer, contract and route by which the product reaches Italy.
A third-party marketplace, an own-webshop DTC sale and a sale to an Italian importer require different packaging analyses. Mixed channels should be separated before any application.
Separate packaging, WEEE and batteries
For packaging, the current foreign-company route centres on CONAI membership, a Codice Socio and the Attestato di adesione. As checked on 14 August 2026, RENAP did not expose an operational packaging register.
Electrical equipment and batteries retain separate registration and system duties. A device with a battery can therefore create three files; no single number replaces them.
Keep registration, labels and declarations linked
A usable file connects the product inventory to its packaging materials and fasce, the selected declaration procedure, filings, CAC invoices and proof of payment.
Environmental labelling is a separate product obligation. Keep material codes and Italian sorting information linked to the same packaging specification used for contribution data.
Conclusion
Scope comes before a form. Connect the legal entity, product, sales channel and EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. CONAI, public registers, collective systems and marketplaces control their own procedures, timing and decisions.