compliance teamWho must join CONAI? Marketplace, own-shop and B2B routes
Step 1
Fix the seller and customer
Step 2
Classify the sales channel
Step 3
Apply the current CONAI route
Step 4
Record exceptions and mixed flows
| 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 |
Foreign marketplace sellers
CONAI's 2026 guidance says a foreign company placing packaged products in Italy through a third-party e-commerce platform may use a simplified platform arrangement where one exists. If it does not use such a service, it must join CONAI and perform the necessary duties.
Do not assume that a marketplace label, fee or uploaded number settles the legal position. Capture the current account request and the official evidence separately.
Own-webshop DTC sales
The same CONAI guidance describes membership as voluntary today for a foreign business outside the third-party-platform route. Once it joins, it is treated like a national member for consortium duties and includes packaging transferred to Italian consumers.
PPWR overlays a separate rule that is not limited to a sales technique: Article 45(3) applies when a producer established in another EU Member State makes packaging or packaged products available in Italy for the first time directly to the end user, including under a distance contract. It covers producer profiles 3(15)(c) and (d). An Italian importer or reseller route must be distinguished, while a third-country producer requires separate evidence of Italy's national choice. The proposed suspension until 2035 remains pending rather than adopted law.
Italian importers and mixed channels
Where an Italian customer imports the packaged goods for resale or distribution as supplied, that importer normally declares and pays CAC. A professional buyer that uses rather than resells the supplied product can be an end user under PPWR, so “B2B” alone is not a conclusion.
A foreign supplier may consider voluntary membership to relieve Italian buyers, but it must follow the corresponding invoice and declaration rules. Split mixed marketplace, DTC and importer flows before deciding.
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.