Identify the producer
Map the selling entity, establishment, contract, marketplace and importer for each sales flow.
Regulation (EU) 2025/40 · applies now
Connect the PPWR representative rule to Italy’s actual CONAI route.
PPWR has applied generally since 12 August 2026. Article 45(3) requires a producer established in another EU Member State that makes packaging or packaged products available in Italy for the first time directly to the end user to appoint an Italian EPR authorised representative. Distance contracts are included rather than defining the whole scope, and producer profiles 3(15)(c) and (d) are covered. This does not replace CONAI, CAC declarations or environmental labelling.
Rules in force · indicative scope only · no authority or marketplace outcome guaranteed
Four controls, not one number
Keep mandate, membership, declarations and labels distinct.
Document the PPWR mandate
The written mandate is for EPR representation. It is not fiscal representation and does not make the service provider a PRO.
Manage CONAI and CAC
Membership, declaration procedure, material fascia, annual class and direct CONAI invoices need their own evidence trail.
Check the packaging
Material codes and Italian collection instructions are assessed separately from membership and marketplace checks.
Route matrix
“B2B” is not enough information.
An Italian importer or reseller and a direct Italian business end-user do not lead to the same Article 45 analysis. Confirm who first makes the products available in Italy, whether the recipient is the end user and whether a distance contract is involved without treating that technique as a condition of the whole rule.
Marketplace sale into Italy
A marketplace is a sales technique, not an Article 45 allocation. If a producer established in another EU Member State first makes products available in Italy directly to the end user, Article 45(3) applies; platform procedures and CONAI evidence remain separate.
Own webshop — direct sale
CONAI guidance currently describes foreign own-webshop adhesion as voluntary. Separately, Article 45(3) covers producer profiles 3(15)(c) and (d) when a producer established in another EU Member State first makes products available in Italy directly to the end user. The distance contract is included, not the sole trigger.
Direct Italian business end-user
Do not label this automatically as an importer or reseller sale. For producer profiles 3(15)(c) and (d), direct first making available in Italy to a professional end user engages Article 45(3), whether or not the contract uses a distance-sales technique.
Italian importer or reseller
Distinguish this route from direct making available to an end user. Where the Italian buyer imports packaged goods for resale, that importer generally declares and pays CAC; contracts and the importer of record must confirm the allocation.
Italian or San Marino establishment
The entity follows the domestic CONAI route rather than the foreign-service route.
Mixed channels
Separate every flow. A reseller share can move responsibility to Italian buyers while direct and marketplace shares follow different routes.
What to prepare now
Build one evidence chain per selling entity and route.
- 01
Confirm the seller
Legal entity, establishment, contracts and importer of record.
- 02
Map each route
Marketplace, own webshop, end-user and reseller flows kept separate.
- 03
Classify packaging
Annual grams by material, paper/plastic fascia and composite rules.
- 04
Choose procedure
Ordinary or an eligible simplified import procedure for the calendar year.
- 05
Keep evidence current
Mandate, Attestato, declarations, CAC invoices and label review reconciled.
Indicative packaging service references
Amazon Starter €399 first year / €299 renewal · Standard €474/year + €150 setup
CONAI CAC, the €5.16 adhesion quota, VAT and third-party costs remain separate. Starter eligibility and every service scope require a written human review.
Non-EU establishment
Keep the CONAI guarantee and PPWR option as separate reviews.
For a foreign CONAI member established outside the EU, except San Marino, the guarantee review depends on whether it has an Italian “sede secondaria con rappresentanza stabile”. Where it has none and uses the foreign-membership route, CONAI guidance calls for suitable security covering an estimated 12 months of CAC; the instrument and amount remain case-specific. Separately, PPWR article 45(3) allows Italy to require a representative from a third-country producer; no primary Italian measure exercising that option was identified as of 14 August 2026. Neither mechanism should be overstated.
Questions about PPWR and CONAI in Italy
Did PPWR create an Italian packaging producer register?
No. Packaging is not currently a RENAP category. CONAI adhesion produces a Codice Socio and Attestato; neither should be described as a national packaging-register number.
Does PPWR replace CONAI membership or CAC declarations?
No. PPWR representation overlays the Italian route. Membership, declaration procedure, CAC and annual evidence continue to be assessed separately.
Is own-webshop CONAI membership mandatory today?
CONAI guidance currently describes the foreign own-webshop route as voluntary. Separately, Article 45(3) requires representation where a producer established in another EU Member State, within Article 3(15)(c) or (d), makes packaging or packaged products available in Italy for the first time directly to the end user. An own-webshop distance contract is included but does not define the whole Article 45 scope. A third-country producer follows a separate national-option review.
Is the PPWR representative already mandatory for every third-country seller?
Do not state that as a general Italian rule. Article 45(3) allows a Member State to impose the requirement on producers established outside the EU, but no primary Italian measure exercising that option was identified as of 14 August 2026.
Is every B2B sale an Italian importer route?
No. An importer or reseller purchase must be distinguished from a producer in another EU Member State making products available in Italy for the first time directly to a business end user. The contract, recipient and importer of record determine which route is being reviewed; distance selling is included but is not the only technique covered.
Does a low CAC estimate remove every obligation?
No. The ordinary €200 threshold is annual and per material, requires self-checking, and can coexist with a statistical declaration at 10 tonnes or more. It does not decide producer status, membership, PPWR representation or labelling.
Can you guarantee a marketplace result?
No. We can prepare evidence for an agreed scope; Amazon and other marketplaces apply their own current fields, review and account decisions.
Primary sources · reviewed August 2026
- Regulation (EU) 2025/40 — EUR-Lex
- Italian Environmental Code — Normattiva
- CONAI 2026 guide to adhesion and CAC
- RENAP — current register scope
- Environmental-labelling guidelines — CONAI / MASE decree
General information only, not legal advice or an authority decision. Product, contract, marketplace and procedural facts require individual review.
Map the Italian route before presenting evidence to a marketplace.
One scope first; any work, price and timeline confirmed separately in writing.