A written EPR mandate,
with each Italian role kept distinct.
We scope the PPWR authorised-representative mandate separately from CONAI domicilio speciale, filing delegation and fiscal representation. 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; third-country cases require separate evidence of Italy’s national choice.
Priced in a written scope after entity, channels and powers are reviewed
✓ Free ✓ Human review ✓ No commitment
Timing depends on document completeness and independent registry and scheme review
The outcome
A versioned mandate and responsibility map
- Producer, representative, territory, powers and start date identified
- PPWR mandate separated from CONAI address and filing roles
- Signatures, filings, changes and termination evidence retained
The legal entity and powers of any representative are confirmed in the separate written engagement
PPWR Article 45(3) is not limited to distance selling
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 must appoint an EPR authorised representative in Italy by written mandate. Distance contracts are included rather than defining the whole scope, and the rule covers the producer profiles in Article 3(15)(c) and (d). A sale to an Italian importer or reseller must be distinguished from direct making available to an end user. For a third-country producer, an Italian national choice must be evidenced. The proposed suspension until 2035 is pending.
Primary sources · Reviewed 14 August 2026
Roles that must not be merged
EPR and tax representation are confused
This service does not appoint a fiscal representative, obtain an Italian VAT number or provide tax advice.
A CONAI address is treated as the PPWR mandate
Domicilio speciale, a filing delegation and an EPR authorised-representative mandate are different controls.
A pending proposal is presented as effective law
The file records enacted duties and watch items separately, with a dated source for each.
Included in the written scope.
- Article 45 applicability review by entity, producer profile and first-making-available route
- Role map covering EPR mandate, domicilio and filing authority
- Identity and signatory-powers checklist
- Written mandate preparation within the agreed scope
- Version, signature, filing and termination evidence plan
- Regulatory-watch note for the pending suspension proposal
Four controlled steps.
Document the facts
Collect the entity, products, channels, contracts and available evidence for authorised representation.
Confirm scope and dependencies
Receive a written map of assumptions, exclusions, third parties and points requiring approval.
Authorise the agreed work
Private fees, external costs and client responsibilities are confirmed before any submission or commitment.
Coordinate and retain evidence
After a valid engagement, each action, external decision and authentic receipt is stored with its date and version.
Frequently asked
Has the PPWR representative duty been suspended until 2035?
No. A proposal is pending. Article 45(3) currently covers producer profiles 3(15)(c) and (d) where 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. An importer or reseller route must be distinguished, and third-country cases require evidence of Italy’s national choice.
Is this a fiscal-representative service?
No. The EPR mandate, CONAI domicilio and filing delegation are scoped separately from tax representation.
Does a mandate make epritalia.com a PRO or CONAI partner?
No. epritalia.com is an independent private service and does not claim appointment, endorsement or affiliation by CONAI.
Can a mandate be backdated?
We retain the real execution and effective dates. Earlier sales are disclosed and reviewed separately rather than rewritten.
Discuss the facts with the team.
Independent private service · human scope review · no third-party outcome promised.
✓ Free ✓ Human review ✓ No commitment