Just Realized Italy Packaging EPR Requires a Domestic Representative? Here's the CONAI Process, Step by Step

Before we start, one clarification worth making up front: PPWR (Regulation (EU) 2025/40) itself does not directly require an “Italian-based representative” in Italy. What creates this need is Italy’s domestic packaging EPR (extended producer responsibility) system — specifically, dealing with CONAI. As overseas sellers work through their PPWR compliance, many discover this Italian-based representative requirement along the way. The distinction may sound minor, but it matters in practice, so it’s worth keeping straight from the outset.

First, What You Need to Know: Overseas Businesses Need a Designated Italian Address

CONAI (Consorzio Nazionale Imballaggi, the National Packaging Consortium) — a private, non-profit consortium — plays a central role in Italy’s packaging waste management system.

Here’s the key point to understand: an overseas business without an Italian establishment needs to designate a domicilio speciale (designated Italian address) in order to complete CONAI registration and compliance procedures. This is the Italian address that serves as the point of contact for legal notices, correspondence, and filing-related documents from CONAI.

Businesses without an existing Italian presence generally have two ways to establish this domicilio speciale:

1. Set up their own presence in Italy (a branch office or local unit) and use that as the domicilio speciale.
2. Engage an Italian-based representative (an intermediario, a domicilio speciale provider, etc.) and use their address as the domicilio speciale.

For most overseas sellers, the second option is the practical route. The rest of this article walks through that process.

Step 1: Select an Italian-Based Representative

Start by selecting an Italian-based representative (intermediario, domicilio speciale provider, etc.) who can handle CONAI-related procedures. Points worth checking when selecting one:

• Do they have hands-on experience with CONAI membership applications (Domanda di Adesione)?
• Can they serve as your domicilio speciale?
• Do they handle ongoing filings (periodic reporting of packaging quantities by material)?
• Do they support the calculation and payment of the CONAI environmental contribution (Contributo Ambientale)?
• Do they have experience working with overseas companies?
• Can they help determine your “producer” classification under EPR, and support packaging flow analysis?

Step 2: Prepare the Required Documents

Your representative will provide guidance on the documents needed for the CONAI membership application. Generally required:

• Certificate of incorporation (equivalent to a company registration certificate)
• Company VAT number
• Legal representative’s identification documents
• Mandato (mandate) — a written document authorizing the representative to act on your behalf
• The domicilio speciale designation form (CONAI’s dedicated form for overseas businesses)
• Packaging information (material composition, estimated annual volumes, etc.)

On the Mandato (mandate): this document authorizes your representative to submit the CONAI application and handle subsequent filings on your behalf. Representatives typically provide a template (facsimile), which you complete with your company’s and legal representative’s details before signing. Depending on the scope of authorization and the requirements of the parties involved, notarization or an apostille may occasionally be needed — but the CONAI membership process itself typically requires only company registration documents, a VAT number, identification for the legal representative, and the mandate. Since the exact template content varies by representative, check the specific version your representative provides.

Step 3: Submit the CONAI Membership Application (Domanda di Adesione)

Membership applications for overseas businesses use a dedicated application form, requested by email from CONAI’s dedicated overseas business contact — a separate channel from the standard online membership system. (Unlike the standard online process, overseas business procedures go through this email-based channel.)

Your representative completes this application form on your behalf and submits it together with the required documents (mandate, domicilio speciale designation form, etc.).

Step 4: Pay the Membership Fee (quota di adesione)

CONAI membership requires payment of a membership fee. The fee consists of a fixed amount, plus an additional amount that may apply depending on company size and other factors. It’s worth confirming the exact calculation basis with your representative.

Payment is typically made via bonifico bancario (bank transfer). Depending on the process, other methods such as MAV (a payment-slip-based transfer) may be indicated. Follow your representative’s guidance either way. The payment receipt (ricevuta di versamento) needs to be attached to the membership application.

Step 5: After Membership Is Confirmed — What Happens Next

Once membership is confirmed, CONAI notifies you of your membership number and related details. From this point, the following ongoing obligations apply:

• Periodic reporting: you report packaging quantities on a regular basis, broken down by material (paper, plastic, wood, metal, glass, etc.)
• Environmental contribution payments: based on your reported figures, you make ongoing payments of the environmental contribution (Contributo Ambientale). The invoicing format varies depending on whether you use the standard or simplified procedure.
• PPWR technical documentation: separately from CONAI membership, you’ll also need to progress your PPWR-related Declaration of Conformity (DoC) and technical documentation in parallel. Keep in mind that CONAI membership is “domestic packaging EPR registration in Italy”, while PPWR product compliance (recyclability, recycled content, labelling, restrictions on excessive packaging, etc.) is a separate matter. The former centers on registration, reporting, and fee payments to CONAI; the latter centers on meeting EU-wide design and labelling requirements — these are obligations of a fundamentally different nature.

Process Summary

1. Select an Italian-based representative (intermediario, domicilio speciale provider)
2. Prepare the required documents (certificate of incorporation, VAT number, identification, mandate, etc.)
3. Sign the mandate and submit it to your representative
4. Your representative submits the membership application to CONAI’s overseas business contact
5. Pay the membership fee (typically via bonifico bancario)
6. After membership is confirmed, continue with periodic reporting and environmental contribution payments

Servix International provides end-to-end support for CONAI membership procedures in Italy, mandate preparation, and ongoing service as your Italian-based representative.

It’s completely fine to reach out even if you’re not sure where to start. We’ll ask about your current sales situation and product range, then guide you through the specific documents and steps you’ll need. Please don’t hesitate to get in touch.

The procedures described in this article reflect general information and may change due to updates in CONAI’s operations or related regulations.

Sources: CONAI, membership and general terms · CONAI, EPR fee · CONAI, the new packaging regulation (PPWR) · Regulation (EU) 2025/40 (PPWR), EUR-Lex.