PPWR Compliance in Italy: CONAI, EPR & What Italian Companies Must Do

PPWR Compliance in Italy: Navigating CONAI, EPR, and National Packaging Rules

Italy is one of the EU's largest packaging markets and a global leader in food, fashion, and luxury goods packaging. For decades, Italy has operated a mature Extended Producer Responsibility (EPR) system through CONAI (Consorzio Nazionale Imballaggi), the national packaging consortium. With the arrival of Regulation (EU) 2025/40 — the PPWR — Italian companies face compounded obligations: existing CONAI duties remain, while new EU-wide requirements layer on top.

This guide explains how PPWR interacts with Italy's national framework, what Italian companies must do before the August 12, 2026 deadline, and how to manage the dual compliance burden.

Italy's EPR System: CONAI and the Material Consortia

Italy's packaging EPR system is structured around CONAI and six material-specific consortia. Established under Legislative Decree 152/2006 (the Italian Environmental Code, or Testo Unico Ambientale), CONAI coordinates collection, recycling, and recovery of packaging waste across Italy.

The Six Material Consortia

All companies that produce, import, or use packaging in Italy must register with CONAI and pay the Contributo Ambientale CONAI (CAC) — an environmental contribution based on the type and weight of packaging placed on the Italian market. In 2026, CAC rates range from approximately EUR 4/tonne for wood to EUR 660/tonne for certain plastic packaging categories.

How PPWR Overlays on Italian National Law

Unlike the previous Packaging Directive (94/62/EC), which allowed member states to transpose rules differently,PPWR is a regulation — it applies directly and uniformly across all 27 EU member states. Italian companies cannot rely solely on CONAI compliance to meet PPWR obligations. The two systems are additive.

What PPWR Adds Beyond CONAI

• Recyclability Grades (A-E): CONAI already tracks recyclability through its eco-modulation system, but PPWR formalises mandatory A-E grades. Grade D and E packaging will be banned from January 1, 2030; only A and B will be permitted from January 1, 2038
• Declaration of Conformity (DoC): A formal written declaration per Article 39 and Annex VIII of the PPWR. CONAI registration does not replace this; both are required for every packaging item
• Digital Product Passport (DPP): From August 28, 2027, all packaging must display a QR code linking to standardised DPP data including material composition, recyclability grade, and sorting instructions
• PFAS Ban: From August 12, 2026, per- and polyfluoroalkyl substances are banned in food-contact packaging. Italy's food packaging sector — the largest in the EU — is particularly affected
• Recycled Content Targets: Mandatory minimums from 2030 (e.g., PET contact-sensitive 30%). CONAI's voluntary incentive system is not sufficient to meet these binding targets
• Heavy Metal Limits: Lead, mercury, cadmium, and hexavalent chromium must not exceed 100 mg/kg combined. This has applied since January 1, 2026

Timeline and Deadlines for Italian Companies

Italy-Specific Considerations

CONAI Environmental Labelling (Decreto 116/2020)

Since January 1, 2023, Italy has required mandatory environmental labelling on all packaging sold in Italy. Under Decreto Legislativo 116/2020, all packaging must display material identification codes (following Decision 129/97/EC) and consumer sorting instructions. This existing obligation partially aligns with PPWR's labelling requirements, but the DPP goes further — requiring digital access to comprehensive data, not just printed symbols.

Italy's Food Packaging Industry

Italy is the EU's largest food packaging market. The PFAS ban effective August 12, 2026 has outsized implications for Italian producers. Pizza boxes, bakery packaging, deli wrap, and grease-resistant food-service containers traditionally rely on PFAS coatings. Italian manufacturers must transition to PFAS-free alternatives — such as aqueous coatings, wax-based barriers, or mineral oil-free options — before the deadline.

CONAI Eco-Modulation and PPWR Grades

CONAI already operates an eco-modulation system that adjusts CAC fees based on recyclability and ease of sorting. Under this system, packaging classified as "facilitating recycling" receives a lower contribution rate. With PPWR's formalised A-E grading system, CONAI is expected to align its eco-modulation with the EU grades, meaning:

• Grade A packaging: Lowest CAC surcharge (potential discount)
• Grade B packaging: Standard contribution rate
• Grade C packaging: Increasing surcharges as 2030 approaches
• Grade D/E packaging: Banned from January 1, 2030 — cannot be placed on the Italian market

Enforcement in Italy: ISPRA and Market Surveillance

In Italy, ISPRA (Istituto Superiore per la Protezione e la Ricerca Ambientale) serves as the national environmental agency responsible for monitoring packaging compliance. Under PPWR Article 56, member states must designate market surveillance authorities. Italy is expected to task ISPRA and regional environmental agencies (ARPA) with enforcement. Penalties for non-compliance can reach up to EUR 30,000 per infringement or 4% of EU turnover, whichever is higher.

Practical Compliance Roadmap for the Italian Market

Phase 1: Now Through August 2026 (Urgent)

1. Verify CONAI registration: Ensure all packaging is registered and CAC contributions are current
2. Conduct packaging inventory: List all materials, weights, components, and supplier certifications
3. Assign recyclability grades: Use a PPWR-compliant assessment tool to assign A-E grades to every SKU
4. Audit PFAS content: Request certificates of PFAS-free compliance from all food-contact packaging suppliers
5. Prepare DoC documents: Draft Declaration of Conformity for each packaging item (separate from CONAI registration)
6. Verify heavy metals: Ensure all packaging meets the 100 mg/kg combined limit for Pb, Hg, Cd, Cr(VI)

Phase 2: August 2026 - August 2027

1. Submit updated CONAI data: Reflect PPWR recyclability grades in CONAI declarations
2. Implement DPP infrastructure: Select a DPP platform provider; generate QR codes for packaging
3. Translate sorting instructions: DPP data must include Italian-language sorting instructions
4. Coordinate with suppliers: Ensure upstream packaging manufacturers provide technical documentation

Phase 3: August 2027 Onwards

1. Activate Digital Product Passports: All packaging must display scannable QR codes with live DPP data
2. Plan for 2030 grade D/E ban: Redesign or reformulate any remaining low-grade packaging
3. Track recycled content sourcing: Begin building supply chains for post-consumer recycled PET, HDPE, and other materials

Key Takeaways for Italian Companies

• CONAI compliance alone is not enough: PPWR adds DoC documentation, DPP infrastructure, PFAS restrictions, and formal recyclability grades on top of existing Italian obligations
• Food packaging companies face the highest risk: Italy's large food packaging sector is disproportionately affected by the PFAS ban — act now to source alternatives
• Environmental labelling partially aligns: Italy's Decreto 116/2020 labelling rules overlap with PPWR, but DPP requirements go significantly further
• Cost pressures will mount: CONAI eco-modulation surcharges on low-grade packaging plus PPWR compliance costs (DPP platforms, material testing, DoC management) will increase total packaging costs
• Penalties are significant: Up to EUR 30,000 per infringement or 4% of EU turnover; market access denial for non-compliant packaging

Resources and Contacts

• CONAI: conai.org — EPR registration, CAC rates, eco-modulation guidelines
• ISPRA: isprambiente.gov.it — Environmental monitoring and enforcement
• COREPLA (plastic packaging): corepla.it — Plastic packaging recycling consortium
• EUR-Lex (Official PPWR Text): Regulation (EU) 2025/40 — Full text of the regulation

Don't wait for the deadline. With August 12, 2026 just months away and Italy's food packaging sector facing unique PFAS challenges, the time to act is now. Use a purpose-built PPWR compliance platform like PPWR Connect to manage your CONAI obligations alongside PPWR requirements — all in one place.