Since 1 January 2023, all packaging placed on the Italian market must carry the environmental labelling required by Article 219(5) of Legislative Decree 152/2006: a material code under Decision 97/129/EC and, for consumer packaging, instructions on how to dispose of it. The Italian ministry’s guidelines let you provide this information digitally, as long as the consumer is told where to find it. Here is what applies to online sellers, when you need CONAI and the Italian WEEE register, and what changes if you ship from another country.
Who is obliged: Italian producer, importer or foreign seller
The duties depend on who first places the packaging or product on the Italian market:
- you make or pack goods in Italy, or import packaged goods and resell them: you are a “producer” or “user” of packaging under Legislative Decree 152/2006, join CONAI and are responsible for the labelling;
- you sell to an Italian importer or distributor who resells in Italy: as a rule they declare the CONAI environmental contribution on the imported “full packaging”, but the labelling still has to be there when the goods reach the shelf or the customer;
- you sell from abroad directly to Italian consumers (your own shop, Amazon.it, eBay.it…): since 12 August 2026, Regulation (EU) 2025/40 (PPWR, Article 3(15)) makes you the “producer” in Italy for the packaging you deliver to end users there.
For businesses established in another EU Member State, Article 178-ter(8) of Legislative Decree 152/2006 already requires an authorised representative established in Italy for extended producer responsibility (EPR) schemes; since 12 August 2026 the PPWR (Article 45(3)) also requires an authorised representative for packaging in every Member State where you sell at a distance without being established. Law No 36 of 17 March 2026 (Article 14) gives the Italian government eight months to adapt national law to the PPWR, so some Italian details — such as the national producer register — are still being settled.
What the environmental label must show
Article 219(5) of Legislative Decree 152/2006, as amended by Legislative Decree 116/2020, requires all packaging to be “appropriately labelled” to help collection and recycling and to tell consumers where it should end up. The ministry’s guidelines (Decree No 360 of 28 September 2022) distinguish:
- all packaging, including B2B and transport packaging: the alphanumeric material code from Decision 97/129/EC (for example PAP 20 for corrugated cardboard, PET 1, LDPE 4, PP 5); for polymers not covered, UNI EN ISO 1043-1 can be used;
- consumer packaging: in addition, collection instructions such as “Raccolta carta” or “Carta – Raccolta differenziata”, with a prompt to check the local council’s rules (“Verifica le disposizioni del tuo Comune”);
- multi-component packaging: code and collection instructions for each component the consumer can separate by hand, or everything on the main body if there is no room.
| Packaging | Example label (in Italian) |
|---|---|
| corrugated shipping box | PAP 20 – Raccolta carta. Verifica le disposizioni del tuo Comune. |
| polyethylene bag | LDPE 4 – Raccolta plastica. Verifica le disposizioni del tuo Comune. |
| carton sleeve with PET tray | Astuccio: PAP 21 – Raccolta carta · Vaschetta: PET 1 – Raccolta plastica |
The material code is formally a duty of packaging producers (manufacturers, converters, importers of empty packaging), but the fine of €5,000–25,000 in Article 261(3) applies to “anyone who places” non-compliant packaging on the Italian market. If you sell packaged goods, ask your packaging supplier for marked packaging and check the consumer instructions yourself.
Selling online: QR codes, websites and the product page
The ministry’s guidelines say digital channels (apps, QR codes, websites) are “always allowed” and can fully replace or supplement the information on the packaging. The condition: for consumer packaging, you must tell the consumer — on the packaging or at the point of sale, “physical or virtual” — how to find the information, and access must be easy, direct and specific to that packaging.
- useful for multilingual, small or imported packaging with no room for an Italian label;
- on the product page you can add a line “Etichettatura ambientale dell’imballaggio” with the codes and collection instructions, or a link to a dedicated page;
- a generic QR code pointing to your home page is not enough: it has to lead to the information for that packaging.
From 12 August 2028 at the earliest, the PPWR will introduce a harmonised EU label on packaging material, whose information must also be available before an online purchase (Article 12). Until then, the Italian rule applies.
CONAI and the environmental contribution
Packaging producers and users join CONAI, the national packaging consortium (Article 221(2), Legislative Decree 152/2006), and pay the CONAI environmental contribution, charged per tonne and per material. For foreign companies the CONAI Guide 2026 (section 2.4) distinguishes:
- a foreign company has “to date” no obligations towards CONAI unless it sells packaged products in Italy through e-commerce platforms, but it may join voluntarily by electing a special domicile in Italy (one-off fee of €5.16);
- anyone placing packaged products on the Italian market through e-commerce platforms is subject to EPR (Article 178-quater): they can use simplified services the platform operator offers under agreements with the consortia, otherwise they must join CONAI;
- for companies based in another EU country these rules apply until the national producer register is operational (Article 178-ter(8)).
Note that the guide was last updated in December 2025, before the PPWR applied. Since 12 August 2026 the Regulation also treats a foreign business selling to Italian consumers from its own website as a producer in Italy; until Italian law is adapted, ask CONAI ([email protected]) how to handle those sales.
Before you upload your catalogue to Amazon.it or another marketplace, ask whether the platform offers an EPR service for packaging in Italy and what it covers: a marketplace service does not cover sales from your own shop.
Electrical products: the Italian WEEE register
A business established in another Member State that sells electrical and electronic equipment directly to Italian users by distance selling is a “producer” under Article 4(1)(g)(4) of Legislative Decree 49/2014.
- register in the national EEE register (Registro AEE) via the Chamber of Commerce before you start selling in Italy (Article 29); a business established in another EU country can appoint, by written mandate, an authorised representative established in Italy to register and meet its obligations (Article 30 of Legislative Decree 49/2014) — in practice the usual route;
- join a collective scheme (or a recognised individual scheme) for household equipment and report the quantities you place on the market every year;
- the crossed-out wheelie bin on the device is the same EU symbol you use elsewhere.
Your German or French WEEE registration number does not count in Italy: each country keeps its own register.
Italian language and warnings
Article 9 of the Italian Consumer Code (Legislative Decree 206/2005) requires all information intended for consumers to be given at least in Italian; where several languages are used, the Italian must be as visible and legible as the others. Article 6 lists the minimum information on the product or its packaging: product name, name and registered office of the producer or EU importer with postal and electronic address, country of origin if outside the EU, any substances harmful to people, property or the environment, materials that determine quality, and instructions and precautions. Instructions may also come as documentation supplied with the product, including in digital form (Article 7).
For safety warnings on the product page, see GPSR in online listings. If you translate a German or English listing with a machine translator, check technical terms and warnings: our guide to machine-translated listings lists the common mistakes. And no “ecologico”, “sostenibile” or “a impatto zero” without proof: such generic claims have been banned in Italy since 27 September 2026 (see the green claims ban).
Checklist and listing check
- Clear who first places the goods on the Italian market (you, your importer or the marketplace), and an authorised representative appointed if you sell from abroad.
- Decision 97/129/EC code on every piece of packaging, including the shipping box; collection instructions on consumer packaging, either printed or through a clearly signposted digital channel.
- CONAI membership, or the marketplace’s EPR service, in place for your Italian sales.
- Registration in the Italian EEE register and a collective scheme if you sell electrical products.
- Product page, instructions and warnings in Italian.
The free listing check finds banned generic environmental claims in your text (“ecologico”, “sostenibile”, “biodegradabile”, “a impatto zero”) and misleading CE or “tested” wording, in six languages. It does not check the physical label on your packaging or your CONAI or WEEE registration.