Anyone selling online in Italy — or importing goods to resell there — sooner or later runs into the acronym CONAI, the National Packaging Consortium. As in Germany with LUCID, Extended Producer Responsibility here translates into an obligation to declare your packaging and pay a contribution. But it works differently, starting with one detail that changes the whole operational flow: you don't upload any file, you fill everything in online.
In this guide we look at when the obligation kicks in, how often you declare, where the declaration is actually filed and what shortcuts exist for importers. A practical tone, written for someone running a Shopify store who is not an environmental-law expert.
When the CONAI obligation kicks in
The principle is the same as European EPR logic: whoever places packaging on the Italian market — producing it or importing it — must contribute to the collection and recycling system. For an e-commerce business, this means the packaging you ship with (boxes, mailers, fillers, tape) makes you subject to CONAI obligations.
Here too there is no minimum threshold: the obligation kicks in from the very first unit imported or produced. There is no volume below which you are exempt. This is an important point for small stores, which often assume they are too small to fall under the rules — they are not.
The CONAI Environmental Contribution (CAC)
The economic core of the system is the CONAI Environmental Contribution (CAC): an amount due per tonne of packaging, differentiated by material (paper, plastic, glass, steel, aluminium, wood, and so on). It is what you declare and pay, and it funds separate collection and recycling.
The calculation is therefore based on the actual weight of packaging by material. And that is exactly the part that becomes burdensome when done by hand: you need to know how many grams of cardboard, plastic and other materials you placed on the market in a given period, aggregated by category. This is the work EPR Pack Report calculates automatically from your real Shopify orders.
Frequency: quarterly the first year, then variable
This is the point that causes the most confusion, so it's worth setting out clearly.
- First year of enrolment: mandatory quarterly filing. When you enrol, for the first year you declare every quarter, with no alternative.
- From the second year: variable frequency. The cadence (annual, quarterly or monthly) depends on the amount of Environmental Contribution declared the previous year. In short: those declaring higher amounts stay on a more frequent basis; those declaring little can move to a less frequent cadence.
In practice, the system is designed so frequency follows volume: the more packaging you place on the market (and the more contribution you pay), the more often you declare.
The deadline: the 20th of the following month
Periodic declarations must be filed by the 20th of the month following the reference period. For a quarterly declaration, then, the January–March quarter is declared by 20 April, and so on. Keeping this recurring deadline in mind is essential: it's a date that comes back regularly and should go into the store's operating calendar.
Where you declare: online only, no files
Here lies the sharpest difference from Germany. In Italy there is no XML or CSV format to import: the declaration is made exclusively by filling in the online form on the dichiarazioni.conai.org portal.
What does that mean in practice? That the added value of an automation tool isn't generating a file to upload, but having the right figures ready to enter in the portal's fields: the weight totals by material, already aggregated for the reference period. Arriving at the form with those figures calculated and checked turns a long, error-prone operation into a few minutes of data entry.
Simplified procedures for importers
CONAI provides simplified procedures designed for importers, as an alternative to the analytical calculation of actual weight for each material. The idea is to apply a rate to the value of the imported goods rather than reconstructing the weight of every piece of packaging.
A confirmed example is the rate of 0.09% on value for non-food products. For some importers this flat-rate route is more convenient; for others — especially those with thin margins or significant volumes — the calculation based on actual weight may work out cheaper. It's worth assessing both paths, because the economic difference over the course of a year is not trivial.
Note: the rates and conditions of the simplified procedures can be updated by CONAI. Always check the current values on the official portal before choosing a regime.
The penalties
The CONAI penalty framework distinguishes between failure to enrol and breaches in declaring the contribution. The legal references are Article 261 of Legislative Decree 152/2006 (the Environmental Code) for failure to enrol, and Article 14 of the CONAI Regulation for breaches relating to declaration and contribution.
- Failure to enrol with CONAI: an administrative fine of €5,000 for the producer/user, on top of which the membership fee and any back-contributions are still owed. For packaging producers that do not join the consortia, the fine ranges from €15,500 to €46,500.
- Omitted, insufficient or untruthful declaration of the Environmental Contribution (or fraudulent use of exemptions): a penalty equal to 50% of the sums due for the first infringement, rising to 150% for subsequent infringements.
- Self-reporting waiver: no penalty applies if the member, before checks begin, self-reports the infringement and settles the contribution due within 30 days of submitting the self-report (by registered letter with return receipt).
The practical message holds: the declaration is a legal obligation and omitting it exposes you to penalties proportional to the contribution due. Better to set the process up properly from the start — and, if needed, to use the self-reporting waiver before an audit.
Primary, secondary and tertiary packaging: what's included
A frequent doubt concerns what must be declared. EPR logic considers all the levels of packaging you place on the market, not just the product's box:
- Primary: the packaging in direct contact with the product (the single item's box, the bag wrapping it).
- Secondary: what groups several units or protects the primary (the sleeve, the box holding several pieces).
- Tertiary: transport packaging, typical of e-commerce — the shipping box, the bubble wrap, the fillers, the tape, the label.
For a Shopify store, tertiary is often the heaviest item by weight, precisely because every order travels in a box with its protective material. It's exactly what a per-order automatic calculation captures better than an end-of-period estimate: every shipment counts.
Keeping your records in order
Regardless of frequency, the aspect that makes the difference in an audit is traceability: being able to reconstruct how you arrived at the figures you declared. That means keeping the weight data by material, period by period, and the logic with which you calculated it. Relying on hand-filled spreadsheets makes this reconstruction fragile; a system that starts from real orders and keeps the calculation history leaves you an orderly, consistent trail, ready to show if needed.
Summary: the CONAI declaration in a table
| Aspect | How it works in Italy |
|---|---|
| Minimum threshold | None — obligation from the first unit imported/produced |
| Frequency (year 1) | Mandatory quarterly |
| Frequency (from year 2) | Annual, quarterly or monthly, based on the Contribution declared the year before |
| Deadline | By the 20th of the month following the reference period |
| How you declare | Online only on dichiarazioni.conai.org — no file to upload |
| Calculation basis | Actual weight by material (CONAI Environmental Contribution) |
| Alternative for importers | Simplified procedure on goods value (e.g. 0.09% for non-food products) |
| Penalties | From €5,000 (failure to enrol) up to €46,500 for packaging producers · 50%/150% of the contribution for untruthful declaration |
What to do now
If you sell in Italy, the steps are: enrol with CONAI, factor in the quarterly frequency of the first year, mark the deadline of the 20th in your calendar, and decide whether weight-based calculation or a simplified procedure suits you. From there, the recurring work is collecting the weights by material for each period — the part EPR Pack Report calculates for you from your Shopify orders, so you reach the portal with the totals already prepared.
Do you also ship to Germany or France? The logic is different: read the guide to LUCID and VerpackG and the one on Citeo in France, or start from the comparative EPR guide for selling across multiple EU countries.
It remains the case that the declaration and final legal responsibility are yours: EPR Pack Report supports the calculation and data preparation; it does not replace the obligations.