Mandatory enrollment in CONAI for imports of packaged goods

Mandatory enrollment in CONAI for imports of packaged goods

All subjects who introduce packaged goods into the Italian territory must carry out obligations similar to those of producers and importers of empty packaging and therefore must be registered with the CONAI consortium.

As provided for by Art. 224 of Legislative Decree no. 152/06 (formerly Legislative Decree no. 22/97), producers and users of packaging join the National Packaging Consortium. Registration with CONAI must be made for all importers as “users” indicating the sector of belonging.

Article 261, paragraph 1, of Legislative Decree no. 152/06, replaced by Art. 11, paragraph 3, of Law no. 154 of 28 July 2016 (Agricultural Connection) provides that “[…] producers and users who do not comply […] are punished with an administrative fine of 5,000 euros”.

To register with CONAI and make the participation fee payment, the online enrollment service must be used. The fee is paid only once and can be adjusted according to the quantities every year at the discretion of the Consortium. The online enrollment service is accessed through the portal directly from the website

The ordinary declaration procedure involves an analysis of all the materials that make up the imported full packaging; the individual materials must be identified based on the categories provided by CONAI and the contribution must be calculated and paid based on their weight.

The importer is exempt (from the declaration and contribution) if the amounts do not exceed € 50.00 per year for each material.

The simplified procedure provides for two alternative types of lump sum:

  • a percentage contribution on the value of all imports of full packaging.
  • a fixed contribution per tonne on the weight of only the packaging (tare), calculated without differentiating the type of materials.
    In this case, the exemption threshold refers to a total annual contribution of € 100.00.