Legal assistance for non-Italian manufacturers, brands, importers and online sellers placing packaged goods on the Italian market. Packaging compliance involves both EU product rules and national extended producer responsibility (EPR) arrangements: satisfying one set of requirements does not automatically satisfy the other.
Entering the Italian market: where the obligations arise
An undertaking supplying products to Italian customers may need to establish who qualifies as the responsible economic operator, which packaging categories are involved, whether an Italian establishment or local commercial partner changes the allocation of duties, and how contractual responsibilities are distributed. Direct sales, e-commerce, imports and distribution through intermediaries can raise different questions.
The relevant review begins with the actual flow of goods: who manufactures, fills, imports, distributes and places packaged products on the market, where packaging becomes waste and which companies receive invoices or submit declarations. Generic statements that an EU group is ‘already compliant’ do not resolve Italian obligations.
Italian packaging EPR and CONAI questions
The Italian environmental framework under Legislative Decree No 152/2006 establishes packaging waste responsibilities and a system involving CONAI and sector consortia. The precise obligations and available compliance arrangements must be checked against the operator’s status and the applicable provisions; registration, declarations, contributions and contractual allocation cannot simply be assumed to be identical for every foreign business.
A defined instruction can address the legal characterisation of the undertaking, responsibility within a supply chain, relevant documentation, a registration or compliance query, an administrative objection or a disagreement over obligations. Operational submission of declarations and calculations may involve separately appointed compliance and accounting advisers.
The Packaging and Packaging Waste Regulation
Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), began applying on 12 August 2026, subject to the specific application dates and transitional provisions of individual requirements. It establishes an EU framework for packaging sustainability, prevention, reuse and related market responsibilities. It does not eliminate the need to determine the Italian obligations relevant to the particular producer or distributor.
An assessment therefore distinguishes requirements already applicable, provisions with later application dates, and implementation matters requiring further clarification. Questions concerning packaging design, supplier information, contract wording, data gathering or market access need to be framed against the specific product and commercial model.
Legal work that can be scoped
We can review a foreign operator’s route to the Italian market, map the potential duties of each commercial actor, consider registration and consortium issues under Italian law, assess contractual arrangements and provide a written opinion on identified EPR or PPWR questions. The mandate may also concern correspondence with an authority, a challenged determination or an administrative dispute.
Technical packaging testing, material certification, detailed packaging engineering, contribution calculations and routine reporting operations are not presented as legal services. They can be coordinated with the appropriate technical and compliance professionals where required.
What a foreign referrer should send initially
Please identify the business model (manufacturer, brand owner, importer, distributor or distance seller), the main packaging formats, the role of the Italian counterparty, whether goods are already supplied to Italy, the legal question and any pending notice or deadline. A preliminary issue list is preferable to forwarding sensitive commercial files before a conflicts review.
Related pages: EPR and WEEE compliance · Environmental law · International law firm referrals · Alfonso Maria Fimiani.
For a focused Italian-law assessment, submit an initial enquiry.
Primary sources: Regulation (EU) 2025/40 · Italian Legislative Decree No 152/2006.
Specialist related services: Circular economy and EPR across industries · Pharmaceutical packaging