Independent Italian legal advice for companies involved in base oils, lubricants and used mineral oils. Article 236 of Legislative Decree No 152/2006 and the CONOU framework create distinct legal questions for producers, importers, commercial operators and businesses involved in the used-oil chain. Legal advice must distinguish statutory duties from practical collection or regeneration services.
Which businesses fall within the used-oil system?
The assessment considers activities actually performed: production, import or supply of base oils, regeneration of base oils, recovery and collection of used oils, and first supply or sale of lubricants in relevant circumstances. The structure of a foreign group and its Italian commercial contracts may change which entities require closer examination.
Consortium participation and contributions
Legal work may cover the grounds for participation in CONOU, contractual allocation of costs, interpretation of contribution duties and the documents needed to challenge or explain a particular claim. A private allocation of costs does not itself eliminate a statutory obligation.
Regeneration, transactions and regulatory risks
An acquisition of a used-oil operator or an industrial arrangement involving collection and regeneration requires legal review of the waste regime, authorisations, contracts and liability. The firm provides Italian-law opinions and transactional support, not waste-handling services.
Scope of a legal mandate
A scoped opinion identifies the economic operator, consortium and contribution issues, the contracts to review and the relevant regulatory or dispute risks.
Contact Italian counsel
Enquire about Italian legal advice · All EPR sectors.
From 28 November 2026, Alfonso Maria Fimiani holds IR Global’s exclusive Environmental Law position for Italy.
Altre lingue / Other languages
Primary legal sources
CONOU – Area consorziati · RENAP – Normativa EPR · D.Lgs. 152/2006, art. 236.
CONOU supply-chain responsibility review
For lubricating-oil producers, importers and waste operators, legal advice can identify the applicable consortium and documentary duties, review collection and transfer contracts, and distinguish producer-related obligations from the separate requirements applying to waste holders and operators.