Based on the relevant regulations, so-called “Producers” and “Users” are required to ensure the correct environmental management of packaging and packaging waste generated by use of their products (art. 221 of Italian Legislative Decree 152/06 under art. 38 of Italian Legislative Decree 22/97).
Who the “Producers” are:
- Producers and Importers of raw materials for packaging;
- Producers/Transformers and Importers of semi-finished products for packaging;
- Producers of empty packaging;
- Importers/Resellers of empty packaging.
Who the “Users” are:
- Buyers/Fillers of empty packaging;
- Importers of “full packaging” (i.e. packed goods);
- Autoproducers (manufacturers of packaging to pack their own goods);
- Full packaging traders (buyers/resellers of packed goods);
- Empty packaging traders (those who buy in Italy and resell this packaging without carrying out any transformation).
in addition to registering with CONAI in the Producers category, Producers register with one or more supply chain consortia in relation to the materials produced and to individual consortium statutes.
All the subjects defined above are members of CONAI.
For each packaging material, CONAI and the supply chain Consortia establish an ENVIRONMENTAL CONTRIBUTION (CAC), which constitutes the form of financing used to divide, among Producers and Users, the costs of separate waste collection and the recovery and recycling of primary, secondary and tertiary packaging.
Payment of the CONAI Environmental Contribution is regulated by articles 221 and 224 of Italian Legislative Decree 152/06 (pursuant to articles 38 and 41 of Italian Legislative Decree 22/97).
The amount of the Environmental Contribution for steel packaging is currently 5.00 Euro/t.
The Environmental Contribution is applied at a particular point of the packaging’s life cycle, called “first transfer”.
This is when:
- the finished packaging passes from the last Producer to the first User, i.e. from the seller of the finished packaging (ready to use) to the subject who will fill it with a product
- the packaging material passes from a Producer of raw materials (or semi-finished products) to an Autoproducer, i.e. when the packaging is not yet finished (ready for use) and is transferred to whoever will give the packaging its final shape and will fill it with product.
In the life cycle of each packaging item there is only one first transfer: this must be clearly indicated to avoid misunderstandings and to correctly distribute the costs among the operators involved.
All Producers who carry out the First Transfer are required to declare to CONAI the packaging they have processed, the quantities subject to the Environmental Contribution and the amount of the Contribution, which must be paid for each material. The periodic Declaration is carried out by the Producer by completing form 6.1, specific for each reference material (Steel, Aluminium, Paper, Wood, Plastic, Bioplastic and Glass); it can be forwarded to CONAI at different times, depending on the size of the Contribution.
For more information, we recommend consulting the CONAI 2021 ENVIRONMENTAL CONTRIBUTION GUIDE (Volume 1 – Volume 2) and the ENVIRONMENTAL CONTRIBUTION GUIDE 2022 (Membership): this is the operational tool that documents all the procedures envisaged for the various interested parties, which provides a wide set of definitions, examples, technical sheets and interpretation guidelines, in order to improve the contents and to provide a complete and detailed key to understanding the entire “packaging system”.
Please be aware that, starting from the year 2014, Declaration-related data must be sent through the online declaration service accessible from the CONAI website.