Italian Packaging EPR Service

Attention Amazon Europe Sellers!
Amazon Europe has recently issued new regulations on EPR compliance. This notification re-emphasizes the importance of compliance with Italy’s Extended Producer Responsibility (EPR) rules, especially for the registration of WEEE products. Sellers are urged to attach great importance and advance the compliance process as soon as possible to avoid delays during the year-end peak period.

What is EPR?

EPR stands for Extended Producer Responsibility.

In simple terms:
Whoever places goods on the market
is responsible for their entire life cycle, including:
1.Product design
2.Use phase
3.Recycling, treatment and waste management

This system aims to reduce waste, protect the environment,
and hold producers accountable for their environmental impact.

EPR Requirements for Selling in Italy

Italy has established its EPR system through multiple decrees.
If your products fall under regulated categories, you must complete EPR registration, reporting, and fulfill recycling obligations.

New Italian EPR Compliance Requirements

Starting 15 November 2024, sellers offering Electrical and Electronic Equipment (EEE), polyethylene products, oils, packaging, tires, batteries and other products on Amazon Italy must comply with local EPR regulations.

Product Categories Under Italian EPR Regulation

The scope is extensive and includes:

Packaging

• Product boxes and packaging (e.g., toy boxes)

• Shipping cartons

• Shipping labels

• Adhesive tape, etc.

Electrical and Electronic Equipment (EEE)

• Computers

• Monitors

• Lamps

• Light bulbs

• Solar panels

• Professional electronic equipment, etc.

Batteries

• Portable batteries

• Automotive batteries

• Industrial batteries, etc.

Waste Vegetable & Animal Oils

Waste Mineral Oils

• Engine oil

• Industrial or lubricating oils (mineral or synthetic), such as waste oil from internal combustion engines and drive systems, as well as waste oil for turbines and hydraulic controls

• Transmission oil

• Hydraulic oil, etc.

Polyethylene Products

• Spring toys

• Sandboxes

• Slides

• Indoor rattan and/or polyethylene furniture

• Plastic wrap

• Freezer bags

• Shovels

• Basins

• Fly traps, etc.

Tires

• Vehicle tires (excluding bicycle tires, aircraft and general aviation tires)

Possible Future Additions

Textiles, footwear (draft under development)

If you are unsure whether you qualify as a “producer”, please refer to the Consolidated Environmental Act (152/2006).

Obligations of a “Producer”

If you are recognized as a producer, you must:
✔ Complete EPR registration
✔ Submit regular reports as required
✔ Join the relevant PRO (Producer Responsibility Organization), or
✔ Appoint an Italian local authorized representative to fulfill obligations on your behalf

⚠ Different product categories require joining different PROs.
For example, when selling laptops containing batteries, you must join PROs for EEE, batteries and packaging.

How to Determine if You Are a Producer

A seller is considered a producer if:

• You sell relevant products in Italy under your own company name or brand;

• You are the entity first making the products available on the market.

Most Chinese sellers established outside Italy fall into this category.

How to Meet Compliance Requirements

For Producers

You may either:

1. Register for Amazon’s EPR Pay-on-Sale Service; or

2. Complete EPR registration and reporting independently:

￮ Registration: Register with an authorized PRO for your category to obtain a registration number. If you have no legal entity in Italy, you may need to appoint an authorized representative. Cross-border seller consultants can provide one-stop compliance for registration + reporting.

￮ Platform Verification: Upload your registration number in Seller Central and keep it valid.

￮ Reporting & Payment: Submit sales data and pay environmental fees according to the required cycle.

For Non‑Producers

Obtain a valid registration number from your upstream supplier,
submit it in Seller Central, and select “Non-producer”.

How to Submit Your EPR Registration Number in Seller Central

1. Go to Account Health → Manage Your Compliance

2. Proceed to Submit Compliance Information to provide your registration number

3. Select the category from the Extended Producer Responsibility (EPR) dropdown menu

4. Click Save — a confirmation window will appear for successful submission

You will receive a decision on your submitted number within seven business days.
Common reasons for rejection: expired number, mismatched name, or invalid number. Please upload a new valid number.

What is Italian EPR Pay-on-Sale Service?

The EPR Pay-on-Sale Service automatically pays environmental fees on your behalf, ensuring your products comply with Italian laws.
Fees are calculated automatically based on sales data and paid to environmental organizations, with deductions made directly from your Amazon seller account.

If you fail to provide a valid EPR registration number for each applicable category by the last day of each reporting period, you will be automatically enrolled in the EPR Pay-on-Sale Service starting the next period.

To opt out of the EPR Pay-on-Sale Service, submit a valid EPR registration number in the Account Health page before the deadline. Processing typically takes 1–2 weeks.

Relevant References

• WEEE (Waste Electrical and Electronic Equipment): Legislative Decree 49/2014

• Batteries: Legislative Decree 188/2008

• Packaging: Legislative Decree 152/2006 (Articles 218, 221, 221‑BIS, 223)

• Waste Tires: Legislative Decree 152/2006 (Article 228) + Ministerial Decree No. 182 of 2019

• Waste Vegetable & Animal Oils: Legislative Decree 152/2006 (Article 233)

• Polyethylene Products: Legislative Decree 152/2006 (Article 234)

• Waste Mineral Oils: Legislative Decree 152/2006 (Article 236)