What Are the Requirements for the Italy CONAI Registration?

Key Changes to the Italian Packaging Law in 2026

Mandatory linkage of electronic invoice data, mandatory material code labeling on packaging, inclusion of secondary packaging in the declaration scope, and requirement to submit packaging design documents for initial registration. The latest requirements also mandate the use of the new official CONAI declaration template.

Latest Changes to the Italian Packaging Law 2026

1. Electronic Invoice Integration
The CONAI system has been connected to the Italian Revenue Agency’s Electronic Invoice (Fattura Elettronica) platform. The declared packaging weight must be logically consistent with packaging information on purchase invoices (e.g., number of cartons, weight of plastic film); otherwise, the application will be automatically rejected. Estimated values are no longer permitted — declarations must be based strictly on invoice data.

2. Packaging Labeling Requirements
All packaging must be marked with material codes (e.g., C/PAP for cardboard, C/PLA for plastic, C/GL for glass) and recycling instructions such as “Ricicla”. Labels must be clear, permanent, and not applied via easily detachable stickers. Starting 2026, packaging without material codes will be considered non-compliant.

3. Extended Producer Responsibility
From 2026 onward, secondary packaging used by e‑commerce sellers (e.g., shipping boxes, bubble wrap, adhesive tape) will be included in the declaration scope and will no longer be exempt. Sellers must calculate the weight of such secondary packaging and declare it by material type.

4. New Initial Registration Requirements
For first-time registration under the Italian Packaging Law, in addition to standard documents, applicants must upload packaging design documents (e.g., design drawings, material specifications) to prove packaging recyclability. CONAI will review compliance with ecodesign requirements.

JJR Compliance Case

1. Client Pain Point
A Zhejiang-based seller making their first registration under the Italian Packaging Law in 2026 prepared documents under the old policy (only company information and estimated packaging weights). The application was rejected by CONAI, which requested supplementary packaging design documents and secondary packaging weight data.

2. Solution
The JJR team assisted the seller in obtaining packaging design drawings (PDF) from the factory with material codes clearly marked. We also guided the seller in compiling secondary packaging data: average weight per shipping box, bubble wrap weight, and total annual weight calculated based on order volume for inclusion in the declaration. The resubmitted application was approved successfully.

3. Outcome
The seller is now operating in full compliance.

Q&A

Is the official CONAI template mandatory for the Italian Packaging Law in 2026?

Yes. The old template has been discontinued, and submissions using outdated templates will be rejected by the system. JJR can provide the latest official template.

How is the weight of secondary packaging calculated under the 2026 Italian Packaging Law?

Weigh 10 typical shipping boxes and use the average weight multiplied by annual order volume. The same method applies to bubble wrap and adhesive tape. JJR can support in establishing a standardized estimation model.

Where can material codes for packaging labeling under the 2026 Italian Packaging Law be found?

The code list is available as a PDF on the official CONAI website. JJR can provide vector source files ready for direct printing.

The 2026 Italian Packaging Law introduces significant regulatory changes: mandatory use of the new template, material code labeling, and declaration of secondary packaging.