CONAI-ის შეფუთვის საფასური: რას იხდიან იმპორტიორები იტალიაში

 

 

შესავალი

Every year, thousands of overseas suppliers and Italian buyers discover the same unpleasant surprise: a shipment clears customs, the goods arrive at the warehouse, and a few weeks later the importer receives a request or a compliance question about something called the CONAI environmental contribution. The fee is small per kilogram, but it is mandatory, it is recurring, and it follows the packaging, not the product. If you bring packed goods into Italy, there is a good chance you are the party who owes it.

This guide explains the CONAI packaging fee from the point of view of a cargo owner and a freight forwarder. It covers who actually pays, how the contribution is calculated, what the 2026 rates look like after the plastic increase that took effect on 1 October 2026, which declaration procedure makes sense for different types of imports, and where shipping documents can either save or cost you money. Rates and rules in this article are drawn from the CONAI 2026 Guide and from recent updates published by Italian compliance advisers, and they were checked in early November 2026. Because CONAI revises its bands every few months, always confirm the figures against the current Guide before you file.

What CONAI Is and Why Your Shipment Triggers It

CONAI, the Consorzio Nazionale Imballaggi, is the Italian consortium that coordinates the collection, recycling and recovery of შეფუთვის ნარჩენები. It does not collect rubbish itself. Instead, it funds six material-specific consortia, one each for steel, aluminium, paper and cardboard, wood, plastic and glass, which then organise the recycling work together with Italian municipalities. The money that pays for this system comes from a single instrument, the Contributo Ambientale CONAI, usually shortened to CAC.

The logic is a classic extended producer responsibility model. Whoever places packaging on the Italian market pays a per-tonne contribution based on the material, and that contribution finances the recycling of the same material when it becomes waste. Because the system must be funded at the moment packaging enters the national territory, importers sit at the heart of the scheme. An Italian compliance publication put it plainly in August 2026: packaging that is introduced into Italy and destined to become waste there falls inside the CONAI system, and the importer answers for it.

For a freight forwarder, the practical consequence is simple. The cartons, pallets, stretch film, corner protectors, inner bags and retail boxes that surround your goods are all regulated objects, even though customs classifies the cargo by the product inside. Customs duty and VAT are calculated on the goods. CONAI is calculated on the weight of the packaging, material by material.

Who Is Treated as an Importer

For CONAI purposes, the word import has a wider meaning than in customs law. The consortium treats purchases from other EU countries and from non-EU countries in the same way, so a company in Milan buying packed goods from a supplier in Germany is an importer in exactly the same sense as a company buying from Shenzhen. The relevant question is not whether the goods crossed an external EU border, but whether an Italian operator is the first one to bring the packaged goods into the Italian market.

In practice, the obligated parties fall into three groups. Importers of packed goods, which is the case for almost every trader, retailer and brand owner reading this article, pay the contribution on the packaging that arrives with the goods. Importers of empty packaging, such as a manufacturer buying cartons or bottles from abroad to fill them in Italy, pay on the empty packaging. Manufacturers and traders of packaging made in Italy are the third group, and they normally charge the contribution on their invoices.

The Role of the Invoice Wording

The contribution is designed to be paid once along the chain. When a producer or trader of empty packaging has already charged the CAC in the invoice, the buyer who fills the packaging pays it to the supplier and the goods later circulate with the wording contributo ambientale CONAI assolto. When the importer declares and pays directly to CONAI, the packaged goods can then be sold on with the same wording, which tells the next buyer that nothing more is owed on that packaging.

This is why an Italian consignee often asks the shipper and the forwarder for a packaging weight breakdown. They are not being difficult. They need the figures to fill in a declaration that has legal consequences for them.

How the Contribution Is Calculated

The basic formula has only three inputs: the weight of the packaging, the material it is made of, and the rate in force for that material at the moment of import. Weight is counted in tonnes, so a shipment with 400 kilograms of cardboard cartons carries 0.4 tonnes of paper packaging. Each material is then multiplied by its own rate, and the results are added together.

Primary packaging, which touches the product, secondary packaging, which groups several units, and tertiary packaging, which supports transport, all count. A wooden pallet, the plastic film wrapped around it, steel strapping, a printed gift box and a foam insert are packaging for CONAI purposes. A few items are classified as not being packaging at all, for example certain reusable bags, which CONAI reclassified in April 2026 when they meet specific durability and design requirements, so it is worth checking the Guide for borderline articles before assuming a fee applies.

Not all weights are equal in complexity. The plastic rate, in particular, depends on a classification system called contribution bands, which reflects how easily a plastic package can be sorted and recycled. A recyclable commercial or industrial plastic package falls in the cheaper bands, while a multilayer or hard-to-recycle consumer package ends up in the most expensive one. The rest of the materials are simpler, although paper has a growing number of bands for composite packaging.

CONAI Rates for 2026

The figures below are the contribution values published by Italian advisers following the CONAI board decisions of 2025 and 2026. The notable development this year is a plastic increase approved by the CONAI board on 25 May 2026 and applicable from 1 October 2026, which means that every shipment arriving now is subject to the new plastic values. Biodegradable and compostable plastic also rose in July 2026, from 130 to 246 euros per tonne.

Steel, Aluminium, Wood and Glass

The metal, wood and glass rates are flat per material and stable through the second half of 2026. Steel remains the cheapest at 5 euros per tonne, aluminium sits at 12 euros, wood at 9 euros, and glass at 40 euros after a phased increase that ended on 1 January 2026.

მასალები	CAC (€/tonne)	ძალაშია	შენიშვნები
ფოლადი	5	უცვლელი	Cans, drums, strapping, closures
ალუმინის	12	უცვლელი	Cans, trays, foil containers
ტყე	9	1 ივლისი 2025	Pallets, crates, wooden boxes
Glass	40	1 იანვარი 2026	Bottles, jars, glass containers
Biodegradable and compostable plastic	246	1 ივლისი 2026	Previously 130 €/tonne

Table 1. CONAI contribution values for steel, aluminium, wood, glass and compostable plastic

ქაღალდი და მუყაო

Paper is the material that most e-commerce and consumer goods importers will use most often, because corrugated cartons dominate packaging weight in almost every container. The good news is that standard single-material paper has a low contribution. Composite packaging, such as liquid cartons or paper combined with plastic and aluminium, climbs through the higher bands.

ქაღალდის ზოლი	აღწერა	CAC (€/tonne)
Band 1	Single-material paper and cardboard	45
Band 2	Composite type A	45
Band 3.1	Composite type B1 (with Aticelca 501 certification)	55
Band 3.2	Composite type B2	70
Band 4	CPL (liquid-carrying composite)	115
Band 5.1	Composite type C1 (with Aticelca 501 certification)	110
Band 5.2	Composite type C2	155
Band 6	Composite type D	285

Table 2. Paper and cardboard contribution bands applicable from 1 July 2026

Plastic After the October 2026 Increase

Plastic is where importers should focus their attention. The values for almost every band rose on 1 October 2026, and some of the jumps are large. Band B1.1, for example, goes from 219 to 260 euros per tonne, and band B1.2 from 228 to 304 euros. The most expensive band for non-recyclable multilayer packaging, band C, reaches 922 euros per tonne.

Plastic band	Until 30 Sept 2026 (€/t)	From 1 Oct 2026 (€/t)	შეცვლა
A1.1	40	51	+ 11
A1.2	87	92	+5
A2	258	264	+6
B1.1	219	260	+ 41
B1.2	228	304	+ 76
B2.1	611	639	+ 28
B2.2	724	856	+ 132
B2.3	785	917	+ 132
C	790	922	+ 132

Table 3. Plastic packaging contribution bands before and after 1 October 2026

As a rule of thumb, bands starting with A cover packaging used in commercial and industrial settings, such as film, crates and shrink wrap that never reach a household bin. Bands starting with B cover packaging that ends up with consumers, and the band number reflects how well the material can be sorted and recycled, with band C reserved for packaging that is essentially non-recyclable. For an importer, this means that a retail-ready plastic blister pack with mixed materials will cost many times more per kilogram than the plain stretch film wrapped around the pallet.

Ordinary Procedure or Simplified Procedure

Once you know the rates, you need to choose how to declare. CONAI offers an ordinary procedure and several simplified procedures for importers of packed goods. The choice affects the administrative effort, and it can also change the amount you pay.

The Ordinary Procedure

Under the ordinary procedure, the importer registers with CONAI, receives access to the Conaiweb portal and declares the actual weight of packaging by material and band. This is the most precise method. It is also the one that depends most heavily on good data, because the importer must know, or be able to estimate reliably, the packaging weight for each product. Companies that import a stable range of goods usually build a packaging database once, SKU by SKU, and reuse it for every shipment.

Simplified Procedures for Packed Goods

Importers of packed goods can alternatively use the simplified procedures set out in the CONAI Guide and filed through module 6.2. These procedures replace the need to know the weight of each material with a flat rate, and they are popular among traders with a wide and changing catalogue. There are two main types.

The first is the flat rate by tare. The importer declares the total weight of packaging, without splitting it by material, and pays a single blended rate. That rate was 110 euros per tonne until 30 September 2026 and has risen to 131 euros per tonne from 1 October 2026. The second is the value-based procedure, where the contribution is a percentage of the value of the imported goods. For food products the percentage is now 0.25 percent, up from 0.19 percent, and for non-food products it is 0.11 percent, up from 0.10 percent. Eligibility and conditions for each simplified route are defined in the Guide, so confirm that your business and product type qualify.

Simplified procedure (module 6.2)	Until 30 Sept 2026	From 1 Oct 2026
Flat rate by tare	110 €/tonne	131 €/tonne
Value-based, food products	საქონლის ღირებულების 0.19%	საქონლის ღირებულების 0.25%
Value-based, non-food products	საქონლის ღირებულების 0.10%	საქონლის ღირებულების 0.11%

Table 4. Simplified import procedures for packed goods

Which Method Costs Less

There is no universal winner. Heavy packaging made mostly of cheap materials, such as wooden pallets and plain cardboard, usually makes the ordinary procedure cheaper, because the actual material rates are far below the blended flat rate. On the other hand, goods with very light packaging and a high customs value may pay less under the flat rate by tare, while low-value goods with heavy packaging can be cheaper under the value-based option. The only reliable way to decide is to run the numbers on a typical container, which the next section does.

A Worked Example: One Container of Non-Food Goods

Consider an Italian importer receiving a mixed shipment of non-food consumer goods from China with an invoice value of 60,000 euros. The packaging breakdown, taken from the ჩასალაგებელი სია and a supplier packaging declaration, is 1,800 kilograms of single-material corrugated cartons, 240 kilograms of wooden pallets, and 150 kilograms of plastic stretch film and strapping. For this illustration, the plastic is assumed to fall in band A1.2, and the actual band must always be verified against the CONAI classification.

Item	წონა	კურსი	წვლილი
Corrugated cartons (paper band 1)	1,800 კგ	45 €/t	€81.00
ხის პლატა	240 კგ	9 €/t	€2.16
Plastic film and strapping (band A1.2, assumed)	150 კგ	92 €/t	€13.80
Total under the ordinary procedure	2,190 კგ		€96.96

Table 5. Ordinary procedure calculation using rates from 1 October 2026

Now compare the same shipment under the simplified options. The flat rate by tare applies 131 euros per tonne to the full 2.19 tonnes of packaging, which gives 286.89 euros. The value-based non-food procedure applies 0.11 percent to 60,000 euros, which gives 66.00 euros. In this case the value-based method is the cheapest, the ordinary procedure sits in the middle, and the flat rate is almost three times more expensive than the ordinary calculation.

The lesson is not that one method is best. The lesson is that the difference between them can be several times the base figure, and that a clean packaging weight breakdown is the input that unlocks every option. Importers who do not have the data tend to default to the flat rate, and they often pay more than necessary.

Declarations, Deadlines and Payment

Registered companies submit their declarations through the Conaiweb portal. Under the ordinary procedure the declaration is periodic, and the filing deadline is the twentieth day of the month following the reference period. A monthly filer reporting September imports, for example, files by 20 October, and a quarterly filer reporting the third quarter files by the same date. Which period applies to you depends on the volume of contribution you generate, and the Guide sets the thresholds. Right now, the next major date for monthly filers is 20 November 2026, when the October declaration falls due.

After the declaration, CONAI issues an invoice based on the quantities and bands you reported. The contribution is booked as an additional cost of the imported goods, and it is therefore part of your მიწის ღირებულება. Many importers forget to add it to their pricing model and discover the impact only when margins are reviewed at the end of the quarter.

Compliance is not optional. Failing to register, declaring too little, or failing to pay can lead to administrative sanctions under Legislative Decree 152 of 2006, and CONAI carries out checks and audits on declarations. A late or incomplete declaration also tends to create problems with customers who expect the contributo ambientale CONAI assolto wording on your invoices.

Keeping Records That Survive an Audit

CONAI can ask an importer to justify the figures in any declaration, so the supporting file matters as much as the declaration itself. A sound audit file normally contains the commercial invoices, packing lists, supplier packaging specifications, weighing records or sample weights, the classification logic used for each plastic band, and the copies of every declaration and CONAI invoice. Keeping these documents together for each shipment, rather than in separate mailboxes, makes it possible to answer a query in a day instead of a month.

It is also sensible to document the method behind any estimate. If you calculated the cardboard weight of a product line by weighing five sample cartons and multiplying by the number shipped, write that down once and apply it consistently. Auditors are generally more comfortable with a transparent, repeatable estimate than with figures that change from one declaration to the next without explanation.

Exemptions, Refunds and Re-Exports

The CONAI system exists to finance recycling inside Italy, so packaging that leaves the country and becomes waste elsewhere should not bear the contribution. If you have already paid the CAC on goods that are later exported, CONAI provides procedures to claim an exemption or a refund, using the dedicated forms and supporting documents defined in the Guide. Typical supporting evidence includes export customs documents and invoices.

This matters for importers who use Italy as a distribution hub for other European markets. If you import into Italy, pay the contribution and then re-export part of the goods to a customer in another country, you have a legitimate refund claim on those quantities. Keep your export documentation organised, because claims must be backed by traceable paperwork and reconciled against the original declarations.

The reverse situation is just as important. If you ship goods to a final Italian customer from a foreign warehouse, the packaging still ends up as waste in Italy, so it generally falls under the system even though no Italian warehouse is involved. Cross-border e-commerce sellers should take advice early on how their direct-to-consumer flows are treated, since the obligated party is not always the one who assumes it.

Mistakes Importers Make With CONAI

Treating the Fee as the Supplier’s Problem

A common assumption among overseas sellers is that CONAI is an Italian tax and therefore the buyer’s responsibility. Often that is true, but the allocation of duty should be written into the contract. Under DDP terms, where the seller delivers duty paid, you should clarify in writing who handles CONAI registration and who covers the cost, rather than leaving it to be discovered after the goods arrive.

Not Having Packaging Weights at the Time of Shipping

The most expensive mistake is a documentation one. Packing lists show gross weight and carton counts, but they rarely show the weight of each packaging material. When the importer has to reconstruct this information weeks later, it becomes an estimate, and estimates tend to be conservative or inconsistent. The cheapest moment to record the data is at origin, when the goods are being packed.

Misclassifying Plastic Bands

With a difference of several hundred euros per tonne between the cheapest and the most expensive plastic bands, a classification error can double or triple the contribution on plastic components. The reverse also happens, and some importers overpay for years because a rigid, recyclable component was declared in a more expensive band. A periodic review of the product range against the current band definitions often pays for itself.

Ignoring Rate Changes

CONAI updates its values often. Within the last eighteen months, importers have seen changes for wood, glass, paper composites and plastic, and the October 2026 plastic revision is the largest in recent memory. Systems and price lists that use rates from the beginning of the year will under-declare. Build a habit of checking the CONAI circulars at least once per quarter.

Mixing Up Customs Value With Packaging Weight

Another frequent confusion comes from the customs side of the file. The customs declaration is built around the product classification, the origin and the value, and none of these fields carries packaging weight by material. Importers who assume that the customs entry gives them everything CONAI needs end up reconstructing the data from scratch, and brokers cannot supply what was never captured. Treat the CONAI data set as a separate document that travels with the shipment, and make sure it reaches your Italian consignee before the cargo does.

Where Your Freight Forwarder Fits In

A forwarder cannot register your company with CONAI or sign your declaration for you, but a good one can make the whole process cheaper and less stressful, because most of the data you need is created in logistics. Packing lists, pallet configurations, carton counts and consolidation plans all sit in the forwarder’s workflow long before the goods arrive in Italy.

Topway Shipping has been working in this area since 2010. The company is headquartered in Shenzhen, China, and was built by a team with more than 15 years of experience in international logistics and customs clearance, with a strong focus on China to United States transportation. Its services cover the full logistics chain, including first-leg transportation, overseas warehousing, customs clearance and last-mile delivery. For shippers heading to Europe, Topway Shipping also offers flexible full-container-load and less-than-container-load ocean freight from China to major ports around the world.

For CONAI planning, a few practical points make the difference. When Topway Shipping consolidates LCL cargo, the packing data from each supplier can be collected on one consistent template that records carton, pallet and film weights separately, so your Italian consignee receives a ready packaging breakdown rather than a gross weight alone. For FCL shipments with palletised cargo, the pallet count and material are confirmed before loading, which settles the wood component immediately. Where customs clearance and overseas warehousing are involved, having clearance and storage handled by one provider also means the commercial invoice, the packing list and the contract terms stay aligned, so the entity that holds the CONAI obligation is the one the documents actually name.

Shippers who sell to Italy repeatedly benefit the most. A one-time packaging data setup, built with your forwarder, can be reused across every container, and a clear division of responsibilities under the chosen Incoterm prevents disputes with your Italian customer about who pays the contribution. If you are planning a new Italy lane, talk to the Topway Shipping team early and ask for packaging data capture to be included in the booking instructions.

Preparing Your Next Shipment

The best time to manage CONAI is before the goods are packed. Start by asking your supplier for the packaging specification of each product, including the material and weight of the inner pack, the outer carton, the pallet, the film and any inserts. For plastic components, ask whether the item is a rigid or flexible package, whether it is monomaterial or multilayer, and whether it is destined for household or commercial use, because these answers determine the band.

Next, decide who in the transaction is the obligated party, and record that decision in your contract and in the Incoterm you use. If your Italian customer is the importer of record and declares CONAI, give them the data in a format they can use directly. If you operate under a structure where a foreign seller carries the obligation, make sure the registration is in place before the first shipment, since retroactive corrections are more costly than timely declarations.

Finally, build the contribution into your landed cost model. At today’s rates the CAC on a typical dry-goods container is a few dozen to a few hundred euros, which is modest compared with freight and duty, but with plastic-heavy retail packaging the figure can be much higher. A model that shows the fee transparently avoids margin surprises and helps you decide whether a packaging redesign, for example replacing a multilayer pouch with a monomaterial one, would pay back within a year.

What Is Changing Next

The CONAI environmental contribution does not stand alone. The European Packaging and Packaging Waste Regulation, known as PPWR, applies from 12 August 2026 and redefines the roles of manufacturer and producer. Under the PPWR, an importer who makes packaging or packaged goods available for the first time in a member state is a producer with financial and registration duties, and the manufacturer is responsible for conformity. The regulation also introduces strict limits on PFAS in food-contact packaging and a cap of 100 milligrams per kilogram on the sum of lead, cadmium, mercury and hexavalent chromium in all packaging.

For importers this means that the documentation requested from suppliers will keep growing. Test reports, declarations of conformity and material specifications will be needed alongside the packaging weights that CONAI already requires. Companies that collect all this information in one place at the time of shipment will be well prepared, while those that handle each requirement separately will spend more time and money. Expect Italy to keep adjusting its contribution values as recycling costs and PPWR obligations evolve, and expect more attention to packaging design as an input to cost.

დასკვნა

The CONAI packaging fee is easy to underestimate because the numbers are small per kilogram and the logic is invisible on a bill of lading. In reality, it is a legal obligation that follows the packaging into Italy, it falls on the importer in the CONAI sense of the word, and it is recalculated whenever CONAI revises its bands. The 2026 plastic increase, which took effect on 1 October, makes accurate classification more valuable than ever, and the difference between the ordinary and simplified procedures can be several times the base amount.

The practical formula is straightforward. Capture packaging weights by material at origin, agree in writing who carries the CONAI obligation, choose the declaration method on the basis of a real calculation, and check the rates every quarter. A forwarder that treats packaging data as part of the shipping file, as Topway Shipping does for customers moving cargo from China, turns a recurring compliance headache into a routine step. Treat CONAI as a line in your landed cost and it stops being a surprise.

ხშირად დასმული კითხვები

Q: Who pays the CONAI fee when I import goods into Italy?

A: The importer of the packaged goods, meaning the Italian operator who first brings them into the Italian market, is normally the obligated party. The same applies to purchases from other EU countries. The contract and Incoterm can allocate the cost commercially, but the legal obligation sits with the importer.

Q: How much is the CONAI fee on a standard cardboard carton?

A: Single-material paper and cardboard is in band 1 at 45 euros per tonne from 1 July 2026. A carton weighing 500 grams therefore carries a contribution of about 2.25 cents.

Q: Did CONAI rates change recently?

A: Yes. Plastic contribution bands increased on 1 October 2026, and compostable plastic rose to 246 euros per tonne on 1 July 2026. The simplified flat rate by tare moved from 110 to 131 euros per tonne on 1 October 2026.

Q: Can I get a refund if I re-export the goods?

A: Generally yes. If the contribution was paid and the packaged goods are later exported, CONAI provides exemption and refund procedures, which require supporting export documents.

Q: What information should my forwarder provide?

A: At minimum, a packing list that separates the weight of cartons, pallets, film and other packaging materials. Topway Shipping can record this data at origin so your Italian consignee can file accurately.