Italy vs Oregon EPR: Rules Compared
Last verified
Italy and Oregon both run packaging EPR, but the rules differ. Both require producers to register. Oregon asks for its first annual report earlier, on May 31 against June 1 in Italy. Every figure below links to its primary source.
Italy and Oregon side by side
2 of 9 rows have a verified figure on each side of Italy and Oregon; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.
| Measure | Italy | Oregon | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | producer compliance schemes | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | none recorded; see thresholds | $5,000,000 | Not comparable |
| Lowest weight exemption | none recorded; see thresholds | 1 tonne | Not comparable |
| First annual report date | June 1 | May 31 | Oregon |
| Published penalties | 2 published | 1 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 65.00 EUR/tonne | 2.0 cents per pound | Not comparable |
| Plastic fee, cheapest matched rate | not yet published | 12.0 cents per pound | Not comparable |
Both programmes require a producer to register, in Italy and in Oregon.
The earliest annual report date is June 1 in Italy and May 31 in Oregon, 1 day apart. Oregon leaves less time to prepare, so its data has to be ready first.
Who runs the programme in Italy and Oregon
Who collects and who the producer files with, in Italy and then Oregon.
| Aspect | Italy | Oregon |
|---|---|---|
| Regime | Legislative Decree 152/2006, Part IV Title II (packaging and packaging waste), CONAI consortium system | Oregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021) |
| Regulator | Ministry of Environment and Energy Security (MASE); CONAI coordinates the consortium system | Oregon Department of Environmental Quality (DEQ) |
| Producers obligated | Yes | Yes |
| Registration | Required, CONAI membership (declaration and contribution to CONAI, then consortium of material) | Required, Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry |
| Producer organisation | producer compliance schemes: CONAI, Comieco (paper), Corepla (plastic), Coreve (glass), Rilegno (wood), CiAl (aluminium), Ricrea (steel); membership optional | one producer responsibility organisation: Circular Action Alliance; membership required |
| Transfer of responsibility | Allowed | Allowed |
| Revenue counted as | not yet published | organisation gross revenue, USD, fiscal year |
| Who counts as the producer | primary: manufacturer or brand owner, importer, first distributor; secondary: manufacturer or brand owner, importer, first distributor; service: manufacturer or brand owner, importer, first distributor; shipping: online marketplace seller, manufacturer or brand owner; tertiary: manufacturer or brand owner, importer, first distributor | other: first distributor; primary: manufacturer or brand owner, brand licensee, importer; secondary: manufacturer or brand owner, brand licensee, importer; service: first distributor; shipping: packer and shipper; tertiary: first distributor |
The two programmes are organised differently. Italy uses producer compliance schemes; Oregon uses one producer responsibility organisation. For a seller in both, that usually means two different counterparties, two different sign-up routes and two different sets of terms to read before the first report is due.
What Italy and Oregon cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Italy or Oregon has no verified entry for it in the dataset.
| Aspect | Italy | Oregon |
|---|---|---|
| Materials covered | paper and cardboard, plastic, glass, wood, steel, aluminium | packaging, printing and writing paper, food serviceware |
| Product classes covered | primary, secondary and tertiary packaging placed on the Italian market, in proportion to quantity | packaging, printing and writing paper, food serviceware |
| Sales channels addressed | domestic producers and users, importers | physical retail, remote sale, other distribution |
| Producer duty: primary packaging | manufacturer_brand_owner; importer; first_distributor | manufacturer_brand_owner; licensee; importer |
| Producer duty: secondary packaging | manufacturer_brand_owner; importer; first_distributor | manufacturer_brand_owner; licensee; importer |
| Producer duty: tertiary packaging | manufacturer_brand_owner; importer; first_distributor | first_distributor |
| Producer duty: shipping packaging | online_marketplace_seller; manufacturer_brand_owner | packer_shipper |
| Producer duty: service packaging | manufacturer_brand_owner; importer; first_distributor | first_distributor |
| Reporting categories | 6, material, with paper and plastic sub-bands | 60, covered material type by material class |
| Labelling | Required: UNI technical standards for labelling; MASE technical guidelines: All packaging must be labelled per UNI standards to aid collection, reuse and recycling and inform consumers on final destinations. | not yet published |
| Published targets | recycling rate, all packaging waste 65% by 2025-12-31; recycling rate, all packaging waste 70% by 2030-12-31 | statewide_plastic_recycling_rate 25 by 2028-12-31; statewide_plastic_recycling_rate 50 by 2040-12-31; statewide_plastic_recycling_rate 70 by 2050-12-31 |
| Excluded from scope | not yet published | beverage containers under bottle bill, bound books, napkins paper towels and cleaning paper, rigid pallets, industrial or manufacturing specialty packaging, drug packaging, items used or sold on a farm, architectural paint containers in paint stewardship, privately recycled material on claim |
| Producer duty: other packaging | not yet published | first_distributor |
| Exemption 1 | not yet published | A small producer is exempt from PRO membership. Seven ways to qualify: nonprofit, public body, revenue under $5 million, under 1 metric ton, small beverage manufacturer, restaurant or food cart that is not a food-serviceware producer, single retail establishment with no online sales and no franchise or chain. |
| Exemption 2 | not yet published | Product-specific exclusions from "covered product" listed in ORS 459A.863(6)(b)(A)-(R) and OAR 340-090-0840(2), such as Bottle Bill containers, bound books, drug packaging, farm items and architectural paint containers. |
| Exemption 3 | not yet published | Material recycled through a non-Opportunity-to-Recycle collection, not separated at a commingled facility, and disposed to a responsible end market can be exempted if the producer demonstrates it to DEQ. Producers still report gross supply. (application needed) |
Thresholds and exemptions in Italy and Oregon
Every verified threshold Italy and Oregon publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| Italy | packaging weight | 10 tonnes per calendar year | reduced duty | packaging made available for the first time in the Member State |
| Oregon | revenue | $5,000,000 | exempt below | gross revenue, most recent fiscal year |
| Oregon | packaging tonnage | 1 metric ton | exempt below | covered products sold in or into Oregon, most recent calendar year |
| Oregon | packaging tonnage | 5 metric tons | exempt below | covered products, including secondary and tertiary packaging for beverage containers, most recent calendar year |
| Oregon | revenue | $10,000,000 | flat-fee band | gross revenue, most recent fiscal year, or under 5 metric tons sold in or into Oregon |
Oregon exemption: A small producer is exempt from PRO membership. Seven ways to qualify: nonprofit, public body, revenue under $5 million, under 1 metric ton, small beverage manufacturer, restaurant or food cart that is not a food-serviceware producer, single retail establishment with no online sales and no franchise or chain. It does not have to be applied for.
Oregon exemption: Product-specific exclusions from "covered product" listed in ORS 459A.863(6)(b)(A)-(R) and OAR 340-090-0840(2), such as Bottle Bill containers, bound books, drug packaging, farm items and architectural paint containers. It does not have to be applied for.
Oregon exemption: Material recycled through a non-Opportunity-to-Recycle collection, not separated at a commingled facility, and disposed to a responsible end market can be exempted if the producer demonstrates it to DEQ. Producers still report gross supply. It must be applied for.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
Fees per kilogram for shared materials
One material class has a published rate on both sides; each row shows the cheapest rate that fits the class.
| Material class | Italy (EUR per kg) | Oregon (USD per kg) | Oregon in EUR, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 65.00 EUR/tonne | 2.0 cents per pound | not yet published | Not comparable |
Scaling the cheapest published rate by weight shows what the gap between Italy and Oregon amounts to for a given tonnage of one material. The amounts are the rate times the weight, nothing added.
| Material class | Kilograms | Italy fee (EUR) | Oregon fee (USD) | Oregon in EUR, approx. | Oregon minus Italy (EUR) |
|---|---|---|---|---|---|
| paper and board | 1 | €0.07 | $0.04 | not yet published | not yet published |
| paper and board | 10 | €0.65 | $0.44 | not yet published | not yet published |
| paper and board | 100 | €6.50 | $4.41 | not yet published | not yet published |
| paper and board | 1,000 | €65.00 | $44.09 | not yet published | not yet published |
| paper and board | 10,000 | €650.00 | $440.92 | not yet published | not yet published |
| paper and board | 100,000 | €6,500.00 | $4,409.25 | not yet published | not yet published |
The two schedules are in different currencies (EUR and USD) and the dataset holds no published exchange rate between them, so this page does not rank the fees. Compare them in your own currency before you decide.
Oregon: the 2027 fee schedule of Circular Action Alliance (Oregon PRO), effective January 1, 2027, is the source of the per-kilogram rates used on this page.
Italy: the 2026 fee schedule of CONAI (Comieco and other consortia), effective July 1, 2025, is the source of the per-kilogram rates used on this page.
Italy 2026: the category “Paper, monomaterial (band 1)” is published at 65.00 EUR/tonne.
Oregon 2027: the category “Kraft Paper” is published at 2.0 cents per pound.
Real packs usually land in a dearer category, so use the calculator for Italy and Oregon.
Deadlines in Italy and Oregon
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Italy | report | June 1 | the previous calendar year |
| Italy | other | August 12, 2026 | not yet published |
| Oregon | report | May 31, 2026 | calendar year 2025 |
| Oregon | other | July 1, 2025 | not yet published |
| Oregon | other | January 1, 2027 | not yet published |
| Oregon | report | December 31, 2026 | not yet published |
The earliest annual report date is June 1 in Italy and May 31 in Oregon, 1 day apart. Oregon leaves less time to prepare, so its data has to be ready first.
Penalties in Italy and Oregon
What each side has published; a side without an amount says so.
Italy penalty for producer that does not organise a system, join a consortium or adopt a return system: €15,500 to €46,500 per administrative fine.
Italy penalty for placing packaging on the market without the Art. 219(5) labelling: €5,000 to €25,000 per administrative fine.
Oregon penalty for failing to register or become a member of a producer responsibility organization: up to $25,000 per day.
Report formats in Italy and Oregon
How the report file for Italy compares with the one for Oregon.
| Aspect | Italy | Oregon |
|---|---|---|
| Layout | Italy packaging declaration (working layout) Working layout, sources reviewed 2026-11-04 | Oregon producer supply report by material category 2026-09-29 (built from CAA Oregon 2026 fee schedule) |
| Recipient | CONAI (Consorzio Nazionale Imballaggi) | Circular Action Alliance (Oregon PRO) |
| How it is submitted | CONAI 'Dichiarazioni on line' service (dichiarazioni.conai.org). The customer signs in and submits. | CAA producer portal. The customer signs in and submits. |
| File type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 4 | 4 |
| Required columns | 4 of 4 | 4 of 4 |
| Weight unit | kg | lb |
| Period basis | calendar year | calendar year |
The two layouts share a file type and a delimiter, but each programme names its own columns and categories, so one file cannot be sent to both programmes. Each report is built from the same underlying measurements and exported separately.
Which to plan for first, Italy or Oregon
Plan around the earlier report date first. Oregon asks for its first annual report on May 31, before Italy, so its data has to be ready first.
Questions about comparing these two programmes
Is Italy or Oregon stricter on packaging EPR?
Both require producers to register. Oregon asks for its first annual report earlier, on May 31 against June 1 in Italy.
Do I register in both Italy and Oregon?
Italy requires producers to register. Oregon requires producers to register.
How do the fees per kilogram compare in Italy and Oregon?
The two schedules share material classes but the dataset holds no published exchange rate between EUR and USD, so the fees are shown in each currency without a ranking.
Which deadline comes first, Italy or Oregon?
The earliest annual report date is June 1 in Italy and May 31 in Oregon, 1 day apart. Oregon leaves less time to prepare, so its data has to be ready first.
How these figures are made
Sources
- normattiva.it: N2Ls (2006) (uri res) retrieved
Original wording: I produttori e gli utilizzatori sono responsabili della corretta ed efficace gestione ambientale degli imballaggi e dei rifiuti di imballaggio
Original wording: I produttori e gli utilizzatori sono responsabili della corretta ed efficace gestione ambientale degli imballaggi
Original wording: aderire ad uno dei consorzi di cui all'articolo 223;
Original wording: in proporzione alla quantità di imballaggi immessi sul mercato nazionale
- normattiva.it: N2Ls (2006) (uri res) retrieved
Original wording: partecipano in forma paritaria al Consorzio nazionale imballaggi, in seguito denominato CONAI
- normattiva.it: N2Ls (2006) (uri res) retrieved
Original wording: costituiscono un Consorzio per ciascun materiale di imballaggio
- eur-lex.europa.eu: oj retrieved
Original wording: makes available for the first time on the territory of another Member State, directly to end users
Original wording: a quantity of packaging, including packaging of packaged products, of less than 10 tonnes during one calendar year
Original wording: of Annex IX to the competent authority responsible for the register, by 1 June for each full preceding calendar year.
Original wording: It shall apply from 12 August 2026.
Original wording: by 31 December 2030, a minimum of 70 % by weight of all packaging waste generated
- normattiva.it: N2Ls (2006) (uri res) retrieved
Original wording: sono puniti con la sanzione amministrativa pecuniaria da quindicimilacinquecento euro a quarantaseimilacinquecento euro
- comieco.org retrieved
Original wording: i consorzi Rilegno , Corepla e Coreve hanno aggiornato le stime
Original wording: Tutte le variazioni decorreranno dal 1° luglio 2025 , con un secondo aumento previsto per il contributo ambientale vetro
Original wording: Fascia 1 - Monomateriale Base 65,00 65,00
- normattiva.it: N2Ls (2006) (uri res) retrieved
Original wording: Tutti gli imballaggi devono essere opportunamente etichettati secondo le modalità stabilite dalle norme tecniche UNI applicabili
- oregon.gov: producers of covered products retrieved
Original wording: producers of products covered under Oregon's Recycling Modernization Act (packaging, paper, and food serviceware)
Original wording: Circular Action Alliance, at present, is Oregon's only approved Producer Responsibility Organization
Original wording: In order to access CAA's data reporting portal, producers must first sign the Producer Participant Agreement with CAA
Original wording: was allowed to begin charging fees from member producers on July 1, 2025
Original wording: Large producer first impact disclosure date of Dec. 31, 2026
Original wording: is a Class 1 violation that can result in fines of up to $25,000 per day.
- oregon.public.law: ors 459A.869 retrieved
Original wording: each producer must register with and be a member of a producer responsibility organization that administers a producer responsibility program
Original wording: A producer is not required to be a member of a producer responsibility organization if, for all covered product the producer sells
- oregon.public.law: ors 459A.863 retrieved
Original wording: Has a gross revenue of less than $5 million for the organization's most recent fiscal year
Original wording: Sold in or into Oregon less than one metric ton of covered products for use in this state in the most recent calendar year
Original wording: that sold in or into Oregon less than five metric tons of covered products
Original wording: "Covered product" means: (A) Packaging; (B) Printing and writing paper; and (C) Food serviceware.
- oregon.public.law: ors 459A.866 retrieved
Original wording: the producer of the packaging is the person that manufactures the packaged item
- oregon.public.law: ors 459A.884 retrieved
Original wording: a producer responsibility organization shall establish uniform membership fees for members that had a gross revenue of less than $10 million
- oregon.public.law: ors 459A.872 retrieved
Original wording: A small producer is exempt from the requirement to be a member of a producer responsibility organization
- oregon.gov: rma exemptions retrieved
Original wording: Covered product exemptions, meanwhile, are product-specific exemptions that exclude a given type of packaging
Original wording: The latest window for producers to submit claims for this exemption was Jan. 6 – March 31, 2026
Original wording: The next claims window will open in Jan. 2027.
- circularactionalliance.org: producer reporting retrieved
Original wording: Oregon's 2026 Report is due May 31, 2026, based on the 2025 Data Year.
- circularactionalliance.org: OR 2026 Fee Schedule Public retrieved
Original wording: Materials labeled N/A in the following table are not accepted on either the USCL or PRO Recycling Acceptance List.
- oregon.public.law: ors 459A.926 retrieved
Original wording: At least 25 percent by calendar year 2028 and in each subsequent year
- circularactionalliance.org: OR 2027FeeSchedule 100126 retrieved
Original wording: 2027 Oregon Producer Fees Schedule Fees for Program Year 2027
Original wording: Kraft Paper USCL 0.07 0.00 -0.05 0.02
The free plan is enough to start. We estimate and prepare; you sign and submit.