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Italy vs United Kingdom EPR: Rules Compared

Last verified

Italy and United Kingdom both run packaging EPR, but the rules differ. Both require producers to register. United Kingdom asks for its first annual report earlier, on April 1 against June 1 in Italy. Every figure below links to its primary source.

Paired bars comparing how many verified thresholds, deadlines and penalties Italy and United Kingdom publish, and how many columns their report layouts hold.Italy / United Kingdom (published items): Thresholds: Italy 1, United Kingdom 3; Deadlines: Italy 2, United Kingdom 6; Penalties: Italy 2, United Kingdom 0; Report columns: Italy 4, United Kingdom 15ItalyUnited Kingdompublished items051015Thresholds13Deadlines26Penalties20Report columns415
Source: Italy and United Kingdom primary sources, retrieved 2026-11-04

Italy and United Kingdom side by side

2 of 9 rows have a verified figure on each side of Italy and United Kingdom; 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.

Italy and United Kingdom: the measures both programmes publish
MeasureItalyUnited KingdomStricter
Registration dutyRequiredRequiredSame
Producer organisationproducer compliance schemesproducer compliance schemesNot comparable
Lowest revenue exemptionnone recorded; see thresholdsnone recorded; see thresholdsNot comparable
Lowest weight exemptionnone recorded; see thresholdsnone recorded; see thresholdsNot comparable
First annual report dateJune 1April 1United Kingdom
Published penalties2 publishednot yet publishedNot comparable
Report filecsvcsvNot comparable
Paper fee, cheapest matched rate65.00 EUR/tonne196 GBP/tonneNot comparable
Plastic fee, cheapest matched ratenot yet published423 GBP/tonneNot comparable

Both programmes require a producer to register, in Italy and in United Kingdom.

The earliest annual report date is June 1 in Italy and April 1 in United Kingdom, 61 days apart. United Kingdom leaves less time to prepare, so its data has to be ready first.

Who runs the programme in Italy and United Kingdom

Who collects and who the producer files with, in Italy and then United Kingdom.

Italy and United Kingdom: how each programme is set up
AspectItalyUnited Kingdom
RegimeLegislative Decree 152/2006, Part IV Title II (packaging and packaging waste), CONAI consortium systemExtended producer responsibility (EPR) for packaging, under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024
RegulatorMinistry of Environment and Energy Security (MASE); CONAI coordinates the consortium systemFour environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets fees
Producers obligatedYesYes
RegistrationRequired, CONAI membership (declaration and contribution to CONAI, then consortium of material)Required, Report packaging data (RPD) service, run by Defra and the regulators
Producer organisationproducer compliance schemes: CONAI, Comieco (paper), Corepla (plastic), Coreve (glass), Rilegno (wood), CiAl (aluminium), Ricrea (steel); membership optionalproducer compliance schemes; membership optional
Transfer of responsibilityAllowedNot allowed
Revenue counted asnot yet publishedworldwide revenue, GBP, previous accounting year
Who counts as the producerprimary: 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 distributorother: manufacturer, importer, online marketplace; primary: brand owner, packer and shipper, importer, online marketplace, seller; secondary: brand owner, packer and shipper, importer, online marketplace, seller; service: brand owner, packer and shipper, manufacturer, importer, seller; shipping: brand owner, packer and shipper, importer, online marketplace, seller; tertiary: brand owner, packer and shipper, importer, online marketplace, seller

Both programmes organise producer responsibility the same way: producer compliance schemes. The practical differences between Italy and United Kingdom therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.

What Italy and United Kingdom cover, side by side

Each row below is one published feature of the two programmes; a cell reads “not yet published” when Italy or United Kingdom has no verified entry for it in the dataset.

Scope, producer duties, categories, labelling and targets, Italy and United Kingdom
AspectItalyUnited Kingdom
Materials coveredpaper and cardboard, plastic, glass, wood, steel, aluminiumaluminium, fibre based composite, glass, paper and card, plastic, steel, wood, other
Product classes coveredprimary, secondary and tertiary packaging placed on the Italian market, in proportion to quantityprimary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging
Sales channels addresseddomestic producers and users, importersretail, wholesale, online, online marketplace
Producer duty: primary packagingmanufacturer_brand_owner; importer; first_distributorbrand_owner; packer_shipper; importer; marketplace; seller
Producer duty: secondary packagingmanufacturer_brand_owner; importer; first_distributorbrand_owner; packer_shipper; importer; marketplace; seller
Producer duty: tertiary packagingmanufacturer_brand_owner; importer; first_distributorbrand_owner; packer_shipper; importer; marketplace; seller
Producer duty: shipping packagingonline_marketplace_seller; manufacturer_brand_ownerbrand_owner; packer_shipper; importer; marketplace; seller
Producer duty: service packagingmanufacturer_brand_owner; importer; first_distributorbrand_owner; packer_shipper; manufacturer; importer; seller
Reporting categories6, material, with paper and plastic sub-bands8, material and packaging class
LabellingRequired: 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 targetsrecycling rate, all packaging waste 65% by 2025-12-31; recycling rate, all packaging waste 70% by 2030-12-31plastic_recycling_obligation 57 by 2026-12-31; plastic_recycling_obligation 59 by 2027-12-31; glass_recycling_obligation 76 by 2026-12-31; glass_recycling_obligation 78 by 2027-12-31; aluminium_recycling_obligation 62 by 2026-12-31; aluminium_recycling_obligation 63 by 2027-12-31; steel_recycling_obligation 81 by 2026-12-31; steel_recycling_obligation 82 by 2027-12-31; wood_recycling_obligation 46 by 2026-12-31; wood_recycling_obligation 47 by 2027-12-31; paper_board_fibre_composite_recycling_obligation 77 by 2026-12-31; paper_board_fibre_composite_recycling_obligation 79 by 2027-12-31
Excluded from scopenot yet publishedcharities supplying or importing packaging
Producer duty: other packagingnot yet publishedmanufacturer; importer; marketplace
Exemption 1not yet publishedCharities that supply or import filled or unfilled packaging in the UK, excluding subsidiaries that trade for profit.

Thresholds and exemptions in Italy and United Kingdom

Every verified threshold Italy and United Kingdom publish, as each states it.

Verified thresholds in Italy and United Kingdom
PlaceMeasureAmountEffectBasis as published
Italypackaging weight10 tonnes per calendar yearreduced dutypackaging made available for the first time in the Member State
United Kingdompackaging tonnage25 tonnesregistration triggerpackaging supplied or imported in the UK in the previous calendar year
United Kingdomrevenue£1,000,000registration triggerworldwide annual turnover
United Kingdompackaging tonnage50 tonnesreduced dutywith turnover above 1 million and up to 2 million pounds, an obligated producer is small; above 50 tonnes with turnover over 2 million pounds is large

United Kingdom exemption: Charities that supply or import filled or unfilled packaging in the UK, excluding subsidiaries that trade for profit. It does not have to 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.

Cheapest published rate per kilogram by material class, Italy and United Kingdom
Material classItaly (EUR per kg)United Kingdom (GBP per kg)United Kingdom in EUR, approx.Higher fee
paper and board65.00 EUR/tonne196 GBP/tonnenot yet publishedNot comparable

Scaling the cheapest published rate by weight shows what the gap between Italy and United Kingdom amounts to for a given tonnage of one material. The amounts are the rate times the weight, nothing added.

Fee at the cheapest published rate for 1 to 100,000 kilograms, Italy and United Kingdom
Material classKilogramsItaly fee (EUR)United Kingdom fee (GBP)United Kingdom in EUR, approx.United Kingdom minus Italy (EUR)
paper and board1€0.07£0.20not yet publishednot yet published
paper and board10€0.65£1.96not yet publishednot yet published
paper and board100€6.50£19.60not yet publishednot yet published
paper and board1,000€65.00£196.00not yet publishednot yet published
paper and board10,000€650.00£1,960.00not yet publishednot yet published
paper and board100,000€6,500.00£19,600.00not yet publishednot yet published

The two schedules are in different currencies (EUR and GBP) 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.

United Kingdom: the 2025-26 fee schedule of PackUK extended producer responsibility for packaging (base fees), effective June 27, 2025, 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.

United Kingdom 2025-26: the category “Paper and card” is published at 196 GBP/tonne.

Real packs usually land in a dearer category, so use the calculator for Italy and United Kingdom.

Deadlines in Italy and United Kingdom

Each verified date, with the period it covers when one is given.

Verified deadlines in Italy and United Kingdom
PlaceKindDateCovers
ItalyreportJune 1the previous calendar year
ItalyotherAugust 12, 2026not yet published
United KingdomreportOctober 1, 2026the first half of 2026
United KingdomreportApril 1, 2027the second half of 2026
United KingdomreportApril 1, 20272026-P0
United KingdomregistrationOctober 1, 2026not yet published
United KingdomregistrationApril 1, 2027not yet published
United KingdomotherJanuary 31, 2027calendar year 2026

The earliest annual report date is June 1 in Italy and April 1 in United Kingdom, 61 days apart. United Kingdom leaves less time to prepare, so its data has to be ready first.

Penalties in Italy and United Kingdom

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.

Report formats in Italy and United Kingdom

How the report file for Italy compares with the one for United Kingdom.

Report file layouts for Italy and United Kingdom
AspectItalyUnited Kingdom
LayoutItaly packaging declaration (working layout) Working layout, sources reviewed 2026-11-04UK EPR packaging data file (large and small producer) 2026 specification, GOV.UK page last updated 19 August 2026
RecipientCONAI (Consorzio Nazionale Imballaggi)The four UK environmental regulators through the Report packaging data (RPD) service
How it is submittedCONAI 'Dichiarazioni on line' service (dichiarazioni.conai.org). The customer signs in and submits.Report packaging data service on GOV.UK. The customer, as an approved person, uploads the CSV. A compliance scheme can do this on the producer's behalf.
File typecsvcsv
Encodingutf-8utf-8
Delimiter,,
Decimal separator.
Columns415
Required columns4 of 46 of 15
Weight unitkgkg
Period basiscalendar yearhalf year

United Kingdom report specification: GOV.UK Report packaging data: create your reporting file, Table 1a (large producers) and Table 1b (small producers), with code tables 2 to 7

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 United Kingdom

Plan around the earlier report date first. United Kingdom asks for its first annual report on April 1, before Italy, so its data has to be ready first.

Questions about comparing these two programmes

Is Italy or United Kingdom stricter on packaging EPR?

Both require producers to register. United Kingdom asks for its first annual report earlier, on April 1 against June 1 in Italy.

Do I register in both Italy and United Kingdom?

Italy requires producers to register. United Kingdom requires producers to register.

How do the fees per kilogram compare in Italy and United Kingdom?

The two schedules share material classes but the dataset holds no published exchange rate between EUR and GBP, so the fees are shown in each currency without a ranking.

Which deadline comes first, Italy or United Kingdom?

The earliest annual report date is June 1 in Italy and April 1 in United Kingdom, 61 days apart. United Kingdom leaves less time to prepare, so its data has to be ready first.

How these figures are made

Our reviewers.

Sources

  1. 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
  2. normattiva.it: N2Ls (2006) (uri res) retrieved
    Original wording: partecipano in forma paritaria al Consorzio nazionale imballaggi, in seguito denominato CONAI
  3. normattiva.it: N2Ls (2006) (uri res) retrieved
    Original wording: costituiscono un Consorzio per ciascun materiale di imballaggio
  4. 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
  5. normattiva.it: N2Ls (2006) (uri res) retrieved
    Original wording: sono puniti con la sanzione amministrativa pecuniaria da quindicimilacinquecento euro a quarantaseimilacinquecento euro
  6. 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
  7. 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
  8. gov.uk (how to comply with packaging recycling obligations as a large producer) retrieved
    Original wording: go to schedule 5 of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (as amended)
    Original wording: A compliance scheme cannot pay your waste disposal fees for you.
    Original wording: you must meet your recycling obligations, including submitting your certificate or statement of compliance, by 31 January 2027
    Original wording: Packaging recycling targets 2025 to 2027
  9. gov.uk: epr for packaging what you must do as a small producer retrieved
    Original wording: Each of the 4 nations of the United Kingdom has its own regulator. You’ll be reporting to and monitored by the regulator for your nation.
    Original wording: the fee is: £1,303 if you register directly with your environmental regulator £696 if you register through a compliance scheme
    Original wording: Compliance schemes are third parties that help organisations meet the EPR for packaging requirements.
    Original wording: annual turnover of more than £1 million and supplies more than 25 tonnes and no more than 50 tonnes of packaging
  10. gov.uk: check if you must comply with epr for packaging 2 retrieved
    Original wording: you supplied or imported more than 25 tonnes of packaging in the UK in the previous year
    Original wording: you must get your annual turnover from the last accounts that were available before 7 April 2026.
    Original wording: your annual turnover worldwide was £1 million or more
    Original wording: Charities that supply or import filled or unfilled packaging in the UK are exempt from EPR for packaging requirements.
  11. legislation.gov.uk: 1 retrieved
    Original wording: a brand owner; (ii) a packer/filler; (iii) an importer or first UK owner; (iv) a distributor; (v) an online marketplace operator;
  12. gov.uk (packaging data check reporting periods and submission deadlines) retrieved
    Original wording: 1 January to 30 June 2026 1 October 2026
    Original wording: 1 July to 31 December 2026 1 April 2027
    Original wording: 1 January to 31 December 2026 1 April 2027
    Original wording: you must register for EPR for packaging each year, and pay the applicable fees by 1 October.
    Original wording: you must register for EPR for packaging each year, and pay a registration fee by 1 April.
  13. gov.uk: report packaging data create your reporting file retrieved
    Original wording: Report the weight of the individual materials used in the packaging you have supplied. You must report each material type separately.
    Original wording: Add a new row of data for each packaging activity and each type of packaging you need to report.
  14. gov.uk (2025) retrieved
    Original wording: This document provides base fees for year 1 (2025 to 2026) of the Extended Producer Responsibility (EPR) for packaging scheme.
    Original wording: Paper and card 196
Model both: Italy and United KingdomCompare another pair

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