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.
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.
| Measure | Italy | United Kingdom | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | producer compliance schemes | producer compliance schemes | Not comparable |
| Lowest revenue exemption | none recorded; see thresholds | none recorded; see thresholds | Not comparable |
| Lowest weight exemption | none recorded; see thresholds | none recorded; see thresholds | Not comparable |
| First annual report date | June 1 | April 1 | United Kingdom |
| Published penalties | 2 published | not yet published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 65.00 EUR/tonne | 196 GBP/tonne | Not comparable |
| Plastic fee, cheapest matched rate | not yet published | 423 GBP/tonne | Not 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.
| Aspect | Italy | United Kingdom |
|---|---|---|
| Regime | Legislative Decree 152/2006, Part IV Title II (packaging and packaging waste), CONAI consortium system | Extended producer responsibility (EPR) for packaging, under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 |
| Regulator | Ministry of Environment and Energy Security (MASE); CONAI coordinates the consortium system | Four environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets fees |
| Producers obligated | Yes | Yes |
| Registration | Required, CONAI membership (declaration and contribution to CONAI, then consortium of material) | Required, Report packaging data (RPD) service, run by Defra and the regulators |
| Producer organisation | producer compliance schemes: CONAI, Comieco (paper), Corepla (plastic), Coreve (glass), Rilegno (wood), CiAl (aluminium), Ricrea (steel); membership optional | producer compliance schemes; membership optional |
| Transfer of responsibility | Allowed | Not allowed |
| Revenue counted as | not yet published | worldwide revenue, GBP, previous accounting 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: 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.
| Aspect | Italy | United Kingdom |
|---|---|---|
| Materials covered | paper and cardboard, plastic, glass, wood, steel, aluminium | aluminium, fibre based composite, glass, paper and card, plastic, steel, wood, other |
| Product classes covered | primary, secondary and tertiary packaging placed on the Italian market, in proportion to quantity | primary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging |
| Sales channels addressed | domestic producers and users, importers | retail, wholesale, online, online marketplace |
| Producer duty: primary packaging | manufacturer_brand_owner; importer; first_distributor | brand_owner; packer_shipper; importer; marketplace; seller |
| Producer duty: secondary packaging | manufacturer_brand_owner; importer; first_distributor | brand_owner; packer_shipper; importer; marketplace; seller |
| Producer duty: tertiary packaging | manufacturer_brand_owner; importer; first_distributor | brand_owner; packer_shipper; importer; marketplace; seller |
| Producer duty: shipping packaging | online_marketplace_seller; manufacturer_brand_owner | brand_owner; packer_shipper; importer; marketplace; seller |
| Producer duty: service packaging | manufacturer_brand_owner; importer; first_distributor | brand_owner; packer_shipper; manufacturer; importer; seller |
| Reporting categories | 6, material, with paper and plastic sub-bands | 8, material and packaging 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 | plastic_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 scope | not yet published | charities supplying or importing packaging |
| Producer duty: other packaging | not yet published | manufacturer; importer; marketplace |
| Exemption 1 | not yet published | Charities 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.
| 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 |
| United Kingdom | packaging tonnage | 25 tonnes | registration trigger | packaging supplied or imported in the UK in the previous calendar year |
| United Kingdom | revenue | £1,000,000 | registration trigger | worldwide annual turnover |
| United Kingdom | packaging tonnage | 50 tonnes | reduced duty | with 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.
| Material class | Italy (EUR per kg) | United Kingdom (GBP per kg) | United Kingdom in EUR, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 65.00 EUR/tonne | 196 GBP/tonne | not yet published | Not 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.
| Material class | Kilograms | Italy fee (EUR) | United Kingdom fee (GBP) | United Kingdom in EUR, approx. | United Kingdom minus Italy (EUR) |
|---|---|---|---|---|---|
| paper and board | 1 | €0.07 | £0.20 | not yet published | not yet published |
| paper and board | 10 | €0.65 | £1.96 | not yet published | not yet published |
| paper and board | 100 | €6.50 | £19.60 | not yet published | not yet published |
| paper and board | 1,000 | €65.00 | £196.00 | not yet published | not yet published |
| paper and board | 10,000 | €650.00 | £1,960.00 | not yet published | not yet published |
| paper and board | 100,000 | €6,500.00 | £19,600.00 | not yet published | not 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.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Italy | report | June 1 | the previous calendar year |
| Italy | other | August 12, 2026 | not yet published |
| United Kingdom | report | October 1, 2026 | the first half of 2026 |
| United Kingdom | report | April 1, 2027 | the second half of 2026 |
| United Kingdom | report | April 1, 2027 | 2026-P0 |
| United Kingdom | registration | October 1, 2026 | not yet published |
| United Kingdom | registration | April 1, 2027 | not yet published |
| United Kingdom | other | January 31, 2027 | calendar 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.
| Aspect | Italy | United Kingdom |
|---|---|---|
| Layout | Italy packaging declaration (working layout) Working layout, sources reviewed 2026-11-04 | UK EPR packaging data file (large and small producer) 2026 specification, GOV.UK page last updated 19 August 2026 |
| Recipient | CONAI (Consorzio Nazionale Imballaggi) | The four UK environmental regulators through the Report packaging data (RPD) service |
| How it is submitted | CONAI '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 type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 4 | 15 |
| Required columns | 4 of 4 | 6 of 15 |
| Weight unit | kg | kg |
| Period basis | calendar year | half 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
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
- 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
- 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
- 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.
- 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;
- 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.
- 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.
- 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
The free plan is enough to start. We estimate and prepare; you sign and submit.