Italy vs Washington EPR: Rules Compared
Last verified
Italy and Washington both run packaging EPR, but the rules differ. Both require producers to register. Washington 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 Washington side by side
2 of 9 rows have a verified figure on each side of Italy and Washington; 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 | Washington | 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 | 907.2 kg | Not comparable |
| First annual report date | June 1 | May 31 | Washington |
| Published penalties | 2 published | 1 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 65.00 EUR/tonne | not yet published | Not comparable |
| Plastic fee, cheapest matched rate | not yet published | not yet published | Not comparable |
Both programmes require a producer to register, in Italy and in Washington.
The earliest annual report date is June 1 in Italy and May 31 in Washington, 1 day apart. Washington leaves less time to prepare, so its data has to be ready first.
Who runs the programme in Italy and Washington
Who collects and who the producer files with, in Italy and then Washington.
| Aspect | Italy | Washington |
|---|---|---|
| Regime | Legislative Decree 152/2006, Part IV Title II (packaging and packaging waste), CONAI consortium system | Washington Recycling Reform Act, chapter 70A.208 RCW |
| Regulator | Ministry of Environment and Energy Security (MASE); CONAI coordinates the consortium system | Washington State Department of Ecology |
| Producers obligated | Yes | Yes |
| Registration | Required, CONAI membership (declaration and contribution to CONAI, then consortium of material) | Required, Producer registers with a PRO; the PRO registers with Ecology |
| 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 | not yet published |
| Revenue counted as | not yet published | worldwide gross revenue, USD, prior 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 | primary: manufacturer, brand licensee, brand owner, importer |
The two programmes are organised differently. Italy uses producer compliance schemes; Washington 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 Washington cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Italy or Washington has no verified entry for it in the dataset.
| Aspect | Italy | Washington |
|---|---|---|
| Materials covered | paper and cardboard, plastic, glass, wood, steel, aluminium | packaging, paper products |
| Product classes covered | primary, secondary and tertiary packaging placed on the Italian market, in proportion to quantity | packaging, paper |
| 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; licensee; brand_owner; importer |
| Producer duty: secondary packaging | manufacturer_brand_owner; importer; first_distributor | not yet published |
| Producer duty: tertiary packaging | manufacturer_brand_owner; importer; first_distributor | not yet published |
| Producer duty: shipping packaging | online_marketplace_seller; manufacturer_brand_owner | not yet published |
| Producer duty: service packaging | manufacturer_brand_owner; importer; first_distributor | not yet published |
| Reporting categories | 6, material, with paper and plastic sub-bands | not yet published |
| 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 | not yet published |
| Excluded from scope | not yet published | exempt materials |
| Exemption 1 | not yet published | A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. |
| Exemption 2 | not yet published | Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. |
Thresholds and exemptions in Italy and Washington
Every verified threshold Italy and Washington 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 |
| Washington | packaging tonnage | 1 short ton | exempt below | covered materials introduced, most recent fiscal year |
| Washington | revenue | $5,000,000 | exempt below | global gross revenue, prior fiscal year |
Washington exemption: A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. It does not have to be applied for.
Washington exemption: Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. 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
Italy publishes per-kilogram rates in the dataset; Washington does not. The rows therefore show Italy only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Italy and Washington would mean inventing a figure, and this page does not do that.
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.
Deadlines in Italy and Washington
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 |
| Washington | other | March 1, 2026 | not yet published |
| Washington | report | May 31, 2026 | not yet published |
| Washington | registration | July 1, 2026 | not yet published |
| Washington | other | October 1, 2028 | not yet published |
| Washington | other | March 1, 2029 | not yet published |
| Washington | other | January 1, 2030 | not yet published |
| Washington | payment | February 15, 2031 | not yet published |
| Washington | payment | February 15, 2032 | not yet published |
The earliest annual report date is June 1 in Italy and May 31 in Washington, 1 day apart. Washington leaves less time to prepare, so its data has to be ready first.
Penalties in Italy and Washington
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.
Washington penalty for producer violating chapter 70A.208 RCW: up to $1,000 per day.
Report formats in Italy and Washington
How the report file for Italy compares with the one for Washington.
| Aspect | Italy | Washington |
|---|---|---|
| Layout | Italy packaging declaration (working layout) Working layout, sources reviewed 2026-11-04 | Washington interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance) |
| Recipient | CONAI (Consorzio Nazionale Imballaggi) | Circular Action Alliance (Washington 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 Washington
Plan around the earlier report date first. Washington 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 Washington stricter on packaging EPR?
Both require producers to register. Washington asks for its first annual report earlier, on May 31 against June 1 in Italy.
Do I register in both Italy and Washington?
Italy requires producers to register. Washington requires producers to register.
How do the fees per kilogram compare in Italy and Washington?
The dataset does not hold per-kilogram rates for the same material class on both sides, so this page does not compare fees.
Which deadline comes first, Italy or Washington?
The earliest annual report date is June 1 in Italy and May 31 in Washington, 1 day apart. Washington 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
- circularactionalliance.org: washington retrieved
Original wording: required in the Recycling Reform Act
Original wording: By January 1, 2026 Washington Department of Ecology must establish and appoint the initial membership of the advisory council.
Original wording: July 1, 2026 Washington regulatory deadline for Producers to register with a PRO.
Original wording: By March 1, 2026 A PRO must register with Washington Department of Ecology on behalf of its producers.
Original wording: By May 31, 2026 Reporting (Interim State Addendum Signed & Simplified Reporting)
- app.leg.wa.gov: default retrieved
Original wording: After July 1, 2026, be a member of a producer responsibility organization registered in this state
Original wording: Has a global gross revenue, not including on-premises alcohol sales, for the prior fiscal year of
Original wording: the producer is the person that manufactures the item
Original wording: In their most recent fiscal year introduced less than one ton of covered materials
Original wording: Until January 1, 2031, less than $5,000,000
Original wording: "De minimis producer" means a producer that
Original wording: Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations
Original wording: By October 1, 2028, and every five years thereafter, submit a plan that meets the requirements of this chapter
Original wording: Beginning March 1, 2029, a producer that is not a member in good standing with a registered producer responsibility organization
Original wording: By January 1, 2030, or within six months of plan approval, whichever is later, implement the plan approved by the department
Original wording: No less than 75 percent of the net costs by February 15, 2031
Original wording: No less than 90 percent of the net costs by February 15, 2032, and each year thereafter
Original wording: civil penalty of up to $1,000 per violation per day on any producer who violates this chapter
Original wording: "Covered material" means packaging and paper products introduced into the state.
- ecology.wa.gov: producer responsibility organization retrieved
Original wording: The Circular Action Alliance is the PRO representing producers in Washington. We encourage all potentially obligated producers to register with CAA.
The free plan is enough to start. We estimate and prepare; you sign and submit.