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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.

Paired bars comparing how many verified thresholds, deadlines and penalties Italy and Washington publish, and how many columns their report layouts hold.Italy / Washington (published items): Thresholds: Italy 1, Washington 2; Deadlines: Italy 2, Washington 8; Penalties: Italy 2, Washington 1; Report columns: Italy 4, Washington 4ItalyWashingtonpublished items02468Thresholds12Deadlines28Penalties21Report columns44
Source: Italy and Washington primary sources, retrieved 2026-11-05

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.

Italy and Washington: the measures both programmes publish
MeasureItalyWashingtonStricter
Registration dutyRequiredRequiredSame
Producer organisationproducer compliance schemesone producer responsibility organisationNot comparable
Lowest revenue exemptionnone recorded; see thresholds$5,000,000Not comparable
Lowest weight exemptionnone recorded; see thresholds907.2 kgNot comparable
First annual report dateJune 1May 31Washington
Published penalties2 published1 publishedNot comparable
Report filecsvcsvNot comparable
Paper fee, cheapest matched rate65.00 EUR/tonnenot yet publishedNot comparable
Plastic fee, cheapest matched ratenot yet publishednot yet publishedNot 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.

Italy and Washington: how each programme is set up
AspectItalyWashington
RegimeLegislative Decree 152/2006, Part IV Title II (packaging and packaging waste), CONAI consortium systemWashington Recycling Reform Act, chapter 70A.208 RCW
RegulatorMinistry of Environment and Energy Security (MASE); CONAI coordinates the consortium systemWashington State Department of Ecology
Producers obligatedYesYes
RegistrationRequired, CONAI membership (declaration and contribution to CONAI, then consortium of material)Required, Producer registers with a PRO; the PRO registers with Ecology
Producer organisationproducer compliance schemes: CONAI, Comieco (paper), Corepla (plastic), Coreve (glass), Rilegno (wood), CiAl (aluminium), Ricrea (steel); membership optionalone producer responsibility organisation: Circular Action Alliance; membership required
Transfer of responsibilityAllowednot yet published
Revenue counted asnot yet publishedworldwide gross revenue, USD, prior fiscal 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 distributorprimary: 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.

Scope, producer duties, categories, labelling and targets, Italy and Washington
AspectItalyWashington
Materials coveredpaper and cardboard, plastic, glass, wood, steel, aluminiumpackaging, paper products
Product classes coveredprimary, secondary and tertiary packaging placed on the Italian market, in proportion to quantitypackaging, paper
Sales channels addresseddomestic producers and users, importersphysical retail, remote sale, other distribution
Producer duty: primary packagingmanufacturer_brand_owner; importer; first_distributormanufacturer; licensee; brand_owner; importer
Producer duty: secondary packagingmanufacturer_brand_owner; importer; first_distributornot yet published
Producer duty: tertiary packagingmanufacturer_brand_owner; importer; first_distributornot yet published
Producer duty: shipping packagingonline_marketplace_seller; manufacturer_brand_ownernot yet published
Producer duty: service packagingmanufacturer_brand_owner; importer; first_distributornot yet published
Reporting categories6, material, with paper and plastic sub-bandsnot yet published
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 2030-12-31not yet published
Excluded from scopenot yet publishedexempt materials
Exemption 1not yet publishedA de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits.
Exemption 2not yet publishedRegistered 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.

Verified thresholds in Italy and Washington
PlaceMeasureAmountEffectBasis as published
Italypackaging weight10 tonnes per calendar yearreduced dutypackaging made available for the first time in the Member State
Washingtonpackaging tonnage1 short tonexempt belowcovered materials introduced, most recent fiscal year
Washingtonrevenue$5,000,000exempt belowglobal 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.

Verified deadlines in Italy and Washington
PlaceKindDateCovers
ItalyreportJune 1the previous calendar year
ItalyotherAugust 12, 2026not yet published
WashingtonotherMarch 1, 2026not yet published
WashingtonreportMay 31, 2026not yet published
WashingtonregistrationJuly 1, 2026not yet published
WashingtonotherOctober 1, 2028not yet published
WashingtonotherMarch 1, 2029not yet published
WashingtonotherJanuary 1, 2030not yet published
WashingtonpaymentFebruary 15, 2031not yet published
WashingtonpaymentFebruary 15, 2032not 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.

Report file layouts for Italy and Washington
AspectItalyWashington
LayoutItaly packaging declaration (working layout) Working layout, sources reviewed 2026-11-04Washington interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance)
RecipientCONAI (Consorzio Nazionale Imballaggi)Circular Action Alliance (Washington PRO)
How it is submittedCONAI 'Dichiarazioni on line' service (dichiarazioni.conai.org). The customer signs in and submits.CAA producer portal. The customer signs in and submits.
File typecsvcsv
Encodingutf-8utf-8
Delimiter,,
Decimal separator.
Columns44
Required columns4 of 44 of 4
Weight unitkglb
Period basiscalendar yearcalendar 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

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. 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)
  9. 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.
  10. 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.
Model both: Italy and WashingtonCompare another pair

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