In Italy a sleeve, a pigment or a fibre share can cut a pack's CONAI fee by more than half

How the CAC is charged

The CAC is a per-tonne fee that the last producer or trader of empty packaging applies when it sells to the first user in Italy, or that a self-producer pays on the packaging material it buys. It has applied since 1 October 1998, under Legislative Decree 152/2006, and is invoiced with the unit weight by material and the fee per band shown on the invoice (CONAI EPR fee page, consulted 22 October 2026; SPI fee-market note for Italy, 14 October 2026). Importers of packaged goods declare it themselves unless a CONAI-registered foreign supplier has already paid.

That structure has a practical consequence for brand owners. The fee usually arrives on a converter’s invoice rather than in the brand’s own filing, so the band a pack lands in depends on information the buyer gives the seller. CONAI’s guidance on paper composites says it plainly: at the first transfer, the producer or trader must ask the user for the information it needs to set the band, unless it already has it (CONAI, instructions for the Aticelca attestation, consulted 22 October 2026). For rigid PP in band B2.1, a footnote on the plastic list allows customer self-certification.

Declarations are periodic. New members declare quarterly in their first year; from the second year the frequency is annual, quarterly or monthly according to the fee declared per material the year before, with paper and plastic bands added together, and every periodic declaration is due by the 20th day of the month after the period (CONAI declaration and payment page, last modified 5 May 2026). CONAI invoices on behalf of each of the seven consortia, one invoice per material on the ordinary procedure and one invoice for all materials on the simplified procedure.

Membership itself is cheap. The fixed quota is EUR 5.16, paid once, with a variable quota for firms with revenue above EUR 500,000 in the year before joining, capped at EUR 100,000 in total (CONAI guide 2026). The fee that matters is the CAC, and the SPI EPR & Plastic Tax Calculator holds 22 Italian rate rows for it. The EPR fees per tonne piece sets Italy’s rows beside 13 other markets, each in its own currency.

Importers have three simplified routes. From 1 October 2026 they can pay a flat rate on the weight of the packaging alone, whatever the material, at EUR 131 per tonne, rising to EUR 132 on 1 January 2027, or a value-based rate of 0.25% for food and 0.11% for non-food goods, which CONAI says stays unchanged in 2027 (CONAI, 2 July 2026). SPI analysis: the flat tare rate sits between bands B1.2 (EUR 304) and A1.1 (EUR 51), so an importer whose packs are mostly glass, paper or metal pays more on the flat route than on the bands, while one with mostly band C plastic pays less.

The plastic bands: circuit, sortability and recyclability

CONAI introduced modulation for plastic on 1 January 2018 and for paper on 1 January 2019, after its board approved the project in 2016 (CONAI modulated plastic fee page, last modified 5 August 2026). The plastic logic has three letters. Band A covers packaging that is sortable and recyclable from the commercial and industrial (C&I) circuit. Band B covers packaging mainly from the household circuit, with B1 for packs whose sorting and recycling chain is consolidated and B2 for chains that are still consolidating or developing. Band C covers packaging that cannot be sorted or recycled with current technology (CONAI guide 2026).

The sub-bands came in steps. In 2019 there were four plastic rates: A at EUR 150, B1 at EUR 208, B2 at EUR 263 and C at EUR 369 per tonne (CONAI release, 1 October 2018). B1 was later split so that PET (B1.2) is priced apart from HDPE (B1.1), and nine bands came into force in 2023 (CONAI modulated plastic fee page). Exhibit 2 sets out what each band holds in the 2026 list.

Four general rules on the list carry most of the weight. Anything not listed falls into band C. PVC packaging and components are band C except in A1.1 and A1.2. Carbon black colouring puts a pack in band C except in the A bands, although carbon black in printing ink is tolerated. Polylaminates made mainly of plastic and multilayer packaging fall into band C unless a reduced-fee list says otherwise (CONAI list, update of 25 March 2026).

Components are classed one by one. The list defines packaging as any component or ancillary element separately subject to the CAC, so a cap, label or pump can sit in a different band from the bottle it closes. Tethered caps for plastic beverage containers, in any band, and for liquid cartons sit in B1.1 at EUR 260, whatever the bottle’s band. Mechanical dispensers such as trigger sprays sit in B2.2. On rigid PP, a covering label or a mainly PP in-mould label counts as part of the pack.

The 2026 list also moved packs. From 1 January 2026, octabin caps and liners moved to A1.1, some PET and HDPE containers and labels moved from B2.2 to B1.1 or B1.2, and multilayer XPS trays moved from C to B2.3; PVC and carbon black were flagged to always fall in band C (CONAI release, 30 October 2025). The 25 March 2026 update added C&I beverage kegs with a confirmed recycling or reuse route to A1.1 and moved non-permeable single-serve tea and coffee units from C to B2.3. CONAI’s list says the definitions behind that entry follow the PPWR, effective 12 August 2026, but does not give a start date for the move itself. A practitioner report dates the B2.3 move from 12 August 2026 (Ambiens, 15 June 2026); SPI has not yet confirmed that date in a CONAI notice.

The paper bands: fibre share and Aticelca 501

Paper has one base rate, EUR 45 per tonne since 1 October 2025, when CONAI cut it from EUR 65 because recovered paper sold better than expected in 2024 and the first half of 2025 (CONAI, 7 July 2025). Composite packs then pay more according to how much of their weight is fibre, in the bands set out in Exhibit 3, which have applied since 1 July 2025.

A composite in CONAI’s sense is made structurally of two or more materials that cannot be separated by hand (CONAI guide 2026). The certified route rewards a test result rather than a fibre count: a pack graded at level B under Aticelca 501 pays EUR 55 instead of EUR 70, and one graded at level C pays EUR 110 instead of EUR 155. The assessment uses UNI 11743:2019, and the guide describes a voluntary trial period for the certification from July 2025 to July 2026. SPI has not yet confirmed what CONAI decided at the end of that trial.

The attestation is a paperwork step with a cash value. The user describes the pack, names the band and gives the Aticelca result, the attestation number, its issue date, the laboratory and the standard used, and sends it to the supplier before buying; it stays valid until the pack or the bands change (CONAI attestation instructions).

The other materials and the seven consortia

CONAI collects the fee; the consortia run collection and recycling for each material. RICREA handles steel, CiAl aluminium, Comieco paper and board, Rilegno wood, Corepla plastic, Biorepack certified compostable bioplastic and CoReVe glass (CONAI material consortia page, last modified 20 April 2026). Exhibit 4 shows each material’s rate and its 2025 recycling result.

Two new lines arrived with the PPWR’s definition of capsules and pods as packaging. From 1 October 2026, aluminium capsules, pods and sachets for tea, coffee or other drinks pay EUR 120 per tonne, made of the EUR 12 base plus a EUR 108 extra fee (CONAI EPR fee table). From 12 August 2026, compostable capsules and pods certified to EN 13432 pay EUR 45 per tonne, a temporary value to be reviewed after at least 12 months of monitoring (CONAI, 2 July 2026). Plastic single-serve units that are not compostable sit in B2.3 at EUR 917.

How the bands have moved since 2019

The plastic bands are repriced often, sometimes twice a year. Exhibit 5 tracks the nine bands across five rate periods.

Three things stand out. First, band C has risen from EUR 369 in 2019 to EUR 922, 2.5 times, while the PET band has gone from EUR 208 to EUR 304, 1.5 times. Second, the July 2025 step was the sharpest, with B2.1 up 38.5% and C up 20.6% in one move while B1.2 fell 22.7%. Third, the ratio of C to B1.2 has swung: 1.8 in 2019, 2.8 in early 2025, 4.4 in late 2025 and 3.0 since October 2026 (SPI calculation from Exhibit 5).

What moves a pack between bands

Every move in the CONAI list traces to a design choice that sorting machines or recyclers can see. Exhibit 6 lists the triggers that SPI found on the 2026 list, with the per-tonne effect at October 2026 rates.

The triggers fall into three families. Detection features decide whether sorting machines can see and route the pack: carbon black, which defeats near infrared sorting, and full-body sleeves, which hide the bottle’s polymer unless perforated so they can be removed. Material choices decide whether the recycler has a market: PVC and PETG go to band C, and a barrier above 5% EVOH leaves the B2.2 and B2.3 lists. Specification facts decide paper, where the fibre share must be stated or certified.

Not every trigger is a saving. Adding an EVOH barrier to a mono PP tub, a common shelf-life upgrade, moves it from B2.1 to B2.2 and adds EUR 217 per tonne. A mineral filler that pushes density above 1 g per cubic centimetre can take a PET bottle to band C, since the list ties several bands to that density limit.

A framework: fee reward against 2030 exposure

Two questions decide where to spend design effort in Italy: how much a move saves under the CAC today, and how exposed the starting format is to the PPWR’s recyclability grades from 2030. SPI uses CONAI’s band C definition, packs “not sortable or recyclable with current technology”, as a proxy for 2030 exposure, because the PPWR grades themselves await a delegated act due by 1 January 2028. Exhibit 7 sets the result out as a 2×2.

The quadrants explain why fee-led design programmes can stall in Italy. A team that ranks projects by CAC saving alone will do the sleeve and the tray, then stop, because a mono-material pouch saves EUR 66 per tonne and a PET blister EUR 5. Those are exactly the formats where the PPWR will make the decision instead, through the ban on packaging below grade C from 2030 (PR-EU-010).

The worked basket: five redesigns, in euro

SPI built a basket of 100 tonnes of household packaging placed in Italy and priced it at CONAI’s rates from 1 October 2026, before and after five design changes (Exhibit 8). The basket is an SPI assumption for illustration, not an industry average, and every line is in euro, so nothing is converted.

SPI calculation: before the redesigns the basket costs 40 x 856 + 20 x 922 + 10 x 922 + 5 x 922 + 25 x 155 = EUR 70,385, or EUR 703.85 per tonne. After them it costs 40 x 304 + 20 x 639 + 10 x 856 + 5 x 917 + 25 x 45 = EUR 39,210, or EUR 392.10 per tonne. The saving is EUR 31,175, or 44.3%.

The PET line dominates because it is both the heaviest and the line with the widest band gap. Perforating the sleeve saves EUR 22,080, 70.8% of the total. The tray recolour adds EUR 5,660 and the paper fibre change EUR 2,750. The pouch and blister changes together save EUR 685, 2.2% of the total, even though they are the two changes that most alter the recyclability of the pack.

Two cautions apply. The basket holds weight constant, which the scenario table tests. And the paper move from 70% to 90% fibre usually means a thinner coating or a different barrier, which is a product decision that the fee alone should not drive.

Scenarios: how much of the saving survives

Exhibit 9 runs the basket through four cases, each in euro at October 2026 rates unless stated.

SPI calculation: the heavier-pack case prices 42 tonnes of PET at EUR 304 and 26.25 tonnes of paper at EUR 45, giving EUR 39,874.25, so a 5% weight penalty on the two redesigned lines gives back only EUR 664.25 of the EUR 31,175 saving. Unchanged, the basket rose by EUR 9,900, or 16.4%, between the January and October 2026 rates.

The low case is the practical headline: one artwork change captures 71% of the full saving with no new material or supplier. The base case comes within EUR 685 of the high case.

Timing: the reward for redesign has grown

Because the bands are repriced so often, SPI also priced the 75 tonnes of plastic in the basket at each rate period since January 2025, holding the 2026 band lists constant (Exhibit 10).

The percentage saving has stayed in a band of 41% to 46%, but the euro reward has grown by 48% in under two years, because every band has risen. The unchanged plastic lines cost 43.1% more after October 2026 than in the first half of 2025. SPI analysis: for a finance team, that is the argument for funding redesign now. The proportional case is stable, and the absolute case strengthens with each CONAI review, and the plastic bands have been repriced three times since July 2025.

Labelling under D.Lgs. 116/2020

Fees and labels are separate duties in Italy, but they rest on the same facts about each component. Legislative Decree 116 of 3 September 2020, published on 11 September 2020, transposed the 2018 EU waste directives and made environmental labelling mandatory for all packaging released for consumption in Italy, through Article 219(5) of Legislative Decree 152/2006 (CONAI labelling portal, consulted 22 October 2026). After a suspension to 31 December 2022, the duty has applied since 1 January 2023, and packaging labelled or bought before that date could be sold through (CONAI labelling FAQ).

Ministerial Decree 360 of 28 September 2022, published on 21 November 2022, adopted the technical guidelines, which follow CONAI’s own (CONAI labelling portal). The guidelines cover primary, secondary and tertiary packaging alike, and set different content for consumer and business packs (Exhibit 11).

Digital channels can fully replace or supplement on-pack information, and CONAI’s vademecum suggests a page per pack and GS1 Digital Link QR codes as a stable standard (CONAI vademecum on digital channels).

The link to the bands is direct. A redesign that moves a pack between CONAI bands nearly always changes its material code or its separable components, so the label artwork changes at the same time. A perforated sleeve becomes a separable component that needs its own code and collection advice; a laminate pouch replaced by mono PE changes its code. SPI analysis: bundling the CAC redesign with the label update avoids paying for two artwork cycles.

The national label has an end date. CONAI says the current Italian labelling can stay until 11 August 2028, after which it is replaced by the harmonised EU label under Article 12 of Regulation (EU) 2025/40 (CONAI labelling portal). That label applies from 12 August 2028 at the earliest, and the Commission’s implementing act on sorting labels was still in preparation in October 2026 (PR-EU-003; Commission Green Forum, consulted 22 October 2026). The PPWR after August 2026 piece sets out the wider label timeline.

How PPWR recyclability grades will meet the bands

Article 6 of the PPWR requires all packaging to be recyclable. The measurable test arrives in layers: design for recycling from 1 January 2030, or 24 months after the Article 6(4) delegated acts enter into force if that is later, and recycling at scale from 2035 (Commission Notice C/2026/3084; PR-EU-010). CONAI’s vademecum sets out the grades per packaging unit by weight: grade A at 95% or more, grade B at 80% or more, and grade C at 70% or more. Below 70% a pack is technically non-recyclable and cannot be placed on the market from 2030, and from 2038 only grades A and B are allowed (CONAI PPWR vademecum, 30 September 2025).

The grades are written to feed fees. Recital 35 of the Regulation calls fee modulation “an effective economic instrument to incentivise more sustainable packaging design”, and says harmonised criteria will apply without the Regulation setting the amounts (EUR-Lex, Regulation (EU) 2025/40). CONAI’s vademecum reads Article 6(4)(d) as providing a framework to modulate producers’ contributions under Article 45(1) according to the grades, with national rules taking account of grades A, B and C from 2030. The delegated act carrying the design criteria is due by 1 January 2028 (Commission Green Forum).

The two systems measure different things. CONAI’s bands combine three tests: which circuit a pack comes from, whether Italy’s sorting plants can route it, and whether there is demand for the recyclate, which is why band B2 and C fractions with weak demand drove the October 2026 rise (CONAI, 25 May 2026). A PPWR grade is a design score for one pack, assessed against EU criteria, and from 2035 a recycled-at-scale test is added on top. The closest match is that recycled-at-scale test, which resembles CONAI’s line between consolidated B1 chains and developing B2 chains.

Whatever the outcome, two groups of packs face a double exposure. Clear thermoformed PET trays in band B2.3 already pay EUR 917, only EUR 5 below band C, because their recycling chain is experimental; if their design grade is also low, they pay near the top today and face a ban risk later. Band C packs that are not sortable today, such as carbon black trays and polylaminates, face the 2030 ban outright unless they reach grade C. By contrast, PET bottles and HDPE containers in B1 have a consolidated chain and a deposit or collection route, so they are the packs most likely to hold their position. The flexible packaging piece follows the film and laminate case in detail.

Tethered caps show how a component rule carries over. Since 3 July 2024 caps on single-use plastic drink containers of up to three litres must stay attached (PR-EU-015), and CONAI places tethered caps in B1.1 at EUR 260, below the B1.2 PET rate. Under the PPWR the cap travels with the bottle into the same stream, so cap material and attachment design will feed the bottle’s grade.

There is also a budget link. Italy has the largest lump-sum reduction on the EU plastic own resource, about EUR 184 million a year in 2020 prices, and the Commission’s proposal for 2028 to 2034 would end the reductions and raise the call rate to EUR 1 per kilogram of unrecycled plastic packaging waste (PR-EU-017; PR-EU-018). SPI has not yet confirmed whether Italy would pass any of that cost through CONAI, but it gives the state a reason to want plastic recycling above its 2025 rate of 50.5%.