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

> Italy's Contributo Ambientale CONAI (CAC) prices plastic in nine bands, from EUR 51 to EUR 922 per tonne since 1 October 2026, and paper in eight bands from EUR 45 to EUR 285, so design details decide the band; on SPI's 100-tonne EUR basket, five redesigns cut the bill by 44.3%, from EUR 70,385 to EUR 39,210.

Publisher: Strategic Packaging Insights  
Published: 2026-10-26  
Last updated: 2026-10-26  
Page: https://www.strategicpackaginginsights.com/insights/italy-conai-fee-bands-explained/

**Italy's Contributo Ambientale CONAI (CAC) prices plastic in nine bands, from EUR 51 to EUR 922 per tonne since 1 October 2026, and paper in eight bands from EUR 45 to EUR 285, so design details decide the band; on SPI's 100-tonne EUR basket, five redesigns cut the bill by 44.3%, from EUR 70,385 to EUR 39,210.**

CONAI sorts plastic by which collection circuit a pack comes from and whether Italy can sort and recycle it, and sorts paper by its fibre share or an Aticelca 501 grade. Those rules sit in a published list that changes every year, and from 2030 they will have to take account of the recyclability grades in the EU Packaging and Packaging Waste Regulation (PPWR).

## Executive summary

Italy runs one of Europe's most finely graded packaging fees. The Contributo Ambientale CONAI is charged per tonne at the first transfer of packaging inside Italy, shown on the seller's invoice and passed through CONAI to seven material consortia. For steel, aluminium, wood and glass there is one rate per material. For plastic there are nine bands and for paper eight, and the gap between the cheapest and dearest plastic band reached 18.1 times on 1 October 2026 (CONAI EPR fee table, consulted 22 October 2026).

The bands are not abstract. CONAI's 2026 list, last updated on 25 March 2026, names the features that move a pack: a covering sleeve that is not perforated, carbon black pigment, PVC, a polylaminate structure, an EVOH barrier above 5% of weight, a density above 1 g per cubic centimetre, or simply not appearing on the list, which puts a pack in band C. For paper, the band follows the share of fibre by weight, or a certified Aticelca 501 level, and a pack whose fibre share is not stated falls to the top band at EUR 285 per tonne.

On SPI's worked basket of 100 tonnes, priced in euro only at CONAI's rates from 1 October 2026, five redesigns cut the fee from EUR 70,385 to EUR 39,210, a fall of 44.3% (Exhibit 8). Most of the saving comes from one change: perforating the sleeve on 40 tonnes of PET bottles moves them from band B2.2 at EUR 856 to band B1.2 at EUR 304. Replacing a PVC blister with clear PET saves just EUR 5 per tonne.

Rates are moving. Plastic rose in every band on 1 October 2026, with B1.2 up 33.3% on the January value, and CONAI has announced glass at EUR 48 and wood at EUR 12 per tonne from 1 January 2027 (CONAI, 2 July 2026). Doing nothing cost the SPI basket 16.4% more after October than before it.

The next shift is regulatory. From 2030 the PPWR grades packaging A, B or C on recyclability, at 95%, 80% and 70% by weight, and CONAI's own guidance says national fee modulation must then take those grades into account (CONAI PPWR vademecum, 30 September 2025). Leaders should map every Italian pack to its band now, fix the cheap design moves before 2027 budgets close, and read the CONAI list as an early guide to 2030 exposure.

## Key findings

1. From 1 October 2026 CONAI's plastic bands run from EUR 51 per tonne (A1.1) to EUR 922 (C), a ratio of 18.1, and paper runs from EUR 45 to EUR 285, a ratio of 6.3 (CONAI EPR fee table, consulted 22 October 2026).
2. A non-perforated covering sleeve moves a PET bottle from band B1.2 (EUR 304) to B2.2 (EUR 856), a step of EUR 552 per tonne from one artwork feature; direct printing or a multilayer wall takes the same bottle to band C, EUR 618 above B1.2 (CONAI list, update of 25 March 2026).
3. **SPI calculation:**  five redesigns on a 100-tonne basket cut the CAC from EUR 70,385 to EUR 39,210 at October 2026 rates, a fall of 44.3%, and 71% of the saving comes from the sleeve change alone.
4. Plastic rose in all nine bands on 1 October 2026; CONAI cited higher volumes and weak demand for band B2 and C fractions, about 34% of what it manages (CONAI, 25 May 2026).
5. Glass rises 20% to EUR 48 per tonne and wood 20% to EUR 12 on 1 January 2027, and the flat import rate on packaging tare goes from EUR 131 to EUR 132 per tonne (CONAI, 2 July 2026).
6. Italy recycled 77.3% of the 14.2 million tonnes of packaging placed on its market in 2025, with plastic lowest at 50.5% and paper highest at 92.6% (CONAI, 16 July 2026).
7. **SPI analysis:**  CONAI bands price recycling cost and recyclate demand, while PPWR grades will price design per unit, so the two will not map one to one; packs in bands B2.3 and C carry the most risk of a double penalty.

## 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](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/) 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.

SPI analysis

The top of the plastic scale is now compressed. Band C is only EUR 5 per tonne above B2.3 and EUR 66 above B2.2, while the step from B2.2 down to B1.2 is EUR 552. In fee terms, the decisive line in Italy is whether a household pack reaches B1, not whether it escapes C.

## 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).

SPI analysis

The most expensive paper outcome is administrative. A composite whose fibre share is simply not stated pays EUR 285 per tonne, 6.3 times band 1, so the first saving on paper in Italy is often a specification sheet rather than a redesign.

## 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.

In practice: Corepla.

Italy recycled 1,161,000 tonnes of conventional plastic packaging in 2025, 50.5% of what was placed on the market, plus over 44,000 tonnes of compostable bioplastic (CONAI, 16 July 2026). CONAI's case for the October increase was that about 34% of the plastic it manages, mainly in bands B2 and C, has weak demand and no stable outlet, while auction revenue improved on just over 25%, and that the money is needed to keep the recycling rate at 50% or more (CONAI, 25 May 2026).

In practice: Comieco.

Paper and board are the other end of the scale: 4,612,000 tonnes recycled in 2025, a rate of 92.6% (CONAI, 16 July 2026). Better recovered paper prices let CONAI cut the paper base by 30.8%, from EUR 65 to EUR 45 per tonne on 1 October 2025, even as more board came from municipal collection under agreement with Comieco (CONAI, 7 July 2025). The composite bands, requested by Comieco, now carry the modulation that the base rate no longer does.

In practice: CoReVe and Rilegno.

Glass rises from EUR 40 to EUR 48 per tonne on 1 January 2027 because cullet prices stay low and demand is falling as wine and drinks consumption drops, so the cost of managing collected glass now exceeds what recycling it earns. Wood rises from EUR 10 to EUR 12 to keep Rilegno stable over the medium term, after a technical annex allowed more post-consumer wood to be collected from urban areas until 31 December 2029 (CONAI, 2 July 2026).

In practice: Biorepack.

The CAC for compostable bioplastic went from EUR 130 to EUR 246 per tonne on 1 July 2026, after CONAI's board consulted Biorepack and noted that the value had been more than halved in the previous three years; the rise is meant to balance income and costs while keeping adequate reserves (CONAI, 30 October 2025).

## 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).

SPI analysis

The ratio fell after October 2026 because B1.2 rose faster than C, but the euro gap per tonne grew from EUR 562 to EUR 618. A redesign case built on 2025 rates therefore understates the cash reward of moving a household pack into B1 today.

## 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.

SPI analysis

The largest savings sit in PET bottles and paper composites, where consolidated recycling and high recyclate demand already exist. The smallest sit in the formats the PPWR is most likely to grade low, such as PVC blisters and polylaminates, because CONAI already prices B2.3, B2.2 and C close together.

## 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 2x2.

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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)).

SPI analysis

Treat the "Compliance move" quadrant as a 2030 market-access budget, not a fee project. Its business case is the cost of losing the right to sell the pack, which the CAC table does not show.

## 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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-003/); Commission Green Forum, consulted 22 October 2026). The [PPWR after August 2026 piece](https://www.strategicpackaginginsights.com/insights/ppwr-after-august-2026/) 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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/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.

SPI analysis

Three outcomes are possible once grades exist, and they are not exclusive. CONAI could add the grade as an overlay inside each band, as Citeo applies maluses on top of its tariff; it could re-cut the bands around grades; or it could keep the bands and let the 2030 market ban remove grade-less packs from band C. SPI has not yet confirmed any CONAI decision on this, and the CONAI fee pages consulted on 22 October 2026 describe none.

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](https://www.strategicpackaginginsights.com/insights/flexible-packaging-recyclability-gap/) 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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-017/); [PR-EU-018](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/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%.

## Industry reaction

> "Le più recenti analisi confermano alcuni segnali di miglioramento dei ricavi da aste per specifiche frazioni di materiale"

In English: "The most recent analyses confirm some signs of improvement in auction revenues for specific material fractions"

***CONAI** , national packaging consortium, [announcement of new plastic CAC values](https://www.conai.org/news-e-press/imballaggi-in-plastica-definiti-i-nuovi-valori-del-contributo-ambientale-conai/), 25 May 2026*

CONAI said that improvement, on just over 25% of the plastic it manages, does not offset the cost pressure from higher volumes and weak demand for band B2 and C fractions, which is why every band rose on 1 October 2026.

> "Questo traguardo va tuttavia considerato una base di partenza, non un punto di arrivo"

In English: "This milestone should, however, be considered a starting point, not a finishing line"

***President of CONAI** , national packaging consortium, [release on 2025 recycling results](https://www.conai.org/news-e-press/litalia-supera-il-77-di-riciclo-degli-imballaggi/), 16 July 2026*

The milestone is Italy's 77.3% packaging recycling rate for 2025. The same release says companies will need to focus more on design for reuse in the coming years, and records EUR 892 million paid by CONAI to municipalities in 2025 for separate collection.

> "We inform you that until 11 August 2028 it will be possible to maintain environmental labelling in its current form."

***CONAI** , environmental labelling portal, [Etichettatura Ambientale degli Imballaggi](https://www.etichetta-conai.com/en/), consulted 22 October 2026*

The portal adds that the Italian label will then be replaced by harmonised EU pictogram labelling, still being defined, on the timeline in Article 12 of Regulation (EU) 2025/40.

## What leaders should do now

1. **Packaging and procurement leads, by 31 December 2026:**  map every pack sold in Italy to its CONAI band from the 2026 list, component by component, and check the bands your converters invoice against that map.
2. **Brand and design teams, at the next artwork cycle:**  move full-body sleeves on PET bottles to perforated designs and replace carbon black on rigid trays where the product allows; on SPI's basket these two moves deliver 89% of the saving.
3. **Paper packaging buyers, by the first 2027 order:**  state the fibre share for every paper composite and send Aticelca 501 attestations to suppliers before purchase, so no pack defaults to band 6 at EUR 285.
4. **Finance teams, before 2027 budgets close:**  load CONAI's October 2026 plastic rates and the 1 January 2027 glass, wood and import tare values into cost models, and stop using 2025 rates for redesign cases.
5. **Regulatory and sustainability teams, by 1 January 2028:**  prepare for the Article 6(4) design criteria by listing band B2.3 and C packs as the first candidates for grade testing.
6. **Labelling owners, before 11 August 2028:**  combine any band-driven redesign with the Italian label update, and plan the switch to the harmonised EU label in the same artwork programme.
7. **Importers of packaged goods, each declaration period:**  compare the flat tare rate (EUR 132 per tonne from 1 January 2027) against band pricing for your actual pack mix before choosing the simplified route.

## Questions for your board

- What did we pay in CONAI fees in 2026, by material and band, and how much of it came from band C?
- Which of our Italian packs could move to band B1 with an artwork change alone, and what is that worth at October 2026 rates?
- Do our converters invoice the CAC on the bands we expect, and who checks?
- How many of our packs sit in bands B2.3 or C today, and what is our plan if they fall below PPWR grade C in 2030?
- Have we budgeted for the 1 January 2027 rises in glass and wood, and for further plastic reviews in 2027?
- Will our Italian label redesign and our band redesign run as one programme?

## What to watch

- **27 Oct 2026:**  CONAI holds a webinar on the PPWR and green claims, listed on its home page as of 22 October 2026.
- **1 Jan 2027:**  glass rises to EUR 48 and wood to EUR 12 per tonne, and the import tare rate to EUR 132 (CONAI, 2 July 2026).
- **20 Jan 2027:**  declarations for December 2026 and the fourth quarter of 2026 fall due, the first full quarter at October 2026 plastic rates.
- **1 Jan 2028:**  the Article 6(4) design for recycling delegated act is due ([PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)), and the proposed 2028 own resources decision would end Italy's plastic lump-sum reduction ([PR-EU-018](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-018/)).
- **11 Aug 2028:**  last day for the current Italian label format before the harmonised EU label ([PR-EU-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-003/)).
- **1 Jan 2030:**  packaging below PPWR grade C barred at the earliest, and national fee modulation to take account of the grades (CONAI PPWR vademecum).

## Methodology

- **Data used:**  CONAI's 2026 fee table, its plastic list valid from 1 January 2026 (update of 25 March 2026), the 2026 guide (December 2025 update), CONAI releases from October 2018 to July 2026, CONAI labelling and PPWR guidance, EUR-Lex and Commission pages, SPI's Italy fee-market note (14 October 2026) and the 22 Italian rows in the SPI EPR & Plastic Tax Calculator. All consulted 22 October 2026.
- **Counting rules:**  EUR per tonne as published, excluding VAT; each line is rate times tonnes; no currency conversion and no figures from other currencies.
- **Basket:**  an SPI assumption of 100 tonnes (Exhibit 8), not a market average; weights held constant except in the stated scenario; bands as read from CONAI's English list, where the Italian text prevails.
- **Framework:**  the 2x2 cut-offs (EUR 250 per tonne; band C start) are SPI choices, and band C is a proxy for PPWR exposure, not a grade.
- **Cut-off:**  22 October 2026.
- **Limitations:**  CONAI assigns bands item by item and updates lists each year; the timing exhibit applies 2026 lists to 2025 rates; PPWR grades and fee rules await delegated acts. This is not an invoice or a legal view; confirm bands with CONAI and your supplier, and check with counsel where it applies.

## Sources

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14. CONAI, Vademecum sulle misure di prevenzione di cui al Regolamento 2025/40, 30 September 2025, [https://www.conai.org/wp-content/uploads/2025/09/VADEMECUM-CONAI-PPWR-Progettazione-degli-imballaggi.pdf](https://www.conai.org/wp-content/uploads/2025/09/VADEMECUM-CONAI-PPWR-Progettazione-degli-imballaggi.pdf), consulted 2026-10-22.
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23. SPI EPR & Plastic Tax Calculator (22 Italian rate rows) and SPI fee-market note for Italy (14 October 2026), /data/epr-plastic-tax-calculator/, consulted 2026-10-22.
24. SPI Regulation Tracker, rules PR-EU-003, PR-EU-010, PR-EU-015, PR-EU-017 and PR-EU-018, /data/packaging-regulation-tracker/european-union/, consulted 2026-10-22.