Selling into Italy from stock in Portugal

A seller shipping goods from Portugal to Italian customers meets three national layers on top of EU rules. Packaging must carry environmental labelling under Article 219(5) of Legislative Decree 152/2006, in force since 1 January 2023, with material coding based on Commission Decision 97/129/EC. Packaging placed on the Italian market is covered by the CONAI system and its environmental contribution, all consumer information must be at least in Italian under Article 9 of the Consumer Code, and electrical equipment needs registration in Italy’s national register before sale.

Each of these rules has an official reference point, and each can be settled before the first shipment leaves Portugal.

What environmental labelling does packaging need in Italy?

Legislative Decree 116/2020 amended Italy’s Environmental Code, Legislative Decree 152/2006, and made environmental labelling of packaging mandatory. The Chamber of Commerce of Bolzano summarises the rule, found in Article 219(5): all packaging must be labelled according to the applicable UNI technical standards and the determinations of the European Commission, to make collection, reuse, recovery and recycling easier.

Two elements matter most.

• Material identification. Packaging indicates the nature of its materials, using the identification codes and abbreviations of Commission Decision 97/129/EC. This applies to every packaging component, whether primary, secondary or tertiary.
• Sorting instructions for consumers. Packaging that reaches consumers, the B2C flow, also tells them how to separate it for collection. The guidelines treat packaging that only travels between businesses, the B2B flow, separately.

The obligations have applied since 1 January 2023. Packaging already on the market, or labelled before that date without the required information, could be sold until stock ran out.

Can packaging information be given digitally in Italy?

Yes, within limits. Technical guidelines on packaging labelling under Article 219(5) were published on 22 November 2022, and the Chamber of Commerce of Bolzano notes that they allow digital means to carry the mandatory information, in line with the free movement of goods. CONAI, the national packaging consortium, provides an application and a guide for using digital channels.

For a seller whose packs serve several countries, this is useful. A printed code or symbol can point to Italian sorting instructions online, instead of adding another block of text to a crowded label. What must still appear physically, and what may move to a digital channel, is set out in the guidelines and should be checked per pack.

Who has to join CONAI and pay the environmental contribution?

CONAI, the Consorzio Nazionale Imballaggi, runs Italy’s packaging recovery system. Under Article 221 of Legislative Decree 152/2006, as summarised by the tax portal FiscoeTasse, two groups must join: packaging producers, who make or import packaging and packaging materials, and packaging users, who buy packaging or packaged goods and place them on the Italian market.

Members pay the Contributo Ambientale CONAI, the environmental contribution that finances recovery and recycling. It applies at the “prima cessione”, the first transfer of packaging on Italian territory. Importers of packaged goods also declare and pay the contribution on the packaging they bring in, through specific procedures.

The EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, has applied since 12 August 2026 and reshapes producer responsibility across the EU. Germany has used it to require an authorised representative for sellers without a German branch, as set out in selling into Germany from stock in Portugal. For Italy, CONAI is the reference point for how the new rules apply to a given seller.

Must product information be in Italian?

Yes. Article 9 of the Consumer Code, Legislative Decree 206/2005, is short and clear.

• “Tutte le informazioni destinate ai consumatori e agli utenti devono essere rese almeno in lingua italiana.” All information intended for consumers and users must be given at least in Italian.
• Where information appears in several languages, it also appears in Italian, with visibility and legibility no lower than the other languages.
• Expressions in other languages that have entered common use are allowed.

“At least in Italian” means other languages may sit beside it. A multilingual pack for Portugal, Spain and Italy works, provided the Italian text is complete and as visible as the rest. Sector rules add their own requirements; cosmetics follow the Cosmetics Regulation, as set out in holding cosmetics stock for the EU market.

Do I need to register electrical equipment in Italy?

Yes. Italy’s WEEE rules, known as RAEE, are set by Legislative Decree 49/2014. Article 29 establishes the national register of producers of electrical and electronic equipment, held by the Chambers of Commerce.

The Chamber of Commerce of Bologna sets out the essentials:

• Producers register before they begin to operate in Italy.
• Registration is done only online, through registroaee.it.
• The producer definition covers those who manufacture, have equipment made, resell under their own brand, or bring equipment into the Italian market, whatever the sales method, including distance selling.
• Producers established in another EU state or in a third country that sell equipment in Italy at a distance must also register.
• The registration number is issued electronically and must appear on transport documents and invoices within 30 days of issue.

The WEEE Directive 2012/19/EU, Article 17, adds the EU-level rule: a producer established in one member state that sells electrical equipment into another appoints an authorised representative there. Batteries inside the equipment bring the battery rules into play as well, covered in shipping lithium batteries from an EU warehouse.

A worked example

Suppose a maker of electric hair tools from outside the EU releases its stock for free circulation in Portugal and sells to Italian consumers through its own web shop and a marketplace. The details are hypothetical, for the mechanics only.

Before the first Italian order, it prepares four things. Packaging labels that code every component under Decision 97/129/EC and give Italian sorting instructions, printed or through a digital channel the guidelines allow. A CONAI position for the packaging it places on the Italian market, with the environmental contribution declared. Italian instructions, warnings and warranty information, as visible as the other languages on the pack. And a registration in the national register of electrical equipment producers, with the number on its Italian invoices and transport documents.

The parcels then travel from Portugal as intra-EU domestic freight. The VAT on those consumer sales is a separate question, covered in OSS, IOSS, and what they do not cover.

What if an Italian distributor buys the goods?

CONAI’s system distinguishes producers of packaging from users of packaging. A business that buys packaged goods and places them on the Italian market is a packaging user in that sense, and the contribution is linked to the first transfer on Italian territory. When an Italian distributor or retailer buys the goods, who declares what is therefore a point for the supply agreement, not an assumption.

The same applies to the other layers. Whose name is on the equipment registration, who supplies Italian consumer information, and who answers for the packaging labels are questions an Italian trade buyer raises before listing a product. What European distributors ask before signing sets out the wider list.

A seller with both a web shop and a distributor in Italy runs two flows from the same stock. The direct flow carries the full set of obligations; the distributor flow is settled in each contract.

What does the seller check before the first Italian sale?

1. Every packaging component coded under Decision 97/129/EC, with consumer sorting instructions.
2. The CONAI position and who declares the contribution on the packaging.
3. Italian consumer information, complete and equally visible.
4. RAEE registration, where electrical equipment is sold, and the number on documents.
5. The GPSR operator details on the product, for consumer goods.

This is general information, not legal advice. National duties for a specific product are confirmed with the relevant register, CONAI and the seller’s advisers.

How this runs at EFC

EFC’s base in Portugal, run with its logistics partner, holds stock inside the EU and ships it to customers in Italy and across Europe, after release for free circulation. EFC does not register brands with CONAI or in the national register of electrical equipment producers, and gives no legal advice. For consumer products, its GPSR Responsible Person role is described on responsible person, and outbound shipping on fulfilment.

Sources

Label	Value	Source
Environmental labelling	Article 219(5) of D.Lgs. 152/2006 as amended by D.Lgs. 116/2020; in force since 1 January 2023; Decision 97/129/EC coding; B2C sorting instructions; sell-out of earlier stock	Chamber of Commerce of Bolzano, environmental labelling of packaging, opened 2026-09-15
Digital means	guidelines of 22 November 2022 allow digital means; CONAI application and guide	Chamber of Commerce of Bolzano, environmental labelling of packaging, opened 2026-09-15
CONAI membership and contribution	Article 221 of D.Lgs. 152/2006; producers and users; contribution at first transfer; importers of packaged goods	FiscoeTasse, CONAI: packaging and obligations, opened 2026-09-15
PPWR	Regulation (EU) 2025/40; applies from 12 August 2026	European Commission, packaging waste, opened 2026-09-15
Italian language	Article 9 of the Consumer Code: at least in Italian; equal visibility; common foreign expressions allowed	Brocardi.it, Codice del consumo, art. 9, opened 2026-09-15
RAEE register	Article 29 of D.Lgs. 49/2014; registration before operating; online via registroaee.it; distance sellers from other states; number on transport documents and invoices within 30 days	Chamber of Commerce of Bologna, register of producers of electrical and electronic equipment, opened 2026-09-15
WEEE Directive	authorised representative for producers selling into another member state	Directive 2012/19/EU, Article 17, EU text on legislation.gov.uk, opened 2026-09-15