Selling into Italy from stock in Portugal

Three national layers sit on top of EU rules for a seller shipping from Portugal to Italian customers. They are environmental labelling on packaging, membership of the CONAI recovery system, and Italian on everything a consumer reads. Sell electrical equipment and a fourth applies, registration in the national producer register. Every one of these has an official reference point, and every one can be settled before goods leave Portugal.

Packaging labelling is mandatory since 2023

Legislative Decree 116/2020 amended Italy’s Environmental Code, Legislative Decree 152/2006, and made environmental labelling of packaging compulsory. Article 219(5) of Legislative Decree 152/2006 requires labelling according to UNI technical standards and European Commission determinations. The aim is that collection, reuse, recovery and recycling get easier downstream.

Two things sit inside that requirement. Every packaging component, primary, secondary or tertiary, carries a material code drawn from Commission Decision 97/129/EC. Packaging that reaches consumers, the B2C flow, also carries sorting instructions; packaging that only moves between businesses is treated separately. The obligation has run since 1 January 2023, and stock already labelled or on the market before that date could still be sold through.

Digital labelling helps here. Technical guidelines published 22 November 2022 allow the mandatory information to be carried digitally, in line with free movement of goods. CONAI provides its own application and guide for doing this. For a pack serving several countries, a code that points to Italian sorting instructions online can beat squeezing another text block onto a crowded label. What has to stay physical and what can move online is set out per pack in the guidelines.

CONAI membership follows two roles, not one

CONAI, the Consorzio Nazionale Imballaggi, runs Italy’s packaging recovery system under Article 221 of Legislative Decree 152/2006. Two groups 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.

Both pay the Contributo Ambientale CONAI, financing recovery and recycling, due at the “prima cessione”, the first transfer of packaging on Italian territory. Importers of already-packaged goods declare and pay the contribution on what they bring in, through their own procedure. The EU Packaging and Packaging Waste Regulation, which applies from 12 August 2026, reshapes producer responsibility EU-wide. For Italy specifically, CONAI remains the place to confirm how that reshaping applies to a given product.

Italian-language requirements for product information

Article 9 of the Consumer Code, Legislative Decree 206/2005, states it without qualification. “Tutte le informazioni destinate ai consumatori e agli utenti devono essere rese almeno in lingua italiana.” All information for consumers and users must be given at least in Italian. Where other languages appear alongside it, the Italian text must be no less visible or legible than they are. Common foreign expressions already in everyday use are allowed to stand as they are.

That “at least” is the operative word. A pack in Portuguese, Spanish and Italian works together, provided the Italian is complete and equally readable. Sector rules layer on top of this baseline; cosmetics, for instance, follow the Cosmetics Regulation, covered in holding cosmetics stock for the EU market.

Electrical equipment needs a RAEE registration first

Italy’s WEEE rules, RAEE, run under Legislative Decree 49/2014. Article 29 sets up a national producer register, held by the Chambers of Commerce and reached only online, through registroaee.it. Registration happens before operating in Italy, not after the first sale.

The producer definition is broad by design. It covers anyone who manufactures, has equipment made, resells under its own brand, or brings equipment into Italy, distance selling included. A producer based in another EU state or outside the EU that sells at a distance into Italy still registers. The registration number, issued electronically, has to appear on transport documents and invoices within 30 days of issue. Article 17 of the WEEE Directive adds the EU-wide backstop: a producer in one member state selling into another appoints an authorised representative there. Batteries built into equipment bring their own rules along too, covered in shipping lithium batteries from an EU warehouse.

A distributor changes who declares, not whether the rules apply

CONAI’s producer/user distinction matters here. A distributor that buys already-packaged goods and places them on the Italian market is a packaging user. The contribution is tied to that first transfer inside Italy. When an Italian distributor or retailer buys the goods instead of a consumer buying direct, who declares the contribution becomes a supply-agreement question. So does whose name carries the equipment registration, and who supplies the Italian consumer information; none of these are assumptions to make in advance. What European distributors ask before signing sets out the wider list a buyer usually raises.

A seller running both a web shop and an Italian distributor from the same stock carries the full obligation set on the direct flow. It settles the distributor flow contract by contract.

Checklist before the first sale in Italy

1. Every packaging component coded under Decision 97/129/EC, with consumer sorting instructions attached.
2. A CONAI position, with the party responsible for the contribution identified.
3. Italian consumer information, complete and as visible as any other language on the pack.
4. A RAEE registration, where electrical equipment is involved, with the number appearing on documents.
5. GPSR operator details on the product, for consumer goods.

CONAI, the relevant Italian register, and the seller’s own advisers confirm the national duties for a specific product. The five points are the questions worth asking; the answer for a given product is theirs to give, not EFC’s. Once these five are settled, parcels move from Portugal within the EU with no customs step. VAT on the consumer sales runs on its own track, set out in OSS, IOSS, and what they do not cover.

How EFC ships Italian orders from stock in Portugal

Stock for Italian customers holds at EFC’s base in Portugal and moves with its logistics partner. It ships across Europe after release for free circulation, described on fulfilment. The four items above are not something EFC takes over. We register no brand with CONAI or in the national equipment register, and give no legal advice. Of the four, the Italian-language requirement is the easiest to underestimate, because it looks like a translation task rather than a compliance one. For consumer products, our GPSR Responsible Person role is described on responsible person.

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 EUR-Lex, opened 2026-09-15