CONAI eco-modulation: how Italy's packaging fee rewards recyclable design

By Laura G. Sabbadini · Published July 10, 2026

The 9 CONAI plastic packaging fee bands: from the highest fee (band C) to the lowest (A1.1) according to packaging recyclability.

Eco-modulation ties Italy's CONAI environmental contribution (CAC) to a pack's end-of-life performance: the more recyclable and better-designed it is, the less it costs. For the same weight and material, two plastic packs can carry fees differing by up to roughly 1:20 — from €40/t to €790/t. In Italy this is the economic lever that already anticipates the requirements the PPWR will make mandatory in 2030.

What it is

CONAI (the Italian National Packaging Consortium) runs Italy's Extended Producer Responsibility (EPR) system for packaging, in continuity with national waste law and aligned with Art. 44 of Reg. (EU) 2025/40 (EPR schemes). The CONAI environmental contribution is owed by those who produce or import packaging and funds collection, recycling and recovery. Since 2018 the system has been progressively differentiated to reward more virtuous materials and design — this is eco-modulation.

The fee is set by technical recyclability (design class and supply-chain availability), sortability in collection streams, composition (mono-material vs multi-material vs composite) and post-consumer recycled content. These are the same parameters as PPWR Art. 6 (recyclability) and Art. 7 (recycled content): designing for one pays off on the other. (Source: CONAI 2026 Guideline — eco-modulation).

Update in progress. CONAI's board has defined an upward re-modulation of the plastic CAC across all bands, effective 1 October 2026. The exact values are being finalised: this page will be updated once consolidated. The figures below are those in force from 1 January 2026.

What it means for your SKU

Plastic is structured in 9 fee bands. They range from band A1.1 (€40/t) — rigid mono-material in clear PET or HDPE for food liquids, with an efficient recycling stream — up to band C (€790/t), which catches non-sortable or non-recyclable packaging, and where PVC and carbon-black plastic always land. In between sit flexibles and multi-materials (B1, B2) with rising fees as recyclability falls.

The operational point is that the band isn't a destiny: it's the consequence of design choices you can change. Moving from a multi-material (B2.2, €724/t) to a mono-material flexible (B1.1, €219/t) is worth −€505/t. Removing carbon black from a black plastic and bringing it back to clear PET can be worth up to −€750/t. Replacing opaque PET with clear PET is worth −€188/t. On a single 50-tonne/year line, redesigning a PET bottle from band B1.2 to A1.1 is worth €9,400/year in fee alone.

This is where CONAI and PPWR become the same decision: every euro of CAC saved runs through the same choices — mono-materiality, recycled content, sortability — that make the SKU compliant with Articles 6 and 7 by 2030. The redesign you do for the fee is the redesign you need for compliance.

What to do now

Map the portfolio by CONAI band and quantify the annual fee per SKU (weight × band rate).
Isolate high-band packs (B2.x and C): they are both the costliest and the most Art. 6-at-risk for 2030.
Estimate the saving of a redesign to a lower band and compare it to project cost: the business case often pays back before the regulatory deadline.
Book certified recycled content where Art. 7 needs it: it's scarce and also rewarded in some CONAI bands.
Watch the new values effective 1 October 2026: the upward re-modulation raises the cost of staying high-band — and so the return on redesign.

FAQ

What is CONAI fee eco-modulation? The mechanism that differentiates the CAC rate by a pack's end-of-life performance: recyclability, sortability, composition and recycled content.

How many bands does plastic have? Nine fee bands, from A1.1 (lowest) to C (highest), plus a special regime for composites.

How much can the jump between bands be worth? For the same weight and material, up to roughly 1:20 — from €40/t to €790/t.

What changes with the 2026 re-modulation? CONAI defined new upward plastic CAC values across all bands, effective 1 October 2026. The exact values are being finalised.

How are CONAI and the PPWR linked? Eco-modulation already rewards the same parameters (recyclability, recycled content) the PPWR will make mandatory in 2030 via Articles 6 and 7.