Lorax Compliance Environmental Blog . . .

CONAI: Plastic Packaging reporting changes
by Emma Mundy at 14:15 in Circular Economy, Environmental, Packaging

CONAI, the Italian packaging scheme, are making changes to their reporting requirements in 2017. The first amendment will be to diversify the environmental contribution for plastic packaging based upon the environmental impact it has. Plastic has been chosen as it is the most complex material in terms of variety of types, selection and recycling technologies.

CONAI will be adjusting the costs for plastic based on three guiding principles:

  • Ease of selection  

  • Recyclability

  • Where the packaging ends up once it becomes waste (Domestic or Commerce and Industry)

During this initial application phase, plastic packaging will be subsidised if it falls within a pre-determined list broken down into "Commerce & Industry" and "Domestic" categories. Each of these categories contains examples of the subsidized items such as bottles, caps, shrink wrap, pallets, and pumps. "Commerce & Industry" plastics will attract a greater subsidy than "Domestic" items. Packaging that is not recyclable with current technologies will fall into a 3rd category and pay a higher contribution.

As the criteria of ease of selection and recyclability of plastics change over time, depending on consumption and waste management, CONAI have appointed a body to monitor these changes and make amendments to the lists where required.

 

What reporting changes should be expected?

Some declaration procedures have been maintained. There are currently no changes to the environmental contribution exemption for packaging exports, simplified declaration procedures for importing filled packaging and exclusion formulas for certain packaging flows such as internal production cycles.

However, there are some reports which will change and we cover two of them in more detail below.

 

Form 6.1 Plastic

This form is currently used for any CONAI members making the first transfer of packaging i.e. importers of empty packaging or packaging producers. This form has now been adapted to extend to all importers of empty packaging/packaging materials, even if there is no first transfer and will be directly used by the importer. CONAI members need to indicate the type of activity to which the contribution refers from production/import of empty packaging/packaging materials, subject to first transfer and import of empty packaging/packaging materials for direct use by the importer/self-producer.

Forms 6.1 are available for all 6 materials (Alu, Steel, Wood, Plastic, Paper, Glass) but only the plastics form is subject to these changes.

Members of CONAI need to enter the quantities transferred with exemption and those that are subject to the contribution, as before, but now the plastic values need to be divided into the following 3 sub-categories:

  1. Selectable and recyclable packaging from the commerce and industry circuit

  2. Selectable and recyclable from the domestic circuit

  3. Packaging materials other than those under 1 and 2, not selectable/recyclable with current technologies

There is no need to further report a primary and secondary packaging breakdown. Each of the three categories includes a row for raw materials for packaging to self-producers where the relevant data can be entered. 

 

Form 6.2

This form was designed for consortium members who have imported packaging materials and empty or filled packaging. Moving forward, this form will be exclusively for importers for filled packaging. Importers of empty packaging must use form 6.1.

Members are required to enter information as covered in the existing procedure i.e. Material categories of Steel, Aluminium, Paper, Wood, Glass and Plastic. The difference under the new reporting method requires that plastics are broken down further, referencing the 3 new sub-categories (Domestic, Commerce & Industry, Non-Recyclable). You do not need to go into the level of detail required on form 6.1 and the Primary/Secondary split which currently exists has also been removed.

If members are not able to make the separation between the 3 categories, there are a number of different methods of splitting and calculating the data. We are happy to provide guidance depending on your product range and data requirements.

 

When do I need to make the changes?

The new changes will come into force from April 2017 and there will be a 6-month trial period. Any new contribution values will be announced at least 6 months before they enter into force.

 

There are a number of other reporting changes, if you would like further guidance, we are happy to help. Please contact us here​