Recent updates to CONAI diversification of plastic contribution
by Emma Mundy at 13:02 in Circular Economy, Emerging, Environmental, Packaging

Following on from our last blog CONAI: Plastic Packaging Reporting Changes here are the latest updates on packaging compliance in Italy and how you should be reporting for the remainder of 2017.

We have outlined two major changes in the CONAI scheme and we now have further information on the details and reporting schedules required.

As a refresher, CONAI will require their members to provide additional details about the plastic waste they are bringing to the market. Plastic has been chosen as it is the most complex material in terms of variety of types, selection and recycling technologies. This has impacts on the information you need to collect and the way you will now report it.

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1. Plastics changes

The first change has been to diversify the fee contribution for plastic packaging based upon the environmental impact it has. The diversified plastic categories have now been released and will be compulsory from the August submission (July data). CONAI will keep the current fee contribution the same for all plastics over the next 6 months during an adjustment period, but new fees are expected from January 2018.

The three criteria for contribution diversification are:

• Band A - Recyclable and Selectable plastic packaging from Commerce and Industry business streams

• Band B - Recyclable and Selectable plastic packaging from Household streams

• Band C – Plastic Packaging which is not Selectable or Recyclable according to current technologies

The definitions of Selectable and Recyclable are available from CONAI and outline how the packaging could be handled after use. The definitions are quite detailed (e.g. the packaging must exceed the minimum size so it can be read by an automated recycling sorter). CONAI have put together a guidance list (with pictures) to help out if you are uncertain. If your packaging does not fall into one of the 3 Bands, or you do not have the exact details of your packaging, you can use an 'overflow' category. There are 2 overflow categories, one for recyclable/selectable packaging and one for non-recyclable/selectable packaging. Prices will be determined by the criteria with categories A and B attracting lower fees, the overflow categories will be the highest.

Selectable and recyclable evolve over time so it is likely that this list will be interchangeable depending on current and future technologies. It's important that companies understand that this means their submission will be subject to change. CONAI have established a technical committee to monitor the developments in this area and will update the packaging lists accordingly.

2. Submission form reporting changes

In addition to the plastics changes, members of CONAI will also need to review their usage of the submission forms 6.1 and 6.2. These changes are also currently voluntary, but will come into force from next month's submission.

6.1 Empty packaging

Form 6.1 (producers/importers of empty packaging): is for those who have carried out the first sales of packaging or that have imported empty packaging/packaging material for direct use in the six mentioned materials. This form is now also extended to importers of empty packaging, which was previously reported under form 6.2. Consortium members must indicate the type of activity to which the environmental contribution declaration refers, selecting between:

• production/import of empty packaging/packaging materials, subject to first transfer

• import of empty packaging/packaging materials for direct use by the importer/self-producer

Form 6.1 continues to report material categories in more detail, and the way you report empty plastic packaging in form 6.1 is now further split by three bands A, B and C, which refers to the three criteria for contribution diversification. Lists of the packaging which falls into the contribution bands are available from CONAI. Bands A and B contain an exhaustive list of packaging, if your packaging type does not fit into Band A or B then it must fall into band C.

6.2 Filled packaging

Form 6.2 (importers of packaging packaged goods/full): is now limited to importers of filled packaging. For plastic material, consortium members must split their declaration into the 3 Bands listed above. Whilst you do not need to go to the level of detail as required in 6.1, you will need this information in order to select a category. Finally the requirement to split your report by primary, secondary and tertiary packaging has been removed.

If you would like any further information CONAI have released a series of documentation and a technical guide which is available via their website​, or you can get in touch with us here for more guidance.

Please note: Plastic is the first material to be reported via this method due to its large environmental impact and CONAI are the first scheme to enforce such a level of detail. However with the development of the EU Circular Economy package and the focus on Plastics at an international level, we should expect that other materials and schemes may follow suit with similar requirements.

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