WEEE in Italy for non-EU sellers: Registro AEE (RAEE)

A business outside Italy that sells electrical or electronic equipment (AEE) straight to buyers in Italy is a producer there (art. 4(1)(g)(4)). It has to be in the Registro AEE before its first sale, and it may place equipment on the market only after it is registered (art. 29). This page is only what Italy adds to the EU WEEE rule. The other Italian rules are on the Italy page.

Who files, and through whom

A producer with no Italian seat registers through an authorised representative established in Italy. Art. 22(1) also says “personally”, but art. 29(5) applies DM 185/2007 art. 3(1), and the register takes a foreign-producer filing only from the representative. DM 185/2007 art. 3(1) reads: a producer not established in Italy registers “attraverso un proprio rappresentante in Italia”, and the chamber of commerce is the one where the representative has its seat. The register’s producer manual lists a foreign producer as one “iscritta dal rappresentante” (section 5.1) and says the filing goes in with the digital-signature device of the representative (section 8). The register’s English page says the same of a distance seller not established in Italy: it appoints an authorised representative.

For a seller in an EU state the Directive says the same: a distance seller not registered in the country it sells to registers through its authorised representative (Directive 2012/19/EU Art. 16(1), 17(2)).

The representative is a legal person established in Italy, or a natural person who is the legal representative of a company established in Italy. It is appointed by written mandate (art. 30(1)). Art. 30(1) opens with a producer seated in another EU state, so a seller outside the EU reaches art. 30 through art. 22(1). Three points follow from the texts:

• A representative that registers a producer answers for the producer’s duties, the registration charges included (art. 29(5)).
• That representative is also responsible for organising the free one-for-one take-back of equivalent waste equipment across Italy (art. 22(1)).
• The register’s form asks for the VAT number of a company in an EU state, and for another identification code for a company in any other country (manual, section 8.1). A seller in the United States or the United Kingdom is covered by that second line.

The register is now part of the national register of producers, RENAP. The environment ministry says the Registro AEE was integrated into it by ministerial decree n. 144/2024 (MASE), and producers already in the Registro AEE were registered in RENAP without a new filing (Registro AEE, 7 May 2025). The general EPR article that creates RENAP, art. 178-ter(8) of D.Lgs. 152/2006, names EU-seated producers only for its representative clause. For electrical equipment the representative route comes from the WEEE decree above.

The registration, in order

1. Appoint the representative in Italy by written mandate. The representative files.
2. A producer of household equipment joins a collective scheme first. The register checks the membership when the application is made (DM 185/2007 art. 3(4)). The coordination centre (CdC RAEE) lists the schemes: fifteen consortia of household-equipment producers and one of professional-equipment producers (CdC RAEE). A producer may instead set up an individual system, which the ministry must recognise first (art. 9). Joining a scheme is a free choice, and a producer that leaves for another scheme may not be obstructed (art. 10(1)).
3. File electronically at the Registro AEE on registroaee.it, signed with a digital-signature device that carries an authentication certificate. You state your activity code, the categories and types of equipment, the brand, how you meet the financing duties and the scheme you chose, and the sales technique, distance selling included (producer manual, 1.2.4).
4. The financial guarantee comes with the registration, given by the scheme or by the producer’s own system. See below.
5. The system issues a registration number. Show it on all commercial documents within thirty days of issue (DM 185/2007 art. 3(8), (9)).

New equipment types are added by a change filing before they go on the market, and a new brand is added by a change filing too (producer manual, section 9.1.2). The manual sets a time only for the equipment.

A registration in another EU country does not cover Italy: the register you must be in is the one of the country you sell to (EU WEEE rule).

The guarantee

A producer places equipment on the market with a financial guarantee. The collective scheme the producer joins gives it for its members. The producer gives its own only when it complies with its duties individually (art. 25(1)). The guarantee relates to waste equipment from households only (DM 68/2017 art. 1(2)). It lasts one year and is given at registration, so it is renewed every year (DM 68/2017 art. 2). The forms are a deposit, a bank guarantee, an insurance policy or a guarantee from a registered financial intermediary. A scheme can instead send a declaration that it has adequate financial capacity (DM 68/2017 art. 3). A producer that joins a scheme is covered by the scheme’s guarantee.

What it costs

The first three lines are the amounts in the producer manual on the RENAP portal, version 2.2 of 23 January 2020 (section 1.2.6). The law sets the secretariat fee at the level charged for electronic filings in the companies register (DM 185/2007 art. 5(2)).

The tariff lines come from DM 17 June 2016 (art. 2). The fixed part is EUR 10.00 a year for each producer, whatever its market share. The variable part follows the market share that the supervisory committee calculates from the annual communications. The tariffs are published in the producer’s reserved area by 30 June and paid by 30 September; late payment adds interest at the legal rate (arts. 2(5), 6). For 2024 the register published the tariffs on 28 April 2026 and allowed payment without interest until 30 June 2026 (Registro AEE). A collective scheme may pay for its members.

The scheme’s own contribution is separate. It follows the cost of collecting and treating the waste, and each scheme publishes the values for each item of equipment (art. 8(3-bis)). Italy lets the producer add the contribution to the sale price and show it separately on invoices to distributors; the price shown to the end user may disclose it (art. 8(3)).

Deadlines

• Before the first sale. Registration comes first, whatever the volume. The registration article sets no threshold (art. 29(2), (4)).
• Within thirty days of issue. The registration number goes on all commercial documents.
• Before new equipment goes on sale. A change filing. A new brand is added by a change filing as well. The end of the activity is notified the same way (DM 185/2007 art. 4).
• Every year. The annual communication of the quantities placed on the market in the previous year, through the environmental declaration (MUD) model (DM 185/2007 art. 6). The default deadline is 30 April (Law 70/1994 art. 6(2)). When a decree of the Prime Minister approves a changed form, it is 120 days after that decree is published (art. 6(2-bis)). For the 2025 data the decree was published on 5 March 2026, so the date was 3 July 2026, and the portal opened for it on 30 March 2026 (Registro AEE, 13 March 2026).
• Every year, by 30 June and 30 September. The tariffs are published, then paid. The guarantee is renewed each year.

Taking old equipment back when you sell online

For a producer outside Italy, the free one-for-one take-back falls on the authorised representative. Art. 22(1) makes the representative responsible for organising the take-back of equivalent waste equipment, one for one, across the whole country.

The duty behind it is the free one-for-one take-back: when a distributor supplies a new item, it takes back the used equivalent without charge (art. 11(1)). Taking back very small waste equipment from households without a purchase (one for zero) is compulsory for shops with 400 m2 or more of equipment sales area. A distributor that sells at a distance may do it on a voluntary basis (art. 11(2)). Every distributor, distance sellers included, must tell consumers clearly that the take-back is free, for example in a notice on its website (art. 11(3)). Sellers that sell at a distance may use the collection place of another distributor that does not sell at a distance, or organise their own (art. 11(5)). The site where waste is stored before collection is reported on the portal of the coordination centre (art. 11(4)); the coordination centre says registering that site costs nothing (CdC RAEE).

A distributor that sells by distance communication, teleshopping and electronic sales included, must say in its offer how the buyer can return old equipment free of charge. It states either its collection points or the places agreed with it where the buyer can hand in equivalent waste, or the free collection at the place of delivery, at no more cost than a sale that is not at a distance would bring (art. 22(2)). The statement is an essential element of the contract. Without it the contract is void and the buyer can claim back the full price (art. 22(3)).

Art. 22(2)-(3) bind distributors, and art. 4(1)(h) defines a distributor as a person enrolled in the Italian companies register. The same business can be a distributor and a producer at once. A seller enrolled in that register is bound by both paragraphs. The coordination centre reads art. 22 more widely: it says every retailer that sells equipment online must take back equivalent waste and state how (CdC RAEE, secondary source).

Marking and information

Every item carries a mark that identifies the producer: its name, its registered logo or its register number. The mark follows the technical standard CEI EN 50419:2023-02 and has to be visible, legible and indelible. The crossed-out bin symbol goes on the item as well. Where size or function makes that impossible, both go on the packaging, the instructions and the guarantee (art. 28). The instructions for use carry the waste information (art. 26(1)): the duty not to throw it in mixed household waste and to collect it separately; the take-back and collection systems, and how to hand an equivalent item to the distributor; the potential effects on the environment and human health of hazardous substances and of wrong handling; the buyer’s role in reuse, recycling and recovery; and what the symbol means. The symbol itself is in the WEEE symbol guide.

If you sell through a marketplace

A producer that places a product under an EPR regime on the Italian market through an e-commerce platform stays subject to that regime. It may meet its duties through services the platform operator must offer under agreements signed with the consortia or management systems of art. 237 of the code (art. 178-quater(1), (3)). The services are scheme membership, passing on the data, payment of the environmental contribution and communicating the information to the bodies named in art. 178-ter(1)(e) (art. 178-quater(4)). For the packaging title of the code, those agreements cover only producers with a seat outside Italy that gave the platform a written mandate (art. 178-quater(10)).

For electrical equipment, no agreement under art. 178-quater(3) was found on 4 October 2026. Art. 178-quater(8) provides a section of the national register for platform operators that sign such agreements and, in simplified form, for the producers selling through them; no text read shows that section open. While no agreement exists, the platform service does not replace the Registro AEE registration: the services in art. 178-quater(4) do not include the filing in the register.

What happens if you do nothing

The fines are in art. 38. They are administrative fines and apply where the act is not a crime.

Art. 38(7) applies arts. 262 and 263 of D.Lgs. 152/2006 to finding and imposing the fines. Art. 262(1) gives the power to impose them to the province in whose territory the violation was committed. The supervisory committee plans inspections of producers that do not make their communications, with ISPRA and, for inspections, the Guardia di finanza (art. 35).

Batteries inside or sold with your equipment have their own register and representative: see the EU Battery Regulation and Italy battery registration. The same representative role under the packaging rules is in the EPR authorised representative.