Plastic pallets: CONAI, plastic tax and EPR in Europe

In briefIn Italy, a new plastic pallet carries the CONAI environmental contribution at the first transfer: pallets are in band A1.1, at €40 per tonne in 2026, about €0.80 for a 20 kg pallet. The plastic taxes in Italy, the United Kingdom and Spain target single-use packaging: a pallet designed for reuse generally falls outside them, on the conditions set out below.

In Italy a new plastic pallet carries the CONAI environmental contribution on the invoice. The plastic taxes in Italy, the United Kingdom and Spain, on the other hand, target single-use packaging. Here you will find who pays what, country by country, with the rules as checked on 17 October 2026.

Note that CONAI, the Italian packaging recovery consortium, is an obligation in Italy only. Other countries have their own national EPR (extended producer responsibility) schemes, such as the Plastic Packaging Tax in the United Kingdom, the Spanish plastic tax and LUCID registration in Germany: you will find them further down, in the section on the United Kingdom, Spain and Germany.

This page is not tax advice. Have your own case checked by an adviser or directly by CONAI.

Who pays what: country by country

CONAI: the band for pallets and what it costs

In the CONAI list in force from 1 January 2026, the entry 'Pallet' is in band A1.1, together with rigid PP layer pads, for example ^[2]. This is the group of packaging with an established sorting and recycling chain, mainly in the commercial and industrial stream ^[2].

Band A1.1 has been €40/t since 1 July 2025; before that it was €24/t ^[1]. The CONAI 2026 Guide confirms €40/t for the whole of 2026 ^[3]. For comparison, band C, the most expensive, is €790/t ^[1].

The contribution is levied at the 'first transfer': when the manufacturer or trader of the empty packaging sells it to the first user ^[3]. The seller shows it on the invoice and you pay it with the price. If you import empty pallets from abroad, the procedures fall to you as the importer ^[3].

Reusable pallets and controlled loops

CONAI provides two favourable regimes for reusable packaging ^[4]:

• exclusion from the contribution for packaging used within your own production cycle or your own sales network;
• reduced-fee schemes for packaging that circulates in certain re-use loops: the contribution is applied when the packaging leaves the loop rather than when it is first placed on the market, or with a percentage weight reduction.

CONAI has specific rules for wooden pallets put back on the market and for new wooden pallets designed for reuse over several years ^[4]. For plastic pallets, new or used, the special cases page says nothing specific. If you run a closed loop or rent your pallets, ask CONAI which scheme applies before you set up your accounts. The European framework for reuse is in reusable pallets and the PPWR.

The Italian plastic tax: why a reusable pallet falls outside it

The plastic tax was introduced by the 2020 Budget Law (Law 160/2019, paragraph 634) ^[5]. It targets MACSI, the single-use plastic products that are not 'conceived, designed or placed on the market to perform multiple trips during their life cycle or to be reused for the same purpose' ^[5].

The rate is €0.45 per kilo. Recycled plastic contained in the product is left out of the calculation, and compostable products and packaging for medicines are excluded ^[6]. The 2026 Budget Law postponed its entry into force from July 2026 to January 2027 ^[6].

It follows from the definition that a pallet designed for reuse is not a MACSI. This is our own reading of the legal text. The law does not mention pallets, so an official clarification from the Italian Customs Agency (Agenzia delle Dogane) remains the reference to ask for. The risk mainly concerns lightweight pallets sold for one-way shipments.

United Kingdom, Spain, Germany

United Kingdom

The Plastic Packaging Tax does not apply to transport packaging used to import goods. Government guidance mentions reusable plastic crates, containers, pallets and other heavy-duty plastic packaging ^[7]. The exemption does not cover packaging that comes in empty ^[7]. For packaging with less than 30% recycled plastic, the rate is £228.82 per tonne from 1 April 2026 ^[8].

Spain

Ley 7/2022 introduced, from 1 January 2023, a tax of €0.45 per kilo on non-reusable plastic packaging, whether filled or empty ^[9]. The same law defines as single-use a product not designed to complete multiple trips or rotations ^[9]. A pallet designed for reuse should therefore fall outside it; the article that sets the scope of the tax needs to be read in full with your Spanish adviser.

Germany

Since 1 July 2022 the obligation to register in the LUCID register applies to all packaging filled with goods, including transport packaging such as pallets ^[10]. Transport packaging does not have to join a dual system, but there is a take-back obligation (§ 15 VerpackG) ^[10]. The source is a German law firm: check against the official register.

For phytosanitary rules on export, see pallets for export and ISPM 15.

Worked example and checklist for your accounts department

With band A1.1 at €40/t ^[1][3], the contribution per pallet is its weight in tonnes multiplied by €40:

These are small sums compared with the price of the pallet, which you will find in how much a plastic pallet costs. The paperwork matters more. Before you place an order, check:

1. that the Italian supplier's invoice shows the CONAI contribution;
2. the actual weight of the pallet, because the contribution is calculated on weight;
3. whether the manufacturer declares the pallet reusable, for the plastic tax and the Spanish tax;
4. if you import empty pallets, the CONAI procedures are your responsibility;
5. the rules in the destination country: PPT exemption only for loaded pallets in the United Kingdom, LUCID registration in Germany.

The cost comparison with wood is in plastic or wooden pallets.

Found a mistake or an outdated figure? Write to us at info@roll-packaging.com