Italy Mandates Product Codes in E-Invoices for National Commission Tracked Goods

Italy's Revenue Agency (Agenzia delle Entrate) has mandated that businesses include specific product identification codes in electronic invoices for goods monitored by National Unique Commissions, effective from March 18, 2026, under new transparency requirements for agricultural supply chains.

The measure implements Article 3, paragraph 7-bis of Decree-Law No. 63/2024, which requires electronic invoices for products overseen by National Unique Commissions established under Article 6-bis of Decree-Law No. 51/2015 to contain a unique identification code for each product. The commissions monitor key agricultural supply chains including cereals, olive oil, wine, and livestock.

Technical Requirements

Businesses must use the standard XML format for ordinary invoices established by Revenue Agency Provision No. 433608/2022. For each covered product, invoices must include a specific data block (2.2.1.16 ) containing "CUN" in the data type field and the relevant product code from the official list published by the Ministry of Agriculture, Food Sovereignty and Forestry.

The Revenue Agency will transmit aggregated, anonymized data weekly to each National Unique Commission through B.M.T.I. S.c.p.A., the telematic commodity exchange that serves as the technical secretariat. Transmitted data includes the CUN product code, unit of measure, quantity, and total price, aggregated by product code and measurement unit.

Data Protection Framework

The Revenue Agency serves as data controller under GDPR Article 6(1)(e) for this public interest processing, with data stored in the Tax Registry information systems. Sogei S.p.A., the agency's technology partner managing the Tax Registry system, acts as data processor. Data transmission occurs through Italy's National Digital Data Platform established under Article 50-ter of Legislative Decree No. 82/2005.

Context

This requirement supports the National Unique Commissions' mandate to produce informational reports on agricultural market conditions and pricing transparency. The measure reflects Italy's broader push for supply chain transparency in key agricultural sectors, building on existing electronic invoicing infrastructure that has been mandatory for B2B transactions since 2019.