Industrial land: contaminated sites, clean-up, the ZLS and the free zone: what do they really offer?

It is an international regime, not a national incentive. It originates in Annex VIII of the Peace Treaty signed in Paris on 10 February 1947, given effect in Italy by Legislative Decree no. 1430 of 28 November 1947 ¹. It is implemented by two decrees of the Government's General Commissioner for the Territory of Trieste, no. 29 of 19 January 1955 and no. 53 of 23 December 1959 ². The ports act preserves these rules and leaves the administrative organisation of the free zones to a decree of the Minister of Infrastructure, in agreement with the Minister of Economy (art. 6, para. 12, Law 84/1994) ³. That decree is no. 368 of 13 July 2017 ².

Under the 2017 decree the Eastern Adriatic Sea Port System Authority is the sole manager of the regime. It can change the area of the free zones and authorise handling and industrial processing within them ⁴. The Authority itself writes that, at least in theory, the regime could extend to areas anywhere in the province of Trieste ⁴: no further.

What it offers, according to the Authority ⁴:

• the free zones are outside the customs territory: non-EU goods need no customs declaration on entry;
• third-country goods are exempt from duty, VAT and trade-policy measures while they remain in the free zones;
• storage has no time limit, for EU and non-EU goods alike;
• handling and industrial processing are allowed; the processed product can acquire EU origin if it meets the rules of origin;
• on import, the Trieste customs credit can be used: duty and VAT deferred by 180 giorniBIZ.

What it is not. It is not a tax-free zone for businesses: companies that set up there enjoy the ordinary national and regional incentives, not different income taxation ⁴. The excise exemption on fuel and electricity for industrial plants, provided for in the 1959 decree, is by the Authority's own account "under review": today it is not an advantage to build a business plan on ⁴. And the customs advantages depend on the goods, their origin and their destination: they are checked case by case with a customs agent, never assumed.

The free zones lie within the port and in inland port areas brought under the regime. Two cases are documented in an official document, the ZLS Strategic Development Plan (rev. September 2024) ⁵:

Source: ⁵. Interporto di Trieste, the freight village operator that runs both, now states a total of 215.000 m²politichecoesione.governo.it of yards and 110.000 m²politichecoesione.governo.it of covered warehousing, "national, foreign and free"; FreeEste is 6 kminterportotrieste.it from the port, Fernetti 18 ⁶.

For property the consequence is concrete. Quays and State-owned port land cannot be bought: they are granted as concessions by the Port System Authority through a public procedure (art. 18, Law 84/1994) ⁷. Private value arises in the port hinterland: warehouses, yards, service offices. And free zone status is not an attribute you "buy" with the building: it is a boundary set by the Authority. An offer of a property "in the free port" must be checked against the act that defined that area.

No. It is a point that is often misunderstood.

The FVG Simplified Logistics Zone (Zona Logistica Semplificata, ZLS) was established by Prime Ministerial Decree of 3 February 2025, and its steering committee by Prime Ministerial Decree of 6 May 2025 ⁸. It covers 1.455,74 ettaripolitichecoesione.governo.it in 26 municipalities ⁵. None is in the province of Trieste. The Plan says so plainly: the areas of the port of Trieste are not part of the ZLS, partly because of the special legal regime that applies to them ⁵. Trieste stays outside, linked to the ZLS by the customs corridors and rail services the Plan proposes.

The largest shares are in San Giorgio di Nogaro (354,46 ettaripolitichecoesione.governo.it) and Monfalcone (236.83) ⁵. The ZLS does not cover whole municipalities but cadastral parcels listed in an annex: check the sheet and parcel number, not the address ⁸.

The tax credit: where it really applies

Businesses in the ZLS get the administrative simplifications in the founding law (art. 1, paras 61–65, Law 205/2017) ⁹; the zone lasts at most seven years, renewable for seven more (para. 63) ⁹. The tax credit is a different matter: it applies only to the parts of the ZLS that also fall within the regional aid map under art. 107(3)(c) TFEU (art. 13, Decree-Law 60/2024) ¹⁰. The 2026 budget law (Law 199/2025, art. 1, para. 444) extends it to investments made from 1 January 2026 to 31 December 2028 ¹⁰²⁹.

The credit is not automatic and it is capped ²⁹³⁰:

• National cap: €100 milioniTriesteBusiness for each of 2026, 2027 and 2028, for all Italian ZLS together (Law 199/2025, art. 1, para. 444).
• Reservation: the year's expenditure is notified to the Revenue Agency from 31 March to 30 May; then, from 3 to 17 January of the following year, a supplementary notice of the expenditure actually incurred, on pain of forfeiture (para. 445). The 2026 window is closed: anyone investing now is looking at 31 March – 30 May 2027.
• Pro-rating: if applications exceed the cap, each receives a credit reduced by a percentage published by the Revenue Agency after the supplementary notices (para. 447). The aid-map intensity is a maximum, not an amount you can count on.

Of the 26 ZLS municipalities, 13 are on the aid map ¹¹:

Source: ¹¹; list of aid-map municipalities and intensities: ¹².

The rules that matter for investments from 2026 ¹⁰¹³:

• Intensity (aid map 2022–2027): 15%Normattiva of eligible costs for large companies in the former provinces of Gorizia and Udine, 10%Normattiva in the former province of Pordenone; +10 points for medium-sized and +20 for small companies ¹². Brugnera, the only municipality on the list in the Pordenone area, is therefore at 10%Regione FVG.
• Large companies: in these areas the EU regulation allows aid to large companies only for an initial investment that creates a new economic activity in the area; SMEs can do so for any initial investment (Reg. (EU) 651/2014, art. 14, para. 3) ³¹. Expanding an existing activity is not enough for a large company.
• Thresholds: projects from 200.000 €Normattiva up to €100 milioniNormattiva per project ¹³.
• Property: land and buildings are eligible within an initial investment project, but not beyond 50%Normattiva of the total investment ¹³. A purely property transaction is not an eligible project.
• Excluded sectors: among others steel, transport and its infrastructure, energy, banking and insurance, and companies in difficulty. Warehousing and transport support services remain eligible ¹³.
• Conditions: the company must keep the activity in the area for at least five years after completing the investment, or the credit is revoked; and if within the fifth tax year the assets are sold or put to other uses, the credit is recalculated ¹³.

For an owner of an industrial building in Monfalcone, Ronchi or San Giorgio di Nogaro, sitting on a ZLS parcel is a selling point, provided it is documented with the cadastral annex and presented for what it is: a possible credit for a buyer who invests, within a national cap and with its own windows, not a value that passes with the building. For an owner in the city of Udine or Pordenone, the ZLS brings simplifications but not the credit. In Trieste, Muggia and San Dorligo it brings nothing.

Trieste, Muggia and San Dorligo della Valle are an area of complex industrial crisis – a designated area with dedicated State aid for industrial investment. The first programme agreement dates from 27 July 2017; the new one was signed on 1 August 2025 and registered by the Court of Auditors on 11 September 2025 ¹⁶; the Ministry announced it on 19 December 2025 together with the call (directorial circular no. 3327 of 16 December 2025) ¹⁴¹⁶. The tool is provided by art. 27 of Decree-Law 83/2012 ¹⁵; the aid runs through Law 181/1989, managed by Invitalia ¹⁶.

The 2026 call ¹⁴¹⁶:

• budget: €15 milioniMIMIT, including the manager's fee;
• minimum investment: €1 milioneBIZ (400.000 €BIZ for business networks);
• forms: capital grants, expenditure grants, subsidised loans;
• application window: 26 February to 23 April 2026.

How it went: the ranking of applications admitted to assessment (page updated on 22 May 2026) shows 4 applications, for €55,4 milioniMIMIT of investment, €13,3 milioniMIMIT of aid requested and 106 unitàMIMIT of additional employment; only one exceeds €40 milioniMIMIT ¹⁶ (our totals from the official table). Admission to assessment is not an award.

Our reading: the tool exists, but demand is thin. For an owner selling a building in the industrial area, a buyer with a genuine industrial project can apply for a grant; a buyer purchasing only to let is unlikely to have a productive investment programme to put forward. Note: read eligible sectors and costs in circular no. 3327/2025 before promising anything. Note: art. 27 of Decree-Law 83/2012 was amended by Legislative Decree no. 138 of 26 June 2026 ¹⁵: reread the rule in force before any new call.

Six economic development consortia operate in the region, governed by Regional Law no. 3 of 20 February 2015 ("RilancimpresaFVG"); for the Trieste area it is the local economic development consortium of the Giuliana area (Coselag) ¹⁷. According to the ZLS Plan ⁵, the region's consortium areas measure 4.389 ettaripolitichecoesione.governo.it; Coselag has 810.5, with 731 businesses, the highest density (0.9 businesses per hectare) and occupancy of 80%Regione FVG. The Pordenone area is 94%Regione FVG occupied. Free land amounted to about 129 ettaripolitichecoesione.governo.it across the region, with expansions planned mainly in the Pordenone area (226 ettaripolitichecoesione.governo.it) ⁵. The Plan does not state the year of these figures: they are an order of magnitude, not today's availability.

Within a consortium area, buying and selling is not always free: allocations, permitted uses and transfers may go through the consortium. Note: the rules differ from one consortium to another; read the regulations and the original allocation deed before making any proposal.

The ZLS Plan sets out an integrated system, the "FVG Port-Region": the ports of Trieste, Monfalcone and Porto Nogaro and the freight villages of Pordenone, Cervignano, Gorizia and Trieste-Fernetti, connected by dedicated trains that carry port functions inland ⁵. The nodes, according to the Plan ⁵:

The official quotations are those of the Revenue Agency's Property Market Observatory (OMI). Latest half-year available: 2025/2. Values in €/m² of gross area, rents in €/m² a month, "normal" condition ¹⁸. The gross yield is our own calculation at the mid-point of the two ranges: (average rent × 12) / average value.

Source: ¹⁸, records read on 7 October 2026. For the region as a whole, the 2026 Property Report (2025 data) gives an average quotation for industrial buildings of 296 €/m²lavoripubblici.it: FVG has the lowest average values for productive property in Italy, at 66.4 against a national average of 100 ¹⁹. It is an average weighted on the stock which very probably excludes the land-register municipalities: on the Report's maps they appear as "not processed" ¹⁹.

Three caveats, worth more than the figures:

1. OMI values and rents are estimated separately. Their ratio is an indicator, not a market yield. Pordenone's 8,3%AdE or Monfalcone's 7,9%AdE say that sale values there are low relative to rents, not that any building yields that much.
2. Trieste is a statistical gap. Official transaction statistics exclude the 43 land-register municipalities of FVG, including the whole of the provinces of Trieste and Gorizia; for those municipalities the Revenue Agency publishes residential data only ³². On the Report's maps they appear as "not processed" ¹⁹. For industrial buildings in Trieste, Muggia, San Dorligo, Gorizia and Monfalcone no public transaction series exists: an estimate is built from comparables collected one by one. The reason is explained in the guide to the land register.
3. OMI describes the ordinary stock, not modern logistics. The nearest prime benchmark published by an international broker is Verona: 62 €/m²C&W a year for logistics warehousing, 95 for last mile, prime net yield 5,50%C&W (second quarter of 2026) ²⁰. The maximum OMI rent for Trieste D1, 3 €/m²AdE a month, makes 36 €/m²AdE a year. No FVG market appears in the brokers' tables ²⁰.

Nationally, yes: in the first half of 2026 about 1,5 milioniC&W m² of logistics space was taken up, a high for the series according to the source, with Lombardy at 32%C&W of second-quarter volumes and Emilia-Romagna at 29%C&W ²⁰. In the region the official signal is sales of productive property: 439 in 2025, +8,5%lavoripubblici.it ¹⁹, a figure that essentially describes the provinces of Udine and Pordenone without the land-register municipalities.

The manufacturing heart lies there. On 2020 ISTAT data analysed in the ZLS Plan, industry in the narrow sense employs 37%politichecoesione.governo.it of workers in the province of Pordenone, 29%politichecoesione.governo.it in Gorizia, 24%politichecoesione.governo.it in Udine and 13%politichecoesione.governo.it in Trieste, where about four workers in five are in services, and two in three in services other than retail and hotels ⁵. The data are six years old, but describe a structure that changes slowly.

Our reading, which is an inference and not a data point: in the region, demand for industrial buildings comes mainly from occupiers – manufacturers and port operators – rather than institutional investors. Those looking for large floor areas at low prices find them in central and western Friuli; those who need the port, the free zone or the rail link to Central Europe pay for Trieste's scarcity. And an owner of an industrial building in Trieste holds a scarce asset, with a narrow pool of buyers and no public statistics describing it.

Trieste is a Contaminated Site of National Interest (SIN) for remediation: delimited by Ministerial Decree of 24 February 2003, redefined by Ministerial Decree of 2 February 2018 and by Ministerial Decree no. 95 of 16 March 2021 ²¹²². Note: the Region's page dates the 2018 decree to 12 February; the ISPRA list, with the Official Gazette reference (OJ no. 41 of 19/02/2018), to 2 February. According to the Region the current site covers about 1.400 ettariRegione FVG: about 200 on land, in the municipalities of Trieste and Muggia, and about 1.200Regione FVG at sea, from Pier V to Punta Ronco, within the breakwaters ²². For the areas taken out of the perimeter in 2021, proceedings passed from the Ministry to the Region (art. 242, Legislative Decree 152/2006) ²². There is a programme agreement of 25 May 2012 and a risk analysis of the areas characterised by the former industrial zone authority in the Noghere valley and Rio Ospo (Regional Decision 1517 of 4 August 2017) ²². The region has a second SIN, Caffaro di Torviscosa ²¹.

What matters to buyers and sellers:

• An owner not responsible for the contamination who discovers that thresholds are exceeded must notify the Region, the Province and the Municipality and carry out preventive measures; it may always remediate voluntarily (art. 245, Legislative Decree 152/2006) ²³. Note: in FVG the provinces were abolished in 2016 and the Region is reconstituting them (statute amended by Constitutional Law 1/2026 of 26 January 2026) ³³: which body receives the "provincial" notice today must be checked at the date.
• Remediation carried out by the authorities becomes a charge on the land, registered after approval of the project and shown in the zoning certificate (CDU); the costs carry a special lien enforceable even against later buyers. An owner not at fault is liable only by reasoned order and up to the market value of the site after the works (art. 253) ²³. Note: in Trieste and Muggia property publicity runs through the land register: how the charge appears there must be checked on the land register extract as well as on the zoning certificate.
• In sites under remediation, SIN included, certain works are allowed (maintenance of plant, safety, renewables, linear infrastructure and others), provided they do not prejudice the remediation (art. 242-ter) ²³. For areas under regional competence, FVG has its own implementing regulation (Regional Decree no. 04/Pres. of 16 January 2023) ²².

For a site within the SIN, the price depends on three answers: where it falls relative to the 2021 perimeter, how far characterisation has gone, and who is responsible for the contamination.

Mining, trading and producing asbestos are banned by Law 257/1992 ²⁴. Where asbestos in place is found in a building open to the public or in collective use, industrial buildings included, the owner or the person responsible for the activity must start a control and maintenance programme, appoint a responsible person and keep records of where the materials are (Ministerial Decree of 6 September 1994) ²⁵.

In FVG the regional guidelines, revised by Regional Decision no. 1559 of 7 November 2025 implementing Regional Law no. 34 of 20 October 2017, govern reporting, traceability and assessment of condition ²⁶. An owner who identifies an asbestos item reports it to ARPA, the regional environmental agency, on the prescribed form, together with the condition assessment where required; for friable asbestos the report goes to the health authority; updates after removal go to ARPA, with a copy to the municipality. Each building receives a code in the regional archive. The assessment uses standard methods: one for asbestos-cement roofing, one for materials inside buildings ²⁶. The Region has a grant line for municipalities, private owners and businesses; for the grants under art. 4, para. 30, Regional Law 25/2016, compliance with the micro-collection guidelines, which concern residential buildings, is binding (Regional Decision 1558/2025) ²⁶. Not yet verified: amounts and open calls in 2026 for an industrial building.

For an industrial building built before the 1992 ban, asbestos-cement roofing is a possibility to rule out with a site inspection and, if present, a cost to estimate before the offer – not a discovery after completion.

Before any price, we line up the checks that decide whether a transaction on an industrial asset in the region can go ahead: boundaries, restrictions, remediation, customs regime, incentives. Then we present it to whoever has a concrete reason to use it or to buy it.