Portugal EPR

What is Portugal EPR Packaging

Extended Producer Responsibility (EPR) in Portugal is a waste management policy that requires producers to take responsibility for the environmental impact of the packaging they place on the Portuguese market. This system is primarily governed by Decree-Law No. 152-D/2017, which transposes EU directives into national law. As of August 12, 2026, the new EU Packaging and Packaging Waste Regulation (PPWR) will apply directly, harmonizing many of these rules across the EU. The main regulatory authority in Portugal is the Portuguese Environment Agency (Agência Portuguesa do Ambiente - APA).

Does this apply to e-commerce & online sales

Yes. Under the Decree-Law 152-D/2017, distance sellers, including foreign e-commerce companies and online marketplaces, are considered producers if they sell packaged products directly to Portuguese consumers (B2C). These sellers are responsible for the packaging of the products themselves and any additional shipping packaging (e.g., mailer bags, boxes) used for delivery to the customer in Portugal.

Who is the “producer” under Portugal EPR?

In Portugal, a "producer" is defined as any entity that first places packaged products on the national market for professional or domestic use. This includes:

1. Manufacturers based in Portugal.

2. Importers who bring packaged goods into Portugal from other countries.

3. Distance sellers (foreign companies) selling directly to Portuguese end-users.

4. Service providers who package goods at the point of sale (e.g., retailers).

Who must register for EPR packaging in Portugal

All producers must register with the Portuguese Environment Agency (APA) through the SILiamb (Integrated Environmental Licensing Information System) platform. Additionally, producers must fulfill their waste management obligations either by setting up an individual system (rare) or by joining a licensed Producer Responsibility Organization (PRO).

Portugal EPR Packaging Registration Threshold

Portugal operates a zero threshold policy for registration. There is no minimum turnover or volume required to trigger the obligation to register; companies must comply from the first gram of packaging placed on the market. While there are no exemptions for registration, some PROs may offer simplified flat-fee structures for very small volumes (e.g., under 1 tonne per year).

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Packaging Covered (and Excluded)

The EPR system covers all types of packaging materials:

• Primary (Sales) packaging: The immediate wrap for the consumer.

• Secondary (Grouped) packaging: Used to group products at the point of sale.

• Tertiary (Transport) packaging: Used for shipping (e.g., pallets, plastic film).

Materials include glass, plastic, paper, cardboard, metal, wood, and composites. Exclusions are limited to specific packaging for hazardous waste or medical products that fall under separate specialized regulations.

Producer Responsibility Organization (PRO)

Producers typically transfer their responsibility to one of the licensed collective systems (PROs) in Portugal. The main organizations are:

• Sociedade Ponto Verde (SPV)

• Novo Verde

• Electrão

These entities manage the collection and recycling network and report data to the APA on behalf of their members.

EPR Registration in Portugal

The registration process involves:

1. Creating an account on the SILiamb portal managed by the APA.

2. Choosing and signing a contract with a licensed PRO (e.g., SPV or Novo Verde).

3. Obtaining a unique Producer Registration Number.

4. Registering the specific quantities and materials in the SILiamb database.

Authorized Representative

For foreign companies (non-residents) selling directly to Portuguese consumers, the appointment of an Authorized Representative (AR) in Portugal is mandatory. The AR must be a legal or natural person based in Portugal who acts as the primary contact for the APA and ensures that registration, reporting, and fee payments are handled correctly.

What Data Must Be Reported

Producers are required to report:

• The total weight (in kilograms) of packaging placed on the market.

• A breakdown by material type (e.g., PET, HDPE, Cardboard).

• The category of packaging (household vs. non-household).

• Recyclability data, as required for the calculation of eco-modulated fees.

First Reporting Period & EPR Reporting Deadlines

Reporting is typically done annually.

• Annual Declaration: Data for the previous calendar year must be submitted to the PRO and the APA (via SILiamb) by March 31st each year.

• New Members: Must report initial data upon registration to establish their first fee payment.

Labels & Marketing Claims

As of January 1, 2025, Portugal introduced updated labeling rules. Producers have two choices:

1. Direct Labeling: Placing disposal instructions (sorting pictograms) directly on the packaging.

2. Alternative Channels: Providing sorting information via websites, manuals, or at the point of sale.

   Additionally, from August 2026, Portugal will participate in the mandatory EU Deposit Return System (SDR) for beverage containers (plastic, metal, and aluminum), which will require specific "Volta" logos.

EPR Eco Fees & Eco-Modulation

Fees are calculated based on the weight of the packaging. Starting in 2026, Portugal is moving toward a full eco-modulation system. Fees will be adjusted based on the "Recyclability Assessment Methodology" (RAM):

• Green-rated: Lower fees for highly recyclable materials.

• Red-rated: Significant surcharges for packaging that is difficult to recycle or contains hazardous substances.

Risks, Penalties & Common Mistakes

Non-compliance can lead to:

• Fines: Ranging from €250 to €44,891, depending on the size of the company and the nature of the violation.

• Market Bans: Authorities can prevent the sale of products if the producer is not registered in SILiamb.

• Common Mistakes: Failing to appoint an Authorized Representative and under-reporting transport packaging like pallets and stretch film.

What E-Commerce Sellers Should Do Now

1. Appoint a local Authorized Representative in Portugal to handle compliance.

2. Register your company on the SILiamb portal.

3. Join a licensed PRO like Sociedade Ponto Verde or Novo Verde.

4. Review your packaging design now to ensure it qualifies for lower eco-modulated fees in 2026.

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FAQ

Is registration mandatory for small sellers?

• Yes, Portugal has a zero threshold; registration is required from the first item sold.

What is the SILiamb portal?

• It is the official electronic system of the APA where all environmental data and registrations are managed.

Is the Green Dot mandatory in Portugal?

• It is not a legal requirement, but it is a widely recognized symbol managed by Sociedade Ponto Verde.

Do I need to report B2B packaging?

• Yes, both household and commercial/industrial packaging must be licensed and reported.

When does the new Deposit Return System (SDR) start?

• It becomes mandatory for beverage containers by August 2026.