Portugal has established a robust Extended Producer Responsibility (EPR) framework through Decree-Law 152-D/2017, effective since 1 January 2018. The legislation consolidates various waste streams into a single regime based on the principle of extended producer responsibility (EPR). Its main goals are to reduce environmental impact, promote recycling and reuse, enhance resource efficiency, and support the transition to a circular economy.

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Portugal EPR Regulations for Manufacturers, Importers and Ecommerce

Portugal’s EPR law applies to producers, importers, distributors, retailers, and e-commerce operators who place products and packaging on the Portuguese market.

• Co-responsibility for waste management across the full product lifecycle, from production to disposal
• Choice of compliance system: either an individual system (with financial guarantees) or joining an integrated management system (IMS) licensed by the Portuguese Environment Agency (APA, I.P.)
• Producers & packers must finance the collection, recycling, and recovery of packaging waste
• Importers & e-commerce sellers established abroad must appoint an authorized representative in Portugal
• Distributors & retailers must accept used packaging, WEEE, and batteries returned by consumers at no extra cost

The two officially approved PROs (Producer Responsibility Organizations) for packaging in Portugal are:

• Sociedade Ponto Verde (SPV) – manages the Green Dot (SIGRE) system for non-reusable packaging
• Novo Verde – alternative PRO managing packaging waste collection and recycling

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Covered and Exempted Packaging under Portugal EPR

Covered packaging and waste streams include:

• Packaging and packaging waste (primary, secondary, tertiary, service packaging)
• Oils and used oils
• Tires and used tires
• Electrical and electronic equipment (EEE) and waste electrical and electronic equipment (WEEE)
• Batteries, accumulators, and their waste
• Vehicles and end-of-life vehicles
• Other non-food cellulosic materials
• Other wood-cellulosic materials (except logs for sawing and wood for veneering)
• Animal fats in categories 1 and 2 (per Regulation (EC) 1069/2009)

Exemptions include:

• Used mineral oils with PCBs/PCTs (covered by Decree-Law 277/99)
• EEE for defense and military purposes
• EEE designed and installed as components of excluded equipment
• Incandescent lamps
• EEE designed exclusively for space applications
• Large stationary industrial tools and installations
• Vehicles for defense/security purposes, non-road mobile machinery for professional use
• Certain medical devices expected to become infectious before end-of-life
• Active implantable medical devices

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Who Must Register under Portugal EPR

The following economic operators are required to register in APA’s electronic waste registration system (SIRER):

• Producers of products (manufacturers, brand owners, resellers under own brand, importers)
• Packers and importers of packaged products
• Suppliers of service packaging
• Distributors and retailers (must accept packaging, batteries, and WEEE returns from consumers)
• E-commerce sellers established outside Portugal but placing packaged products on the Portuguese market (must appoint an authorized representative in Portugal)
• Other stakeholders in the waste chain (waste collectors, treatment operators, municipalities, insurers in case of ELVs)

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Portugal EPR Data Reporting

Registered companies must report data annually through APA’s electronic waste registration system (SIRER). Required data includes:

• Type and quantity of products and packaging placed on the market in Portugal
• Type and quantity of waste generated and recovered
• Chosen waste management system (individual or integrated)
• Details on distributors supplied and quantities (for EEE producers via authorized representatives)
• Annual reports submitted digitally to APA by 15 April of the following year
• Retailers and distributors must keep records of consumer returns of packaging, WEEE, and batteries (minimum 3 years)

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Portugal EPR Schedule and Deadlines

Key reporting and payment deadlines include:

• Annual declaration (Novo Verde & SPV): by 15 March of the following year
• Annual activity reports to APA: by 15 April each year
• Lightweight plastic bag declaration (DIC): processed quarterly, by the 5th of the month following each quarter
• Lightweight plastic bag reporting: estimated quantities by 31 March (for the current year), and actual quantities by 31 March of the following year
• Fee payment to PROs (e.g., Novo Verde): within 45 days of invoice

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Portugal EPR Fees and Penalties

Fees & Financing

• Producers, packers, and service packaging suppliers must pay a financial contribution to a PRO (SPV or Novo Verde) or provide a financial guarantee to APA if using an individual system
• Financial contributions are based on quantity, material type, recyclability, presence of hazardous substances, and incorporation of recycled content
• Lightweight plastic bags are subject to a specific eco-contribution, payable quarterly
• Small producers of batteries and accumulators (≤1 ton annually) may be exempt from fees if approved by the European Commission

Penalties

• Very serious infringements: fines up to €44,890 for legal entities (e.g., placing packaging on the market without joining an EPR system, illegal waste management operations, uncontrolled disposal of oils, landfill of tires, missing WEEE labeling)
• Serious infringements: fines from €500 to €22,445 for companies (e.g., not accepting consumer returns of packaging or batteries, non-compliance with design and labeling requirements)
• Ancillary sanctions: suspension of activities, licenses, or permits

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Common EPR Compliance Challenges In Portugal

Businesses in Portugal often face challenges in meeting EPR obligations, including:

• Complexity of the regulatory framework due to multiple waste streams and actors involved
• Difficulty for SMEs to understand and comply with all requirements
• Managing multiple PRO memberships (SPV and Novo Verde) depending on packaging type
• Ensuring accurate data reporting to APA (SIRER) and meeting deadlines
• Handling financial contributions and deposits, including eco-contributions for lightweight plastic bags
• Adhering to strict technical standards for packaging, EEE, batteries, and ELVs
• Maintaining records of waste returns and treatment for at least 3 years

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Why choose RegSurance as your Portugal EPR Compliance Partner

RegSurance is a trusted EPR compliance service provider for international businesses needing to comply with Portugal packaging EPR rules. We support manufacturers, importers, and e-commerce sellers with complete EPR solutions — including EPR registration, packaging compliance assessments, ongoing regulatory updates, and accurate EPR data reporting for Portugal. With our in-depth knowledge of Portugal EPR requirements, we ensure your business stays fully compliant and up to date with changing legislation.

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• Get a free EPR compliance Assessment
• Receive a personalized registration roadmap
• Book a 1:1 consultation with our experts
• Register or Sign-in for our comprehensive EPR Compliance Guide

FAQs on Portugal EPR

1. What is Portugal’s EPR regulation for packaging?
   Portugal’s EPR is established under Decree-Law 152-D/2017, effective since 1 January 2018. It consolidates waste management rules for packaging, used oils, tires, WEEE, batteries, accumulators, and end-of-life vehicles, ensuring producers take responsibility for the full lifecycle of their products.
2. Who needs to register under Portugal’s EPR?
   All producers, packers, importers of packaged products, service packaging suppliers, distributors, retailers, and e-commerce sellers placing products in Portugal must register with the APA’s electronic waste registration system (SIRER). Foreign sellers must appoint an authorized representative in Portugal.
3. What types of packaging are covered by Portugal’s EPR?
   Packaging obligations apply to primary, secondary, tertiary, and service packaging, as well as other specified waste streams including oils, tires, WEEE, batteries, accumulators, and vehicles.
4. What types of packaging are exempt from EPR in Portugal?
   Exemptions include used mineral oils with PCBs/PCTs, military and defense EEE, incandescent lamps, large industrial tools, large stationary installations, space equipment, certain medical devices, and non-road mobile machinery.
5. How can companies comply with Portugal’s EPR obligations?
   Businesses can comply by either setting up an individual waste management system with financial guarantees to APA, or joining a collective PRO, such as Sociedade Ponto Verde (SPV) or Novo Verde.
6. What are the data reporting requirements under Portugal’s EPR?
   Companies must report annually via APA’s SIRER system the type and quantity of products and packaging placed on the market and the chosen management system. For packaging, annual declarations are due by 15 March to PROs and by 15 April to APA.
7. What are the financial contributions under Portugal EPR?
   Producers must pay eco-contributions to PROs (SPV or Novo Verde) or provide a deposit/financial guarantee to APA if using an individual system. Fees depend on material type, recyclability, hazardous substances, and quantities placed on the market.
8. What are the penalties for non-compliance with Portugal’s EPR?
   Fines can range from €50 to €3,740 for individuals and €500 to €44,890 for companies. Additional sanctions include suspension of business licenses or permits.
9. Are small producers exempt from Portugal EPR obligations?
   Yes, companies placing ≤1 ton of packaging or batteries annually may be considered small producers and can benefit from simplified requirements or fee exemptions if approved by the European Commission.
10. Which Producer Responsibility Organizations (PROs) are available in Portugal?
    The two licensed PROs are Sociedade Ponto Verde (SPV) – manages the Green Dot system for non-reusable packaging, and Novo Verde – an alternative PRO for packaging waste management.