Portugal EPR

Packaging and Packaging Waste Waste Electrical and Electronic Equipment (WEEE) Batteries and Accumulators Tires Mineral and Synthetic Oils End-of-Life Vehicles (ELV)

EPR Guide 2026: Packaging and Packaging Waste in Portugal

Extended Producer Responsibility (EPR) has become a cornerstone of the circular economy in Europe. For businesses placing products on the Portuguese market, staying compliant with the evolving legal landscape is not just an environmental obligation—it is a business necessity.

In this guide, Complico Consulting GmbH breaks down the 11 critical aspects of the Portuguese EPR framework for packaging and packaging waste to ensure your business remains compliant in 2026.

1. Introduction to EPR in Portugal

Extended Producer Responsibility (EPR) in Portugal is a policy approach where producers—including manufacturers, importers, and e-commerce sellers—bear the financial and operational responsibility for the end-of-life management of the packaging they place on the market. The goal is to incentivize eco-design and reach the EU’s ambitious recycling targets of 65% by weight for all packaging waste by 2025/2026.

2. Legal Framework and Regulations in Portugal

The primary legislation governing EPR in Portugal is Decree-Law No. 152-D/2017, often referred to as UNILEX. Recent updates, including Decree-Law No. 24/2024, have introduced stricter labeling requirements and expanded the scope of regulated packaging. These laws transpose EU Directives (94/62/EC and its amendments) into national law, ensuring alignment with the European Green Deal.

3. Who Must Register for EPR in Portugal?

You are considered a "Producer" and must register if you are the first to place packaged products on the Portuguese market. This includes:

Domestic Manufacturers: Producing and selling goods in Portugal.

Importers: Bringing packaged goods into Portugal from other EU or non-EU countries.

E-commerce & Distance Sellers: Selling directly to Portuguese consumers via online marketplaces or websites, regardless of where your company is based.

Service Packaging Suppliers: Providers of bags, wraps, and takeaway containers.

Note: There is no minimum threshold. Whether you ship one parcel or ten thousand, compliance is mandatory from the first item.

4. EPR Categories: Packaging and Packaging Waste

The Portuguese system distinguishes between several packaging categories, each with specific management requirements:

Household Packaging (Urban): Packaging that typically ends up in municipal waste streams (e.g., retail boxes, food containers).

Non-Urban (Industrial/Commercial): Packaging used in B2B environments, such as pallets, shrink wrap, and crates. As of January 2025, these must also be licensed through a Producer Responsibility Organization (PRO).

Service Packaging: Packaging filled at the point of sale (e.g., shopping bags).

Reusable Packaging: Subject to specific "return and reuse" system requirements.

5. EPR Registration Process in Portugal

To achieve compliance, businesses must follow a multi-step process:

1. Register with APA: Sign up via the SIRER (Sistema Integrado de Registo Eletrónico de Resíduos) platform managed by the Portuguese Environmental Agency (APA).

2. Join a PRO: Contract with a licensed Producer Responsibility Organization, such as Sociedade Ponto Verde (SPV) or Novo Verde.

3. Obtain your EPR Number: This unique identification number proves your compliance to authorities and marketplaces like Amazon or eBay.

6. Authorized Representative Requirements

For foreign companies (non-residents) selling in Portugal, appointing an Authorized Representative (AR) is mandatory under Article 20.2 of Decree-Law 152-D/2017. The AR must be a Portuguese legal entity that takes on the legal responsibility for your EPR obligations, handles reporting, and interacts with the APA on your behalf.

7. Reporting Obligations and Deadlines

Compliance requires regular data submission regarding the weight and material type of packaging placed on the market:

Annual Declaration to PRO: Usually due by March 15th of the following year.

Annual Report to APA (via SIRER): Usually due by April 15th.

Data Accuracy: Reports must specify material fractions (Paper, Plastic, Glass, Metal, Wood, etc.).

8. EPR Fees and Eco-Contributions

Producers pay "Eco-values" (fees) based on the quantity and type of materials used. In 2026, eco-modulation plays a larger role:

Recyclable Materials: Benefit from lower rates.

Non-Recyclable or Complex Materials: Subject to higher "malus" fees to discourage their use.

Lightweight Plastic Bags: Subject to a specific contribution (DIC) reported quarterly.

9. Labeling Requirements and Compliance

Significant changes came into effect in 2025/2026 regarding packaging labels:

Sorting Instructions: Packaging must include clear instructions on which recycling bin the consumer should use (e.g., Yellow for plastic/metal, Blue for paper).

Language: Instructions should be in Portuguese.

Symbols: While the "Green Dot" is voluntary, specific sorting icons provided by PROs or the "Triman" style instructions are becoming the standard for transparency.

10. Penalties for Non-Compliance

Failure to comply can lead to severe consequences:

Financial Fines: Can range from €2,500 to €50,000 for legal entities.

Market Restrictions: Online marketplaces are legally required to block sellers who cannot provide a valid EPR registration number.

Confiscation: Potential seizure of goods and prohibition of sales within Portuguese territory.