Portugal EPR

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EPR Guidelines for Tires in Portugal

The transition toward a circular economy has made Extended Producer Responsibility (EPR) a cornerstone of environmental law in the European Union. For companies placing tires on the market in Portugal, the legal landscape is complex, requiring precise registration, reporting, and financial contributions.

This guide provides a comprehensive breakdown of the EPR requirements for tires in Portugal, ensuring your business remains compliant and avoids heavy penalties.

1. Introduction to EPR in Portugal

Extended Producer Responsibility (EPR) is a policy approach where producers bear the financial and operational responsibility for the end-of-life management of their products. In Portugal, this system aims to minimize the environmental impact of waste tires by ensuring they are collected, processed, and recycled into high-value raw materials or energy.

2. Legal Framework and Regulations in Portugal

The primary legislation governing EPR for tires in Portugal is Decree-Law No. 152-D/2017, which unified the management of several waste streams.

Recent Updates: As of January 1, 2026, new "Ecovalor" fee structures and differentiation rules have come into force under Portaria n.º 150/2024/1, specifically impacting retreaded tires and eco-modulated fees.

Regulatory Body: The APA (Agência Portuguesa do Ambiente) oversees the national waste management system and the SILiamb portal.

3. Who Must Register for EPR Tires in Portugal?

The "Producer" definition in Portugal is broad. You must register if you are:

Manufacturers: Based in Portugal, producing tires for the domestic market.

Importers: Companies bringing tires into Portugal from EU or non-EU countries.

Distance Sellers: Online retailers selling tires directly to Portuguese end-users (B2C).

Service Providers: Entities that retread tires and place them back on the market.

4. EPR Categories: Tires

The EPR obligations apply to various tire categories, each with specific fee structures:

1. Passenger Vehicle Tires: Cars, SUVs, and light commercials.

2. Heavy Duty Tires: Trucks, buses, and industrial machinery.

3. Two-Wheeler Tires: Motorcycles and scooters.

4. Specialty Tires: Agricultural and construction equipment.

5. Retreaded Tires: Now explicitly included in the fee structure as of 2026.

5. EPR Registration Process in Portugal

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

Step 1: SILiamb Registration: Create an account on the APA’s Integrated Environmental Licensing System (SILiamb).

Step 2: Join a PRO: You must contract with a licensed Producer Responsibility Organization (PRO). In Portugal, Valorpneu is the primary entity managing the tire waste stream.

Step 3: Producer Number: Upon successful registration and PRO affiliation, you will receive a unique Producer Registration Number.

6. Authorized Representative (AR) Requirements

For foreign companies (non-residents) selling tires in Portugal, the rules are strict:

Mandatory Appointment: Since 2022, non-resident producers must appoint a local Authorized Representative (AR).

Role of the AR: The AR acts as the legal liaison with the APA, handles the SILiamb reporting, and ensures that the company’s "Ecovalor" contributions are paid accurately.

Power of Attorney: A formal Power of Attorney (PoA) is required to grant the AR the authority to act on your behalf.

7. Reporting Obligations and Deadlines

Data accuracy is critical. Producers must report the total weight and quantity of tires placed on the market.

Annual Declaration: The deadline for the annual return of the previous year's data is typically March 31st.

Quarterly Reporting: Some PROs require quarterly data submissions to align fee payments with actual market placement.

Record Keeping: Producers must maintain records of all sales and imports for at least five years for audit purposes.

8. EPR Fees and Eco-Contributions

Commonly known as the Ecovalor, these fees fund the collection and treatment of end-of-life tires.

Current Rates (2026): For example, passenger tires carry a fee of approximately €1.48 per unit.

Retreading Bonus: Retreaded tires receive a 10% discount compared to new tires to encourage circularity.

Visible Fee: In Portugal, the Ecovalor must be clearly itemized as a separate line on invoices between economic operators.

9. Labeling Requirements and Compliance

While tires themselves have standard EU labeling for performance (wet grip, noise, fuel efficiency), EPR compliance requires:

Invoice Transparency: Clearly stating the "Ecovalor" fee on commercial documents.

Consumer Information: Providing information on how and where end-users can return old tires at no cost.

10. Penalties for Non-Compliance

The Portuguese Environment Agency (APA) has increased enforcement measures. Non-compliance can lead to:

Financial Fines: Ranging from €500 to €44,890 for legal entities.

Market Bans: Prohibition from selling or importing tires into Portugal until registration is rectified.

Blacklisting: Repeated violations can result in being barred from the SILiamb system, effectively halting operations in the country.