Portugal

Extended producer responsibility (EPR) for packaging in Portugal

The legal framework in Portugal governing waste management has been consolidated over the past decades including regulations for managing specific waste flows. National waste related legislation predominantly transposes the EU Directives. The producer responsibility principle is widely applied to achieve targets for prevention, separate collection, and recovery and recycling. Compliance with packaging and packaging waste management requirements at the local level is regulated by Decree-Law No. 152-D/2017.

Who must register for EPR in Portugal

The following entities must register for EPR packaging Portugal:

• Producers and importers of packaged goods
• E-commerce sellers targeting Portuguese consumers
• Retailers and brand owners placing own-branded packaging on the market
• Distance sellers, even if located outside Portugal, are also responsible

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Responsibility in Portugal

According to the legislation in force (Decree-Law no. 152-D / 2017, in its current wording), the responsibility for the packaging and packaging waste management refers, totally or partially, to the product producer, the packer and the service packaging supplier has the financial or financial and operational responsibility for managing the products lifecycle phase when they reach their end of life and become waste

Definition of packaging under the Decree-Law no. 152-D / 2017

The Decree-Law no. 152-D / 2017 of the Portuguese Republic classifies the following materials as packaging:

• Paper/ cardboard
• Black metals
• Glass
• Aluminium
• Plastic
• lliquid food board
• Steel
• Wood
• Other materials

What the package includes

The EPR obligations apply to all primary, secondary, and tertiary packaging used to market products in Portugal, including:

• Plastic, glass, metal, and composite containers
• Cardboard boxes and paper-based packaging
• Shrink wrap, stretch film, pallets, strapping
• Single-use food packaging

Thresholds

There are no lower quantity minimum quantities. Thresholds to exempt anyone introducing packaged products from their obligations. Even sending a single parcel or a solitary product item obliges compliance.

EPR registration procedure in Portugal

To comply with EPR registration Portugal, producers must:

• Register with APA’s Waste Management Platform (SILIAMB)
• Join an approved PRO, such as Sociedade Ponto Verde (SPV) or Resitejo
• Submit a packaging declaration indicating quantities by material type
• Pay the relevant eco-contribution fees based on volume and recyclability

Non-compliant companies may face fines and import/export restrictions.

Authorized representative

There is no mandatory Authorized Representative scheme in Portugal, unlike in some other EU countries. However:

• Non-Portuguese companies without a local establishment are still responsible and must register directly or appoint a local proxy (not legally required, but often done for administrative ease)
• The local proxy or fiscal representative can support with registration and reporting duties

Reporting deadline

The annual declaration is a document that companies fill out annually to report the total weight of single-use packaging of products placed on the national market and intended for the end consumer. The declaration is submitted for the first time upon joining the system, and then annually.

Sanctions

According to Decree-Law No. 152-D/2017, for non-compliance with the rules of extended producer responsibility, the violator may face the following fines:

• Suspension of activities
• Suspension of authorizations, licenses and permits
• Fines from 50 to 3740 euros for individuals
• Fines from 500 to 44,890 euros in the case of a legal entity

Who assumes responsibility?

Responsibility lies with:

• Producers/importers: For registration, reporting, and fee payment
• PROs (e.g., SPV, Novo Verde): For collection, sorting, recycling, and public awareness
• Portuguese Environment Agency (APA): Oversight, enforcement, and regulatory updates

Duties of each group

• Producers: Submit packaging data, join a PRO, pay contributions
• PROs: Organize selective collection, recycling infrastructure, and public communication
• Retailers: Ensure supplier compliance and may be obligated if using private labels
• Authorities: Monitor performance targets, apply fines, publish recycling benchmarks

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