Who the Portuguese fishing gear rules cover
Decreto-Lei 78/2021 transposed the SUP Directive (EU) 2019/904 into Portuguese law, and fishing gear EPR in Portugal has been mandatory since 1 January 2025. But the obligation exists on paper only.
You are a producer here if you place plastic-containing fishing gear on the Portuguese market. There is no volume threshold. The checklist is short:
- You manufacture or import fishing gear containing plastic.
- You sell it in Portugal, whether domestically or from abroad.
- No de minimis applies.
How registration stands in Portugal
Fishing gear is listed in SILiAmb, the portal Portugal uses for all EPR registration. The registration duty is in force. But APA's FAQ states plainly that no scheme has been licensed, so the enquadramento step (where you select your entidade gestora) cannot be completed.
The standard SILiAmb declaration deadline of 31 March applies in theory, but with no operational scheme there are no fees to pay and no declarations to file. Foreign producers are expected to appoint a representante autorizado, but the practical path is blocked alongside the scheme.
The same RGGR penalty framework applies (contraordenação ambiental grave for non-registration), though enforcement against a duty that cannot be fulfilled is a grey area.
Frequently asked questions about fishing gear EPR in Portugal
What producers of fishing gear need to know right now.
Who has to register for fishing gear EPR in Portugal?
Any producer placing plastic-containing fishing gear on the Portuguese market. The duty has been in force since 1 January 2025 under DL 78/2021, but no scheme exists to complete the registration process.
How much does fishing gear EPR cost in Portugal?
Nothing yet. No scheme has been licensed, so there are no fees. SILiAmb registration itself is free across all streams.
What happens if I sell without registering?
Non-registration is classified as a contraordenação ambiental grave under the RGGR. In practice, enforcement against a duty whose completion path is blocked remains unclear.
Which register covers fishing gear in Portugal?
SILiAmb (siliamb.apambiente.pt), operated by APA. Fishing gear is listed as a stream, but the enquadramento cannot be completed until a scheme is licensed.