Portugal
Does Portuguese packaging EPR apply to you
Packaging EPR in Portugal catches more roles than most markets:
- Producers who manufacture or import packaged goods for the Portuguese market.
- Embaladores (packers) who pack products for resale, even if they do not sell to end consumers.
- Importers of packaged products.
- Foreign suppliers of service packaging who sell into Portugal.
There is no volume threshold. The embalador role is a distinctive Portuguese feature: you must register even if you only pack products for another company's resale.
Your SILiAmb registration and reporting in Portugal
Registration runs through SILiAmb (siliamb.apambiente.pt). You create an Enquadramento selecting your packaging categories (primary, secondary, tertiary; household vs industrial; reusable vs non-reusable) and your SIGRE scheme.
The scheme validates, and APA issues a per-stream Certificado de Registo.
Annual declarations are due by 31 March (declarative period 1 January to 31 March). You file a correction (actual quantities) and an estimate (expected quantities). Reusable packaging has its own reporting form.
If you have no Portuguese establishment
Foreign producers and foreign suppliers of service packaging must appoint a representante autorizado in Portugal by written mandate. The AR registers in SILiAmb and carries the EPR duties. APA's FAQ explicitly covers foreign service-packaging suppliers.
Non-registration and non-declaration are each classified as a contraordenação ambiental grave under the RGGR. Enforcement falls to the entities listed in Art. 116, not to APA directly.
The dates ahead for packaging in Portugal
The PPWR (Regulation (EU) 2025/40) applies directly in Portugal from 12 August 2026. One practical detail for tyre producers: tyre labels and stickers currently counted as packaging will stop being packaging from that date under the PPWR rules.
The deposit-return system (SDR) is live, managed by SDR Portugal. From the 2027 declarative period, SDR-scope beverage packaging shifts from SIGRE to the SDR system, splitting what used to be one declaration stream into two.
Frequently asked questions about packaging EPR in Portugal
What producers and importers ask most.
What does packaging EPR mean in Portugal?
It means producers placing packaging on the Portuguese market must register in SILiAmb, join a licensed SIGRE scheme, and submit annual declarations by 31 March. The obligation runs under UNILEX (Decreto-Lei 152-D/2017).
Who has to register for packaging EPR in Portugal?
Anyone placing packaging on the market, including embaladores (packers who pack for resale). There is no volume threshold. Foreign suppliers of service packaging must also register through a representante autorizado.
How much does packaging EPR cost in Portugal?
SILiAmb registration is free. The cost comes from joining a SIGRE scheme (Electrão, Novo Verde, SPV, among others), which sets fees per material and weight. No official Portuguese fee amount has been published by APA.
When are packaging reports due in Portugal?
Both the correction and estimate declarations are due by 31 March each year. Reusable packaging has its own reporting form.
