Portugal
Selling lubricant oils into Portugal
The scope of waste oils EPR in Portugal is wider than the label suggests. You import a piece of equipment that contains lubricant oil, and you are an oil producer. You import a used vehicle, and you must declare the oil, the batteries and the tyres it contains.
The duty covers lubricant oils (óleos lubrificantes) only. Food oils (óleos alimentares) have been out of scope since 1 July 2021 under DL 102-D/2020. If your product contains lubricant oil, you are in scope regardless of volume.
Getting your Portugal registration in place
Registration runs through SILiAmb, the same portal Portugal uses for all EPR streams. You create an Enquadramento selecting the lubricant oils stream and join the SIGOU scheme. The system issues a per-stream Certificado de Registo.
Used-vehicle importers face a multi-stream filing: you declare not just the oil but also the batteries and tyres contained in the vehicles. Each is a separate stream in SILiAmb.
Your reporting duties in Portugal
Annual declarations go through SILiAmb by 31 March each year. You file a correction (actual quantities placed on the market in the prior year) and an estimate (expected quantities for the current year). The declarative period runs from 1 January to 31 March.
What you pay and to whom in Portugal
SILiAmb registration costs nothing. The real cost is participation in the SIGOU scheme, which sets its own fees.
No official Portuguese oil EPR fee amount has been published by APA. The fee funds the collection, treatment and regeneration of used lubricant oils through the SIGOU system.
Foreign sellers without Portuguese establishment must appoint a representante autorizado in Portugal by written mandate under UNILEX. The AR registers in SILiAmb and assumes all EPR duties.
Frequently asked questions about waste oils EPR in Portugal
What producers and importers ask most.
Who has to register for waste oils EPR in Portugal?
Anyone placing lubricant oils on the Portuguese market. This includes oils sold standalone and oils incorporated in imported equipment or used vehicles.
Is there a threshold or exemption for small producers?
No de minimis has been found on official Portuguese sources. The producer definition is broad and includes oils inside imported equipment.
Do foreign or online sellers need an authorised representative in Portugal?
Yes. Foreign producers must appoint a representante autorizado established in Portugal by written mandate under UNILEX.
What happens if I sell without registering?
Non-registration is classified as a contraordenação ambiental grave under the RGGR. APA does not enforce directly; enforcement falls to the entities listed in Art. 116.
