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Packaging EPR in Portugal
The register is live — you can register today.
Checked 2026-09-03 · 4 sources · 2 open questions
- Register
- Registo de produtores de produto — SILiAmb / SIRER
- Authority
- Agência Portuguesa do Ambiente (APA)
- Law
- Decreto-Lei n.º 152-D/2017 (‘Unilex’), art. 19.º; RGGR art. 97.º–98.ºtwo duties, two places: register and submit data in SILiAmb/SIRER to the APA, and separately declare the tonnage to the SIGRE you joined (Sociedade Ponto Verde, Novo Verde, Electrão). ⚠️ predominant-material rule: where components of different materials cannot be easily separated, the WHOLE weight counts as the predominant material.
- Who registers
- You register yourself in the national system
- Authorised representative
- Only for distance selling to consumersrepresentante autorizado established in Portugal, appointed by written mandate — required for a company in another Member State or a third country selling DIRECTLY to an end user in Portugal (definition of ‘produtor do produto’, point iv). SILiAmb now supports registering a representative for all streams.
- Reporting
- Annually, by 31 Marchthe annual declaration covers all non-reusable packaging whose first placing on the national market is your responsibility and which is destined for the final consumer. 🔑 packaging of imported RAW MATERIALS for your own use is not placed on the market by the importer — the foreign exporter holds the duty and must declare through an authorised representative.
- Also required
- Membership of a SIGRE
- Household packaging schemes
- Sociedade Ponto Verde (SPV); Novo Verde; Electrão
- Industrial packaging schemes
- Sociedade Ponto Verde (SPV); Novo Verde; Electrão
What is not settled
- Reporting Not established at sourceThe 31 March annual deadline comes from a trade association calendar, not from the APA pages read. Confirm before relying on it.
- Authorised representative Sources disagreeThe authorised-representative duty is under review. On 10 December 2025 the Commission published COM(2025) 982, part of the Omnibus VIII environmental simplification package, whose Article 2 would suspend Art. 45(3) until 1 January 2035; COM(2025) 983 proposes the same for the Single-Use Plastics Directive. The suspension as drafted covers producers ESTABLISHED IN THE UNION selling cross-border directly to end users. Producers established in third countries are not covered — member states may still require a representative or ensure traceability by other means. European Parliament committee reports of May 2026 would narrow the relief to micro and small enterprises. PROPOSAL, AND NOW LARGELY STOPPED: on 24 June 2026 the Council decided not to proceed with the suspension, opposed by a large majority of member states. A Parliament committee vote is expected around October 2026, and even the Parliament's narrower approach would keep the framework for producers outside the EU. Article 45(3) applies as written today, and for a producer established in a third country nothing in this proposal ever applied.
The same in every EU country
- PPWR Art. 44 — registration is a precondition for placing packaging on that market
- PPWR Art. 45(3) — a producer under Art. 3(1)(15)(c)/(d), i.e. one making packaging available in another Member State DIRECTLY TO END USERS, must appoint an authorised representative there. From 12 Aug 2026.
- set nationally, Art. 68; national rules due by 12 Feb 2027
- Art. 44(14) implementing act still pending; central EU register not before 1 Jan 2029
Sources
Countries with the same answer
We do not register you, we are not your authorised representative, and we do not pay a scheme. This is public information gathered in one place and checked on the date shown. Confirm with the national authority before acting.
Tarafex
The number these registers ask for is kilograms by material for one year of deliveries. If your shipments are recorded as they go out, that number already exists.
See what Tarafex does →
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