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Portugal — EPR Compliance Guide

This guide is part of our pan-European EPR compliance coverage across 29 EU/EEA countries.

Population
10.3 million
Registration System
Sociedade Ponto Verde
Responsible Authority
APA (Portuguese Environment Agency)
Maximum Fine
€44,891

Key Legislation

Decreto-Lei n.º 152-D/2017

Portugal EPR — Decreto-Lei n.º 152-D/2017. The regulatory authority is APA (Portuguese Environment Agency), operating through the Sociedade Ponto Verde system.

Who Must Register

All producers, importers, online sellers, and fulfillment service providers placing packaged goods on the Portugal market must register with a PRO and fulfill EPR obligations. Non-Portugal sellers must appoint an Authorized Representative.

Compliance Schemes (PROs)

Portugal has a competitive market for packaging compliance since 2016. Producers must register with the APA (Agência Portuguesa do Ambiente) via the SILiAmb platform and contract with a licensed compliance scheme:

  • Ponto Verde (SPV) — Dominant scheme — Sociedade Ponto Verde
  • Novo Verde

Registration: SILiAmb (APA — Agência Portuguesa do Ambiente)

Reporting & Deadlines

Reporting & Deadlines: Annual by March 31. Packaging data must be reported by material type and weight. Reports are submitted through SILIAMB.

Penalties for Non-Compliance

Maximum Fine: €44,891. Non-compliance with Portugal EPR regulations can result in fines, marketplace listing deactivation, and legal consequences. Amazon and other marketplaces may independently verify compliance and suspend non-compliant sellers.

What Marketplace Sellers Need to Know

SILIAMB registration mandatory for all packaging importers

If you sell on Amazon, eBay, or other marketplaces and ship products to Portugal, you are responsible for EPR compliance in this market. The "pay on behalf" model is ending — marketplaces will no longer handle this for you. Register now to avoid listing deactivation.

Step-by-Step Registration Guide

Follow these steps to become fully EPR-compliant in Portugal. Non-Portuguese companies must appoint an Authorized Representative before starting.

1

Register in SILiAmb Portal (APA)

Create an account and register your company in APA's SILiAmb (Sistema Integrado de Licenciamento do Ambiente) portal. This is the mandatory government registration that must be completed before contracting with any PRO. You will need your company details, tax identification, and packaging information. Non-Portuguese companies must appoint an Authorized Representative first.

2

Contract with SPV or Novo Verde

Sign a contract with a licensed Producer Responsibility Organization — either SPV (Sociedade Ponto Verde) or Novo Verde. The PRO manages your packaging waste collection and recycling obligations. Costs depend on your packaging volumes and material types. Both PROs are authorized by APA and fulfill the same legal obligation.

3

Report Packaging Volumes

Submit your packaging data to your chosen PRO, reporting by material type and weight. This data is used to calculate your contributions and feeds into national waste statistics. Keep accurate records of all packaging placed on the Portuguese market, including primary, secondary, and tertiary packaging.

4

Upload Registration to Amazon & Marketplaces

Upload your SILiAmb registration number and PRO contract documentation to Amazon Seller Central (under EPR compliance settings) and any other marketplace platforms where you sell into Portugal. This prevents listing deactivation and demonstrates your compliance.

5

File Annual MIRR Declaration

Submit your annual MIRR (Mapa Integrado de Registo de Resíduos) declaration through SILiAmb by March 31 each year. The MIRR reports all packaging placed on the Portuguese market during the previous calendar year. This is a legal obligation separate from your PRO reporting — both must be completed.

PPWR 2026 — What Changes for Portugal

The EU Packaging and Packaging Waste Regulation (PPWR) is a directly applicable regulation that will progressively replace the current Packaging Directive framework. For sellers operating in Portugal, this means significant changes on top of existing Decreto-Lei n.º 152-D/2017 obligations:

  • New recyclability criteria — all packaging must meet EU-wide recyclability standards, potentially affecting current PRO acceptance criteria
  • Mandatory recycled content targets for plastic packaging, with specific percentage thresholds phased in over time
  • Restrictions on certain single-use packaging formats and excessive packaging (empty space ratios)
  • Harmonized labeling requirements across the EU — Portugal will need to adopt EU-standard packaging labels
  • Updated EPR fee modulation — contributions will reflect actual recyclability and environmental impact, which may change current SPV/Novo Verde fee structures

Portugal will need to adapt its Decreto-Lei n.º 152-D/2017 framework to align with PPWR requirements. The competitive PRO market (SPV vs. Novo Verde) may also see adjustments. Sellers should monitor developments and prepare for additional obligations. Contact ekoniq for up-to-date guidance.

PPWR Compliance for Exporters to the EU

If your company manufactures products outside the EU and exports them to the European market, PPWR requires you to prove that your packaging meets EU sustainability standards — before your goods cross the border. ekoniq prepares the complete PPWR compliance package so you can export with confidence.

What we deliver (15–18 documents):

✓ Full Technical Documentation (Annex VII, Module A)

✓ EU Declaration of Conformity (Annex VIII)

✓ Recyclability assessment of all packaging

✓ Substance restriction verification (PFAS, heavy metals)

✓ Recycled content declaration

✓ Packaging minimisation statement

✓ Labeling guidance (material codes, sorting pictograms, QR)

✓ Accredited lab testing coordination (SGS, Intertek, Bureau Veritas)

✓ EPR registration in target EU countries

✓ Authorised Representative appointment (Article 45)

Request PPWR Compliance Quote Read Full PPWR Guide →

Common Mistakes to Avoid

Many sellers make these mistakes when registering for EPR in Portugal. Avoid them to stay compliant and prevent fines up to €44,891.

Not Registering in SILiAmb

SILiAmb is the mandatory government environmental licensing platform operated by APA. Many sellers skip this step and go directly to contracting with a PRO. However, SILiAmb registration is a legal prerequisite — without it, your PRO contract alone does not make you compliant.

Only Contracting with PRO Without Government Registration

Portugal requires two separate steps: government registration in SILiAmb AND a contract with a PRO (SPV or Novo Verde). Some sellers complete only one of these. Both are mandatory and independent — a PRO contract without SILiAmb registration (or vice versa) leaves a compliance gap that can result in fines.

Missing the MIRR Annual Declaration

The MIRR (Mapa Integrado de Registo de Resíduos) is an annual declaration due by March 31 through SILiAmb. Many sellers register and contract with a PRO but then forget to file the annual MIRR. This is a separate legal obligation — missing it can trigger fines even if your PRO reporting is up to date.

Confusing SPV (Ponto Verde) with the Recycling Symbol

The Ponto Verde (Green Dot) symbol on packaging does not mean the product is recycled or recyclable. It indicates that the producer has contributed to a packaging recovery system. Having the symbol on your packaging does not replace the obligation to register with SPV or Novo Verde and pay contributions. Conversely, you can be registered without displaying the symbol.

Not Appointing an Authorized Representative

Non-Portuguese sellers must appoint an Authorized Representative (AR) to handle their EPR obligations. Without an AR, you cannot register in SILiAmb or contract with a PRO. Many foreign sellers attempt to register directly and encounter administrative barriers. ekoniq can serve as your AR for Portugal, managing the entire process.

Frequently Asked Questions

What is SILiAmb and is it mandatory?

Yes, SILiAmb (Sistema Integrado de Licenciamento do Ambiente) is APA's mandatory online environmental licensing platform. All producers and importers placing packaging on the Portuguese market must register in SILiAmb. This is a government registration separate from and in addition to your PRO contract. Without SILiAmb registration, you are not legally compliant regardless of any PRO arrangement.

What is the difference between SPV and Novo Verde?

Both SPV (Sociedade Ponto Verde) and Novo Verde are APA-authorized Producer Responsibility Organizations. SPV is the historically dominant scheme, while Novo Verde entered the market after liberalization in 2016. Both fulfill the same legal obligation — you only need to contract with one. Costs depend on your packaging volumes and material types. Contact ekoniq for guidance on which PRO best suits your situation.

What is the MIRR declaration and when is it due?

MIRR (Mapa Integrado de Registo de Resíduos) is the annual waste declaration that all registered producers must file through SILiAmb. It reports all packaging placed on the Portuguese market during the previous calendar year. The deadline is March 31. MIRR is a government requirement separate from your PRO reporting — both must be completed annually.

How much does Portugal EPR compliance cost?

Costs depend on your packaging volumes, material types, choice of PRO, and whether you need an Authorized Representative. PRO contributions are calculated based on the weight of each material type placed on the market. There may also be SILiAmb registration fees. Contact ekoniq for a personalized quote based on your specific situation.

Do I need an Authorized Representative for Portugal?

If your company is not established in Portugal, you must appoint an Authorized Representative (AR) to fulfill your EPR obligations. The AR registers on your behalf in SILiAmb, contracts with a PRO (SPV or Novo Verde), reports packaging volumes, and files annual MIRR declarations. ekoniq can serve as your AR for Portugal.

What happens if Amazon deactivates my listings?

Amazon verifies EPR compliance for all EU marketplaces. If you have not uploaded valid EPR registration details for Portugal, Amazon may deactivate your listings. To restore them, you must complete your SILiAmb registration, have an active PRO contract, and upload the details to Seller Central. ekoniq can expedite this process — contact us for urgent assistance.

How long does Portugal EPR registration take?

The timeline depends on the completeness of your documentation and whether you need an Authorized Representative. SILiAmb registration and PRO contracting can take several weeks. ekoniq manages the entire process end-to-end — contact us for current processing times and to get started quickly.

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