PPWR ObligationsEU Reg. 2025/40

Who must register for packaging EPR in Portugal, and how

Register: APA via SILiAmb / SIRER Authorised Rep: Only if you sell direct to end users (Art. 45(3)) Load: Moderate to high

Producers register with APA (Agência Portuguesa do Ambiente) via the SILiAmb portal (through SIRER) under Decreto-Lei n.º 152-D/2017, and join a licensed management entity, Sociedade Ponto Verde or Novo Verde. There is no de-minimis for the core obligation. A producer based in another member state or outside the EU that sells by distance contract directly to end users in Portugal must appoint an authorised representative established in Portugal (Art. 20(2)), the same scope as Article 45(3) of Regulation (EU) 2025/40.

Portugal's entry was checked against Decreto-Lei n.º 152-D/2017 and APA Circular 1/2022 on 29 September 2026. This is general information about Regulation (EU) 2025/40 and Portugal's national EPR scheme, not legal advice. Thresholds, fees, penalty amounts and go-live dates come from national law and PRO schedules that change: treat every figure as needing a fresh check, and confirm anything you act on with the national authority or qualified counsel.

Packaging EPR in Portugal at a glance
Register / authorityAPA via SILiAmb / SIRER
PRO / compliance schemeAn entidade gestora: Sociedade Ponto Verde or Novo Verde
Authorised RepresentativeOnly if you sell direct to end users (Art. 45(3))  Art. 20(2) DL 152-D/2017 requires a Portugal-established AR from distance sellers supplying end users directly; the AR registers on your behalf (APA Circular 1/2022)
De-minimis thresholdNone for the core obligation; confirm any simplified procedure with APA
National instrumentDecreto-Lei n.º 152-D/2017, as amended

The register and what it involves

Producers register with APA (Agência Portuguesa do Ambiente) via the SILiAmb environmental portal, specifically through SIRER (the electronic waste registry inside SILiAmb). The legal basis is Decreto-Lei n.º 152-D/2017, the unified regime for specific waste streams, as amended, including by Decreto-Lei n.º 24/2024. Older material may still refer to “SIRAPA”.

You must also join a licensed management entity / PRO (entidade gestora), Sociedade Ponto Verde or Novo Verde, and pay its fees.

The Authorised Representative rule

Portuguese law requires one from distance sellers. Under Article 20(2) of Decreto-Lei n.º 152-D/2017, a producer established in another member state or in a third country that sells by distance contract directly to end users in Portugal must appoint an authorised representative established in Portugal, who registers with APA on the producer's behalf. APA explains how this works in Circular 1/2022.

That is the same scope as Article 45(3) of Regulation (EU) 2025/40, which since 12 August 2026 has required a producer that makes packaging available directly to end users in a member state where it is not established to appoint an authorised representative for EPR there. Both rules reach EU-based sellers as well as non-EU ones. If you supply Portuguese distributors or retailers who resell the goods unchanged, you are not the producer in Portugal and neither rule catches you. The proposal to suspend Article 45(3) until 2035, COM(2025) 982, stalled when the Council ended negotiations on it in April 2026 and left it out of its 24 June 2026 mandate, and in Portugal Article 20(2) would require the representative in any case.

De-minimis and reporting

There is no de-minimis for the core obligation, no turnover or volume exemption; registration and reporting apply from the first unit. If you think a simplified procedure fits your volumes, confirm it with APA before relying on it. Reporting is an annual declaration of packaging placed on the market, by material and weight, made to your management entity and to APA through SIRER.

Penalties

APA can impose fines under national law; ask APA or counsel for the amounts if your exposure matters. Penalties for breaching the PPWR itself are for member states to set under Article 68, with national rules due by 12 February 2027. Two changes took effect in 2025: industrial and professional packaging came inside the EPR regime from 1 January 2025 (Decreto-Lei n.º 24/2024), and non-reusable primary and secondary packaging must show its disposal route, on the pack or by other suitable means such as product instructions or at the point of sale.

How onerous is it?

Moderate to high. No de-minimis, a Portugal-established representative for any seller based elsewhere that supplies Portuguese end users by distance sale, plus the 2025 disposal-marking rules and professional packaging brought into scope.

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Frequently asked questions

Which portal do I register with in Portugal?

APA (Agência Portuguesa do Ambiente) via the SILiAmb environmental portal, through SIRER (the electronic waste registry inside SILiAmb), under Decreto-Lei n.º 152-D/2017. Older guidance may still refer to SIRAPA.

Does Portugal have a small-quantity exemption?

No de-minimis for the core obligation: registration and reporting apply from the first unit. If you think a simplified procedure fits your volumes, confirm it with APA; it is not an exemption.

Do foreign sellers need a Portuguese Authorised Representative?

Yes, if you sell directly to end users in Portugal. Under Article 20(2) of Decreto-Lei n.º 152-D/2017, a producer established in another member state or outside the EU that sells by distance contract directly to end users in Portugal must appoint an authorised representative established in Portugal, who registers on its behalf (APA Circular 1/2022). That matches the scope of Article 45(3) of Regulation (EU) 2025/40, which has applied since 12 August 2026. If you sell only to Portuguese businesses that resell the goods, neither rule requires one.

Sources

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