EPR System in Portugal

Extended Producer Responsibility—usually shortened to EPR—is essentially a “you sell it, you’re responsible for the waste it creates” system. Portugal applies this concept to a wide range of products, from normal packaging to electronics, batteries, oils, tires, vehicles, and soon even things like furniture and mattresses. The idea behind it is simple: if a business puts products or packaging into the Portuguese market, then that business is responsible for helping to pay for the proper collection, sorting, and recycling once customers throw those products away. In practice, that means registering in the Portuguese EPR system, reporting how much you place on the market every year, and paying environmental fees through specific compliance organizations.

For years, many smaller online sellers never really had to think about this, because enforcement was light, information was scattered, and cross-border online sales were not a major government focus. That era is over. Portugal has significantly modernized and centralized its environmental supervision, and products sold online are now treated the same as products sold in physical shops. Today, every seller placing covered products on the market—no matter how small—must follow the rules. There are no volume thresholds, no exceptions for microbusinesses, and no loopholes for non-Portuguese sellers. Even if you only ship a handful of parcels a month, you’re still responsible.

This matters for domestic sellers, but it’s especially important for cross-border e-commerce. A German candle brand shipping to Lisbon, a Polish lifestyle store using Allegro, a Spanish dropshipper sending parcels across borders, or a young founder in the Netherlands selling refurbished electronics—all of them have to meet the same EPR rules once their goods reach a customer in Portugal. And crucially, foreign sellers must appoint what’s called an Authorized Representative: a Portuguese legal entity that takes over your EPR duties locally. Without one, your registrations aren’t valid, and you can’t legally place products on the Portuguese market.

The urgency grows even more when you look at what’s changing next. From January 2025, Portugal expanded the definition of packaging that needs to be managed under EPR. It no longer applies only to the box the customer sees, but also to all the transport packaging behind the scenes—things like pallets, tertiary cardboard boxes, bubble wrap, and internal protective materials used during shipping. For online sellers who use fulfilment warehouses or move stock through multiple logistics steps, this instantly increases the amount of packaging that must be declared. At the same time, Portugal introduced mandatory sorting instructions on packaging, which means that anything non-reusable must now clearly tell the customer which bin to use when throwing it away.

And more changes are coming. By the end of 2025, Portugal will bring new categories—such as furniture, mattresses, and selected home health products—into the EPR system. For e-commerce businesses selling home goods, interior products, or bulky items, this is a huge shift. It means new reporting obligations, new fees, and, for foreign sellers, new responsibilities for your Authorized Representative.

All of this reflects a broader trend: governments around the EU are moving toward stricter waste management rules, tighter compliance checks, and earlier involvement of online marketplaces. Portugal is no exception—in fact, it’s accelerating faster than many other EU countries, especially when it comes to WEEE (electronics) and packaging enforcement. The country has already increased penalties for non-compliance, including very substantial fines for sellers who place products on the market without proper registration. This matters because online sellers often operate across borders without realizing how different EPR systems work in each country. Being compliant in your home country does not automatically mean you are compliant in Portugal.

But despite the legal language and the long lists of requirements, EPR in Portugal is manageable once you break it down. It simply requires understanding what categories apply to your business, registering in the right places, choosing a compliance organization, reporting your annual quantities, and paying the fees. The real challenge for many young e-commerce founders is not the process itself but the lack of clear, friendly explanations. That’s exactly what this article sets out to solve. Over the next sections, we’ll walk through every part of Portugal’s EPR system—what the rules are, who they affect, how to register, how to report, what changes are coming, and how to stay compliant without drowning in paperwork.

If Portugal is already one of your markets—or if you’re planning to expand there—having this clarity from the start can save you time, money, and a whole lot of stress. Let’s dive in.

What Is the EPR System in Portugal?

Definition of Extended Producer Responsibility

Extended Producer Responsibility, usually shortened to EPR, is a policy approach that makes businesses responsible for the environmental impact of the products and packaging they place on the market. Instead of the government or waste companies covering all the costs of collection, sorting, and recycling, the producer shares that responsibility. For e-commerce sellers, this means that if you ship anything to a customer in Portugal—whether you’re based in Porto, Berlin, Kraków, or anywhere else—you are considered a producer under Portuguese law. You don’t have to physically manage the waste yourself, but you must register, report your annual quantities, and contribute financially to the country’s recycling system.

EPR covers a wide range of product categories: everyday packaging, electronics, batteries, oils, tires, and even vehicles. Over time, Portugal has expanded this responsibility to keep up with EU sustainability goals, and this trend is accelerating. For small online businesses, especially those selling across borders, EPR is becoming just as important as VAT or marketplace compliance.

Legal Basis: Decree-Law 152-D/2017

Portugal’s entire EPR framework is built on Decree-Law 152-D/2017, which came into force in 2018. This law reorganised and modernised the country’s waste rules by merging multiple separate regulations into one coherent system. It defines which waste streams are covered, explains who counts as a producer, and outlines the responsibilities companies have once they place products on the Portuguese market.

If you ever try reading the law, you’ll find it’s dense, full of references to EU directives, and not exactly written for young founders running a Shopify store or marketplace shop. But its purpose is straightforward: anyone placing covered products or packaging on the Portuguese market must take responsibility for its end-of-life treatment. And because the law follows the “country of destination” principle, foreign sellers are treated the same as local ones. The moment your parcel gets delivered to a customer in Portugal, you fall under this legislation.

This is why many cross-border e-commerce businesses suddenly discover they need to register, join a compliance organisation, or appoint an Authorized Representative — because the law doesn’t care where your company is based; it cares where your products end up.

Alignment With EU Circular-Economy Legislation

Portugal didn’t create this system in isolation. Decree-Law 152-D/2017 is directly tied to a broader set of EU waste directives designed to push Europe toward a more circular, low-waste economy. The goals are consistent across member states: reduce landfill, increase recycling, and make companies more accountable for the environmental impact of what they sell.

What makes Portugal stand out is its pace of implementation. In some areas, the country is moving faster than the minimum EU requirements—especially with its 2025 packaging expansion, new mandatory labeling rules, and the introduction of new categories like furniture and mattresses. These changes are part of the EU’s long-term sustainability strategy, but Portugal has become one of the more proactive countries in translating those goals into national law.

For e-commerce founders, understanding this alignment helps everything make more sense. EPR is not just local paperwork—it’s part of a Europe-wide shift. If you plan to expand across multiple EU markets, this pattern will repeat, with each country adding its own nuances. Portugal’s system is simply one piece of that larger puzzle, and learning how it works now will make future compliance smoother in other markets too.

Who Must Comply? (EPR Obligated Parties)

Producers and Manufacturers

In Portugal, the word producer covers much more than people imagine. It’s not just factories or big manufacturers. Anyone who makes products available on the Portuguese market for the first time is treated as a producer under EPR law. That includes companies manufacturing in Portugal, but also any business selling its own branded goods from another EU country or beyond. As long as your product reaches a Portuguese customer and carries your brand, you’re the one responsible for the waste it creates.

This responsibility applies no matter how big your business is. The rules don’t change if you’re shipping hundreds of parcels a day or just starting out from your living room. The Portuguese system doesn’t use turnover or volume thresholds to decide who has to comply. It focuses on one thing: whether you place products or packaging on the national market. For young entrepreneurs, this can feel strange at first — but it’s how the whole EPR logic works across Europe.

Importers

Importers also fall under the definition of producers. If your business brings goods into Portugal, either from other EU countries or from outside the EU, you become the obligated party unless the foreign manufacturer has officially taken over the responsibility through an Authorized Representative.

In reality, most foreign suppliers do not appoint Authorized Representatives in Portugal unless they actively target the market themselves. That means the importer usually carries the responsibility by default. This is important for small e-commerce sellers who source stock abroad. Even if you’re simply reselling items manufactured elsewhere, once you import them into Portugal, you’re the one considered to be placing them on the market and therefore responsible for complying with EPR rules.

Foreign Distance Sellers and E-Commerce Platforms

If you run an online shop outside Portugal but ship orders to Portuguese customers, you are considered to be placing products on the Portuguese market — and that triggers EPR obligations, even if your business has no physical presence in the country. This applies across the board: EU sellers, non-EU sellers, small independent brands, dropshippers, marketplace shops, all of them fall under the same rules.

Because you’re not established in Portugal, you must appoint an Authorized Representative. This local representative becomes the official point of contact for the Portuguese Environment Agency and handles your EPR duties on your behalf. Without one, you cannot meet your legal obligations properly, even if you try to register on your own from abroad. It’s simply how the structure is designed.

The key message is straightforward: if you’re an online seller and Portuguese customers can order your products, you are responsible for EPR in Portugal, and you need a local representative to manage it.

Packers, Fillers, Distributors, and Brand Owners

EPR obligations also apply to anyone who packages products, fills containers, or applies a brand — even if they are not the original manufacturer. This is especially relevant for e-commerce businesses creating private-label products, assembling curated sets, or repackaging goods before shipping.

If you buy generic or unbranded products and add your logo, you become the producer under EPR rules. If you repackage items into bundles or seasonal kits, you’re also responsible for the packaging you introduce into the market. Distributors and retailers have their own responsibilities too, especially when it comes to take-back obligations for items like WEEE or batteries, though those obligations can vary by stream.

The basic principle is simple: whichever business controls the branding or packaging at the moment a product is placed on the Portuguese market is the one responsible for its end-of-life management.

Small Producers: The Under-1-Ton Note

Portugal recognises that businesses placing very small quantities of packaging on the market — for example, under one tonne per year — may fall under a “small producer” category. In practice, this can mean simplified procedures or a different fee structure depending on the Producer Responsibility Organisation you join.

However, this does not remove the core obligations. Even if your volumes are tiny, you still need to register, join a PRO, report your annual quantities, and fulfil your compliance duties. There is no exemption that allows micro-sellers to skip EPR entirely. For young online businesses or creators selling limited quantities, this is important to understand. Small volume simply means simplified administration in some cases, not a free pass.

Product Categories Covered Under Portuguese EPR

When you look at Portugal’s EPR rules from an e-commerce point of view, one question matters more than anything else: which of my products actually trigger obligations? The good news is that the list is clear. The slightly annoying news is that it’s also quite broad.

Let’s walk through the main categories one by one, so you can quickly see where your shop fits in.

Packaging and Packaging Waste

If you sell anything at all, this is the category you almost certainly fall under.

In Portugal, packaging EPR covers pretty much every layer of material around your product. That means the box your customer opens, the cute branded tissue paper, the plastic bag around a bottle, the cardboard shipper the courier brings, and the big brown boxes you use to move stock between locations. Legally, this is usually split into primary, secondary and tertiary packaging, but in simple terms you can think of it as customer-facing packaging, grouping packaging and transport/warehouse packaging.

Packaging EPR has existed in Portugal for years, but there used to be a practical split between “urban” (household-style) packaging and everything else. Household packaging was clearly managed through EPR systems, while industrial or commercial packaging sat in a bit of a grey zone.

That changed on 1 January 2025. From that date, Portugal expanded its EPR obligations to explicitly cover non-urban packaging as well. In other words, industrial and commercial packaging now has to go through the same kind of system as household packaging. For you as an e-commerce seller, this means that not only the box that arrives at the customer’s door counts, but also things like pallet wrap, large cartons used in your warehouse, bulk boxes, and other transport materials that previously might have been ignored.

So if your business uses 3PL warehouses, fulfilment centres or a network of partners in Portugal, you’ll need to make sure that all these packaging flows are being included in your declarations. It’s no longer enough just to estimate the size of the shipping boxes the customer sees and call it a day.

WEEE (Electrical and Electronic Equipment)

If your shop sells anything with a plug, cable or battery, you’re probably in WEEE territory.

WEEE covers a very wide range of electrical and electronic equipment: laptops, phones, tablets, small kitchen appliances, shavers, hairdryers, headphones, LED lights, chargers, smart home gadgets, gaming gear, electric toys, e-scooter chargers, and much more. Even small, “low-tech” electronics are still WEEE in the eyes of the law.

Portugal has been tightening how it oversees this category. Authorities and Producer Responsibility Organisations are paying closer attention to electronics, especially when sold cross-border, because they are expensive to recycle and contain valuable and sometimes hazardous materials. In practice, that means more checks, more structured reporting, and real consequences if companies simply ignore their obligations.

It’s safer to think like this: if your product needs electricity at any point in its life, assume it is WEEE and should be registered and reported accordingly. For many young founders, this includes surprise items such as ring lights for content creation, USB desk fans or LED decoration strips that might have never felt like “serious electronics”, but absolutely count under the rules.

Batteries and Accumulators

Batteries have their own EPR stream in Portugal, separate from WEEE, even though the two often go hand in hand.

If you sell loose batteries, that’s straightforward. But even if you never sell a single AA pack, you can still fall into this category because of the batteries inside your products. Toys, remote controls, kitchen tools, grooming devices, bike lights, smart locks, camera gear and pretty much all portable electronics rely on batteries of some kind. Button cells are treated just as seriously as chunky rechargeable packs.

From a compliance point of view, batteries often need to be reported separately, sometimes through specific sections in your PRO contract. Fees can also be calculated differently than for normal packaging or WEEE. The key takeaway is: don’t forget the battery inside the device. If it’s there, it brings a separate set of obligations with it.

End-of-Life Vehicles (ELVs)

This is not a typical e-commerce category, but it’s still part of the bigger EPR picture in Portugal.

ELV responsibilities apply mainly to companies that place vehicles on the market: cars, vans, motorbikes and certain larger vehicles. The rules cover collection, dismantling, recycling of metals, and proper treatment of fluids and hazardous components through a network of authorised treatment facilities.

Most small online stores selling lifestyle products, fashion, cosmetics or general consumer goods will never have to think about ELVs. But if you run a niche business involved in importing vehicles or selling them into Portugal, then you’re in a highly regulated space and ELV EPR becomes a core part of your obligations.

Mineral Oils

Used oils are another dedicated EPR stream in Portugal. This category covers lubricating oils and similar products used in engines, gearboxes and machinery.

If your shop sells motor oils, lubes for tools or bikes, or other oil-based maintenance products, then you’re placing products on the market that will eventually turn into used oil waste. Because this waste is considered environmentally sensitive, Portugal requires producers to contribute to specialised systems that collect and treat these oils properly.

Even if you only sell small quantities, you still need to look at this stream and make sure it’s included in your registration and reporting. For small automotive, motorsport or DIY repair brands, this is one of those “hidden” obligations that can easily be missed without a closer look.

Tires

Tyres are also covered by EPR in Portugal. This includes car tyres, motorbike tyres, bicycle tyres and certain industrial or heavy-duty tyres, depending on your product range.

If your e-commerce business sells complete wheels, replacement tyres or specialised tyre products into Portugal, you are expected to join the appropriate system that handles collection and recycling of end-of-life tyres. These systems are quite mature and operate through established networks of collection and processing partners.

Again, for most general e-commerce stores this will not be relevant. But if you’re in the mobility, cycling or automotive niche, tyres are something you need to treat as a dedicated compliance stream, not just “another product”.

Used Cooking Oils

Used cooking oils sit in a more niche and evolving part of the Portuguese waste system, but they are still linked to extended producer responsibility principles.

They matter mainly for businesses that deal in food at scale: oil suppliers, food service wholesalers, commercial kitchen operators and similar players. For a small D2C brand selling a few bottles of olive oil or specialty cooking oils online, the reality on the ground will usually be less intense than for a company supplying restaurants. But the direction is clear: Portugal wants used cooking oils to be collected and turned into resources such as biodiesel, rather than poured down the drain.

If your business model leans more B2B in the food world, or if you sell cooking oils in larger formats, it’s worth checking how used cooking oil schemes interact with your EPR responsibilities and whether specific collection or reporting duties apply.

Upcoming Categories (2025 Onward)

Portugal isn’t stopping with the categories above. The legal framework has already been updated to bring new product groups into the EPR system, and this will start to bite from the end of 2025 and into 2026. If you sell home goods, furniture or wellness products, this part is especially important.

Furniture

Furniture is being added to the Portuguese EPR system as a new waste stream. The legal groundwork is in place now, with the system expected to be operational by the end of 2025 and full obligations effectively applying from 2026.

For online sellers, this includes a wide range of products: tables, chairs, shelves, wardrobes, cabinets, desks, bed frames, sofa structures and similar pieces. If your brand ships flat-pack furniture, modular storage, office furniture or design pieces to Portuguese customers, you’ll be pulled into this new EPR stream.

Because furniture is bulky, expensive to collect, and made from mixed materials, it’s likely that fees and reporting will be more substantial than for smaller, simpler items. The smart move is to map your furniture portfolio now and keep an eye on how Producer Responsibility Organisations set up the detailed rules.

Mattresses

Mattresses are following the same path as furniture. They are being brought under the EPR umbrella with registration and systems to be in place around the end of 2025, and practical obligations kicking in from 2026.

From a waste-management point of view, mattresses are a big deal: they’re large, heavy, and made from multiple layers of foam, textiles and springs. That makes recycling complex and costly, which is exactly why EPR is being applied here.

If your e-commerce business sells mattresses, toppers or similar bulky bedding, you should assume that new obligations are coming and start factoring them into your long-term pricing and logistics plans.

Home Health Self-Care Products

The third “new” category is a bit more technical and still being defined in detail: home health self-care products. In different summaries it’s sometimes phrased as self-care home appliances or home health articles, but the core idea is the same: certain products used at home for health, care or comfort will be treated as a dedicated EPR stream.

This might include things like specific medical aids, certain types of cushions or supports, or equipment used for personal care in a home setting. The exact product list will depend on how the Portuguese authorities finalise the implementing rules.

For now, the key point for e-commerce sellers is awareness. If your brand operates in the health, wellness or home-care niche, this is an area to watch closely. As the scope becomes clearer, you may find that some of your SKUs need to be reported under this new category in addition to your existing packaging or WEEE obligations.

Taken together, these product categories show how wide Portugal’s EPR system really is. Packaging hits almost everyone, WEEE and batteries are crucial for gadget and electronics brands, and the upcoming furniture and mattress rules will reshape how home-goods sellers think about the end of their products’ life cycle. Understanding where your own product catalogue fits is the first real step toward staying compliant without nasty surprises later.

The SIRER System: The Core of Registration & Reporting

Role of SIRER and Its Link With SILIAMB

If you plan to comply with EPR in Portugal, you will eventually end up inside SIRER, whether you want to or not. SIRER — the Sistema Integrado de Registo Eletrónico de Resíduos — is Portugal’s central online system for everything related to waste registration. Think of it as the government’s master database for tracking which companies place products and packaging on the market, how much they place, and which compliance systems they use.

For an e-commerce founder, the easiest way to understand SIRER is this: it’s where your company officially “exists” in the Portuguese environmental system. If you aren’t in SIRER, you aren’t compliant, even if you’ve joined a Producer Responsibility Organisation or appointed an Authorized Representative.

Access to SIRER happens through another platform called SILIAMB, the broader environmental licensing portal used for multiple environmental processes in Portugal. SIRER is effectively a module inside SILIAMB. Your Authorized Representative usually handles this for you if you’re based abroad, but it’s still useful to know that SILIAMB is the entry point, and SIRER is the specific place where EPR-related data is filed.

What Data Must Be Registered

SIRER is basically the central record of who is producing what, how much enters the market, and how that waste will be handled. When your business registers, the system asks you for detailed information, which typically includes your company details, the waste streams you’re responsible for, the Producer Responsibility Organisations you’ve joined, and the quantities you expect to place on the market during the year.

Later, it becomes the place where you submit your annual declarations. These declarations cover the actual quantities of products and packaging that you placed on the Portuguese market in the previous year. For packaging, that could include the weight of cardboard, plastic, glass, metal or composites. For WEEE, it means the total weight of each category of electronic devices. For batteries, it’s the weight of batteries placed on the market by type.

You are also required to report the system you’re using to manage compliance — either an individual system (rare for small companies) or a PRO for each stream. This information must match what your PRO has on file and is one of the reasons accuracy matters so much.

For many young e-commerce sellers, SIRER becomes the first place where the actual size of their environmental footprint becomes visible. It forces you to quantify the packaging you use, the electronics you sell, or the batteries inside your products, and it links all of that to a national database.

Who Manages the System (APA)

SIRER sits under the authority of APA, the Agência Portuguesa do Ambiente, or Portuguese Environment Agency. APA is the regulator that oversees environmental compliance in Portugal, including the licensing of Producer Responsibility Organisations, the approval of compliance systems, and the enforcement of EPR rules.

APA uses SIRER to monitor market behaviour, cross-check data submitted by companies with data submitted by PROs, and identify businesses that are not registering or reporting correctly. Over the last few years, the agency has been stepping up its use of the system for enforcement, particularly for categories like WEEE and packaging.

For businesses, this means that SIRER isn’t just a formality. It’s the tool the regulator uses to verify whether you are meeting your obligations. It’s also the system that confirms whether a company is legally allowed to place EPR-covered products on the Portuguese market.

If you’re a foreign e-commerce seller, your Authorized Representative handles your interaction with SIRER on your behalf, but APA still sees your company as the responsible producer. The Authorized Representative simply acts as your official link to the regulator.

Understanding SIRER early makes compliance far easier. It’s the backbone of the entire Portuguese EPR system, and once you know what it does — and why APA relies on it — the rest of the obligations begin to make a lot more sense.

Compliance Pathways: Individual System vs. PROs

Individual Compliance

Portugal technically allows producers to manage their own waste responsibilities through what’s called an individual system. In simple terms, this means the company takes full control of the collection, sorting and recycling of the waste generated by its products or packaging. You have to design the system, run the logistics, and prove to the authorities that everything is being handled according to national rules. It also requires providing financial guarantees to the Portuguese Environment Agency to show that you can cover the full cost of these operations over time.

For most businesses, especially those in e-commerce, this option feels more like running a mini waste-management company alongside your actual business. It demands administrative resources, technical knowledge and long-term investment. That’s why individual compliance is generally chosen only by very large producers with high volumes and the ability to manage complex waste streams on their own. For small or medium online sellers, it’s simply not worth the burden.

Integrated Systems (PROs)

For almost everyone else, joining a Producer Responsibility Organisation — a PRO — is the standard route. A PRO is a licensed entity that takes over the practical side of EPR for you. Instead of organising waste collection yourself, you pay the PRO an eco-contribution based on the types and quantities of packaging, electronics or batteries you place on the Portuguese market. The PRO then handles the recycling targets, reporting requirements and operational responsibilities on behalf of all its members.

The biggest advantage is simplicity. When you join a PRO, you’re essentially outsourcing the most technical parts of EPR to specialists who already run nationwide systems. This makes compliance far easier, especially if your business is small, growing quickly or selling cross-border without a physical presence in Portugal. Most e-commerce brands and SMEs choose this path because it’s cost-effective, recognised by the authorities and removes the heavy administrative load of managing an individual system.

For a young online seller, the decision is almost always straightforward: a PRO keeps you compliant without needing to reinvent the wheel.

Authorized Representative (AR): The Critical Requirement for E-Commerce

Who Needs an AR

If your company is not established in Portugal and you sell directly to end customers in Portugal via distance selling (for example through your own online shop, Amazon, Allegro, Etsy or similar), then you must appoint an Authorized Representative in Portugal. In the eyes of Portuguese law, you’re the producer placing products on the Portuguese market, and you can’t fully meet your EPR obligations without someone local officially representing you.

There is one important nuance though. If you don’t sell directly to Portuguese consumers, but only to Portuguese distributors or importers, then those local companies usually become the producers for EPR purposes. In that case, appointing an AR is not strictly mandatory for you, although you can still choose to do it if you want to take over the obligations from your Portuguese partners.

So, for a typical cross-border B2C e-commerce brand shipping parcels straight to Portuguese buyers, an AR is not a “nice to have” — it’s part of the legal setup.

What the AR Does

The AR is your official face in Portugal for environmental matters. They act in your name in front of the Portuguese Environment Agency and the Producer Responsibility Organisations you join. In practice, that means they register your company in SIRER, sign contracts with PROs, submit your EPR declarations, receive letters or notifications from the authorities and make sure deadlines aren’t missed.

You still remain the producer in legal terms, but the AR is the one inside the Portuguese system pressing the right buttons and talking to the right institutions. For a small or medium online business that doesn’t want to open a Portuguese entity just to be compliant, this is what makes selling legally in Portugal realistic.

Documentation Requirements

To appoint an AR, you need to give them a formal mandate — usually in the form of a power of attorney — plus basic company documents such as a commercial register extract that proves who can sign on behalf of the business. Depending on your country and the AR’s process, these documents may need to follow certain formalities, like notarisation, an apostille and/or an official translation into Portuguese.

That might sound intimidating, but in practice most AR service providers walk you through the steps, provide templates and handle the contact with the Portuguese authorities. For you as a founder, it’s mostly about signing the documents they prepare and sending back the necessary company papers, rather than figuring out the legal details yourself.

Relevance for Amazon, Allegro and Other Cross-Border Sellers

If you rely on marketplaces for sales, the AR topic becomes even more strategic. Platforms like Amazon and Allegro are under increasing pressure to make sure their sellers comply with EPR rules in EU countries. In some markets they already ask for EPR registration numbers and can block listings if sellers don’t provide them. Portugal is moving in the same direction as EU rules tighten.

Without an AR, a foreign B2C seller can’t complete proper EPR registration in Portugal, which means you’re exposed on two fronts: regulatory risk from the authorities and platform risk from marketplaces cleaning up non-compliant accounts. Appointing an AR and getting your EPR setup sorted is therefore not just about avoiding fines — it’s also about keeping your Portuguese sales channel stable as compliance checks become more common.

Registration & Reporting Obligations

Annual Deadlines

Once you’re in the Portuguese EPR system, your year naturally follows a clear reporting rhythm. The first big checkpoint is usually around 15 March, when companies submit their annual declarations to the Producer Responsibility Organisation they’ve joined. This is where you tell your PRO how much packaging, WEEE or how many batteries you placed on the Portuguese market in the previous year. The PRO then uses this data to calculate eco-fees and fulfil its own obligations with the authorities.

The next major deadline is 15 April, when producers must report their annual data to the Portuguese Environment Agency through SIRER. If you work with an Authorized Representative, they normally submit this on your behalf. In 2025, this deadline was exceptionally extended to 31 May, mainly because new rules for industrial and commercial packaging created a heavier workload for companies and for the system itself. It was a one-off adjustment, but it shows how critical accurate reporting has become.

Quarterly Requirements

There’s also one small, ongoing quarterly obligation that catches some sellers by surprise: declarations for lightweight plastic bags. These need to be filed by the 5th day of the month following each quarter. Even if you don’t think of your business as a “bag user”, you may still be affected if your packaging includes lightweight retail-style bags somewhere in the process. It’s a quick declaration, but still mandatory.

What Data Must Be Reported

At the heart of Portuguese EPR reporting is transparency about the quantities you place on the market. For packaging, you declare the weight of each material type — cardboard, plastic, paper, glass, metal or composites. For electronics, you report weights by WEEE category. For batteries, you list the total weight of portable, automotive or industrial batteries sold, whether they were loose or integrated in other products.

This information should line up with what your PRO receives, since the authorities cross-check the data submitted through SIRER with the data submitted by PROs. In practice, this means you need solid internal records: packaging weights from your suppliers or fulfilment partner, clear product categories, and reliable tracking of sales to Portugal.

The system might feel technical the first time you go through it, but once you’ve mapped your packaging weights and product categories properly, the process becomes much more predictable. Many founders create a simple spreadsheet for Portugal and then reuse the same setup for other EU countries with similar EPR rules.

Mandatory Packaging Labeling (Since Jan 1, 2025)

Portugal introduced new rules for packaging information at the start of 2025, and they matter for anyone selling to Portuguese consumers. The key point is that customers must receive clear sorting and disposal instructions for non-reusable primary and secondary packaging that ends up as household waste. You can put this information directly on your packaging, but you don’t have to — the law also allows you to communicate it through other channels, such as your website, product instructions or point-of-sale information. What matters is that the guidance is clear, accessible and in Portuguese.

Sorting and Disposal Instructions

Since 1 January 2025, packers and producers must ensure that Portuguese consumers know exactly how to dispose of each type of packaging material. This can be done on-pack if you prefer, but you’re equally allowed to provide the information in a leaflet, on your product page or in any other format that reaches the customer. The goal is simply to help people sort packaging correctly once they unpack the order.

Material Identification

To support that sorting process, the packaging also needs to show what material it’s made of. Portugal follows the EU’s 97/129/EC identification system, which means familiar codes such as PAP for paper, PET for plastic or GL for glass are accepted. You don’t need elaborate icons; you just need to identify the material clearly and in line with the EU coding scheme.

The Ecoponto System (Color-Coded Bins)

Disposal instructions usually refer to Portugal’s well-known Ecoponto system, which uses simple colour coding:

Amarelo (yellow) for plastic and metal
Azul (blue) for paper and cardboard
Verde (green) for glass

You don’t need to use any specific symbols or graphics — plain text is enough. As long as the customer understands which bin the material should go into, you’re meeting the requirement.

97/129/EC Scheme

Because Portugal aligns with the EU’s material coding system, most packaging already used in the EU can be adapted easily. If your packaging already includes PAP 20, PET 1, GL 70 or similar codes, you can continue using them. They fit perfectly into the Portuguese model and help customers — and waste operators — recognise the material quickly.

Green Dot Symbol – Voluntary

The Green Dot symbol sometimes causes confusion, but in Portugal it remains voluntary from a legal standpoint. You don’t need it to comply with EPR, and not using it doesn’t put you at risk. The only nuance is contractual: if you join Sociedade Ponto Verde, their internal rules may require members to use the symbol on primary packaging. Outside that specific arrangement, you’re free to skip it entirely.

EPR Fees & Eco-Contributions

How Fees Are Calculated

When you join a Producer Responsibility Organisation, you pay eco-contributions based on the weight and type of materials you place on the Portuguese market. For packaging, this usually means the kilograms of cardboard, plastics, glass, metals or composite materials used. For electronics, fees follow the WEEE categories, and for batteries they depend on battery type and chemistry.

In simple terms, the system rewards easy-to-recycle materials and charges more for items that are more complex or costly to process. The lighter and simpler your packaging, the lower your contribution tends to be.

Material Factors, Recyclability and Hazardous Components

Different materials carry different costs. Cardboard is generally on the lower end because it’s widely recyclable. Plastics vary depending on type, with some being inexpensive to process and others more difficult to recycle. Composites and materials that are hard to separate usually cost more.

Products containing hazardous components — like certain batteries, components with specific chemicals or more complex electronics — also come with higher contributions due to the extra care required in treatment. This eco-modulation logic is aligned with EU circular economy rules and has become normal in most EU EPR systems.

Payment Timelines

After your annual declaration, your PRO calculates the eco-contribution and sends you an invoice. Most Portuguese PROs give producers around 30 to 45 days to pay, depending on the organisation and the type of contract. Some may invoice annually, others quarterly, and very small producers may have simplified arrangements. If you work through an Authorized Representative, they usually handle the administrative side and make sure deadlines are met.

Fee Structure Differences: PRO vs. Individual System

The cost structure depends on whether you join a PRO or try to manage compliance under an individual system. Under a PRO, your fees are based on weight and material type, and you benefit from a shared nationwide recycling system used by thousands of companies. This keeps costs predictable and avoids the need to run your own waste-management infrastructure.

The individual system is legally possible but almost never used. It requires the company to create and operate its own collection, sorting and recycling system, backed by financial guarantees submitted to the Portuguese Environment Agency. It also involves audits, technical reports and ongoing verification. For an SME or a cross-border seller, this route is not just more expensive — it’s almost impossible to maintain in practice.

For this reason, nearly every online seller in Portugal relies on a PRO. It’s simpler, more cost-effective and designed for businesses that want to stay compliant without needing to build their own recycling operation behind the scenes.

Penalties for Non-Compliance

Portugal expects every company placing products or packaging on its market to follow the EPR rules — and the system does have teeth. The risk for a small online shop isn’t dramatic, but it’s definitely real enough that you want to stay on top of your registrations and filings. Here’s the version that reflects what is publicly documented without overstating anything.

How Portugal Handles Infringements

Portugal’s environmental enforcement framework does distinguish between lighter, more serious and very serious infringements, with fines increasing depending on the gravity of the case. The exact mapping of every individual EPR error into a specific category isn’t publicly itemised, but the logic is simple: the more the behaviour threatens collection, recycling or environmental safety, the higher the potential penalty.

For companies, fines for standard EPR-related issues typically fall in the range of €500 to €44,890, depending on the case and on the regulator’s interpretation. These amounts come from compliance guidance that summarises how Portuguese administrative penalties normally apply to waste and EPR-related violations. Think of things like missing packaging registration, late declarations, or failing to provide required information — the everyday admin mistakes that happen when compliance is new.

The WEEE Exception: Penalties Up to €5 Million

Where Portugal has been extremely clear is WEEE. Electronics have both recyclability value and environmental risk, so the government treats non-compliance more aggressively. In public communications, authorities have stated that the most serious WEEE violations can lead to sanctions up to €5 million.

This upper limit is intended for extreme cases — large producers, repeated violations, illegal imports, or situations where hazardous waste is mishandled. It is not something an ordinary e-commerce seller will face for a late filing. But it does tell you how seriously Portugal views unregistered electronics.

Other Sanctions You Could Theoretically Face

Fines aren’t the only tool in Portugal’s enforcement kit. The law also allows ancillary measures such as temporary suspension of certain licences or activities, or exclusion from public incentives. These are primarily used for larger companies, waste operators or repeat offenders — not for someone shipping 200 orders from a garage in Berlin or Barcelona — but they are part of the legal framework.

How Long Authorities Have to Act (Statute of Limitations)

Environmental offences in Portugal don’t remain open forever. Limitation periods apply, usually around three years for lighter issues and up to five years for the more serious categories. These timeframes come from the broader environmental administrative offence rules, not EPR-specific legislation, but they do apply to EPR-related infringements because they are part of the same regulatory family.

For a typical online seller, the practical lesson is simple: once you register, join a PRO and get your yearly reporting routine sorted, there isn’t much to fear. Most penalties target companies that never register at all, operate outside the system, or deliberately ignore the rules.

The 2025 Regulatory Changes

Portugal is going through a major EPR transition, and 2025 sits right at the centre of it. New obligations took effect in January, and more are lined up for the end of the year. If you sell anything into Portugal — especially packaged goods, furniture or bulky products — this is a year you’ll want on your radar.

Industrial Packaging Obligations (Since January 1, 2025)

From 1 January 2025, Portugal made it explicit that non-urban packaging — meaning industrial, commercial and logistics packaging — must be handled through a licensed Producer Responsibility Organisation.

This does not mean industrial packaging was previously completely unregulated. But in practice, the EPR system focused mainly on household (“urban”) packaging, while transport and B2B packaging often received less attention. The 2025 reform closes that gap and puts all non-reusable packaging squarely under the same EPR umbrella.

For e-commerce sellers, this means something important:
it’s no longer enough to track only the consumer-facing box. Now your annual declarations must include primary, secondary, and tertiary packaging — from your mailing pouch all the way to pallet wrap, big cartons, void fill, commercial film and other logistics materials.

This also affects B2B sellers. If you ship goods to business clients in Portugal — not just end consumers — the packaging used in those shipments must now be declared and licensed through a PRO. In other words, if the packaging is non-reusable, and you place it on the Portuguese market, it is now clearly within the EPR system.

New EPR Categories (Effective December 31, 2025)

The second major shift happens at the end of 2025. Portugal is adding three entirely new product categories to its EPR framework. The date to remember is 31 December 2025: by then, producers must have registered and prepared for the new system. Full obligations apply from 2026.

The new categories are already confirmed in law, even if the final technical details are still being refined.

Furniture
Tables, chairs, sofas, wardrobes — all of them will fall under the extended responsibility system. If you run a furniture shop or ship flat-packed items cross-border, expect new reporting and eco-fee obligations from 2026.

Mattresses
Mattresses follow exactly the same timeline. They’re bulky, expensive to recycle, and a priority in most circular-economy strategies. For mattress-in-a-box sellers, this shift is significant: Portugal is one of the first countries to formally pull this product group into EPR.

Home health self-care items
This category is confirmed but still being defined. It may include certain small appliances or wellness/health-care products used at home. The scope will be clarified by secondary legislation, but its inclusion in principle is already locked in.

Across all three categories, the trend is clear: more structured collection, more recycling, more producer responsibility. If you sell bulky consumer goods or home-care products into Portugal, this is the part of the reform you’ll want to follow closely.

Conclusion

Why E-Commerce Businesses Should Act Early

If you sell into Portugal — whether a few dozen parcels a month or full-scale operations — the smartest move is to get your EPR setup sorted early. Portugal’s system isn’t designed to scare sellers; it’s designed to make sure every business contributes fairly to recycling and waste management. The moment you have your registrations, PRO contract and packaging weights mapped, the whole thing becomes surprisingly manageable. What trips people up isn’t the workload — it’s waiting too long to start.

Acting early also means you avoid the annual bottlenecks around March and April, when producers across the country rush to file their declarations. When you prepare ahead of time, these deadlines become routine instead of stressful.

Rising Enforcement and Market Access Risks

Portugal is not a passive EPR country. Over the past few years, the government has tightened oversight, stepped up WEEE enforcement, introduced new packaging rules, redesigned SIRER reporting and expanded the list of regulated products. As the system matures, “I didn’t know” stops being a viable excuse — especially for cross-border sellers.

On top of that, marketplaces are moving in the same direction. Amazon, Allegro, Kaufland and others across Europe increasingly ask sellers for EPR registration numbers. Even if Portugal doesn’t currently block listings the way Germany or France do, the direction of EU policy is obvious: marketplaces will soon become gatekeepers for national compliance. If you aren’t registered, you risk restrictions or deactivated listings.

In other words, staying compliant isn’t just about avoiding fines — it protects your ability to keep selling in Portugal at all.

The Benefits of Structured Compliance

Once you put a proper EPR process in place, you actually make your life easier. Good documentation means smooth reporting. Knowing your packaging weights means predictable eco-fees. Having an Authorized Representative means someone in Portugal is handling the bureaucratic side so you don’t have to.

More importantly, EPR compliance builds trust. It signals to marketplaces, regulators and even customers that your business operates professionally and responsibly. For a small brand trying to grow across Europe, that reputation matters more than people realise.

Structured compliance also helps you plan cost-efficiently. When you understand your materials and how fees work, you can switch to lighter packaging, reduce composites or redesign shipments — all of which save money over time.