EPR in Portugal 2026: Packaging, WEEE & Batteries

What changed in 2026

The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) entered into force on 11 February 2025 and applies from 12 August 2026. For Portugal, the most important point for foreign sellers is that the representative duty is not new: Portugal has required an authorized representative for foreign distance sellers of packaging since 1 January 2022, and for electrical equipment since 2018.

• Art. 45 PPWR now also requires producers who sell packaged products directly to end users in another member state – EU or non-EU established – to appoint an authorized representative there. In Portugal, this matches the existing national rule.
• Penalty rules: member states must lay down PPWR penalty rules by 12 February 2027. Existing Portuguese penalties under Lei 50/2006 continue to apply.
• Pragmatic enforcement: the European Commission has asked member states to enforce the representative duty "in a constructive and pragmatic" way while an exemption is negotiated.

Packaging obligations in Portugal

A packaging producer is the business that first makes packaging available on the Portuguese market. A seller established abroad who ships packaged goods directly to Portuguese end users is a distance seller and the producer of that packaging, including shipping cartons and filling material.

1. Map your Portuguese packaging. Record every packaging type that reaches Portuguese customers, by material and weight.
2. Appoint an authorized representative. Mandatory for foreign distance sellers of packaging since 1 January 2022 (DL 152-D/2017, art. 20(2)).
3. Register in SILiAmb. The producer register is kept by APA on its SILiAmb platform; you receive a producer number such as PTFF000000.
4. Set up the management scheme. Licensed schemes include SPV, Novo Verde and Electrão. Which one fits depends on your products – we confirm it for you.
5. Show your number on invoices. APA requires the producer number to appear on invoices.

The PTFF producer number

The PTFF number is the producer registration number assigned in APA's producer register, in a format such as PTFF000000. According to APA, it must appear on invoices. For marketplace sellers it is also the number you provide where a platform asks for your Portuguese EPR registration – eBay, for example, requires packaging EPR numbers for each country where the seller is a producer and may hide listings without them.

WEEE obligations (electrical and electronic equipment)

Producers of electrical and electronic equipment also register in APA's producer register. Portugal has required an authorized representative for foreign distance sellers of EEE to end users since 2018 – earlier than for packaging and batteries. Scheme choice, categories and reporting depend on your product range and are confirmed in our free check.

Battery obligations

Foreign distance sellers of batteries to Portuguese end users must appoint an authorized representative since 1 January 2022. At EU level, the EPR regime of the Battery Regulation (EU) 2023/1542 applies since 18 August 2025.

• From 18 February 2027 (reported): QR code on all batteries, removability and replaceability rules, and a battery passport for EV, LMT and industrial batteries above 2 kWh.
• 18 August 2027 (reported): due-diligence obligations, postponed by Regulation (EU) 2025/1561.
• Proposal – not yet law The EU Omnibus would also suspend the batteries representative duty under the Battery Regulation; Parliament voted on 20 October 2026, the Council position is pending.

Authorized representative in Portugal

An authorized representative is a business that fulfils the producer's EPR obligations in Portugal on behalf of a seller established abroad. Under DL 152-D/2017, art. 20(2), it is mandatory for foreign distance sellers to end users:

How Certify helps

1. Free obligation check. Tell us what you sell, where you are established and how you ship to Portugal.
2. Route mapping. We map the streams you are a producer for, the right scheme and the SILiAmb registration, and check the current route with APA.
3. Representation. Certify can act as your authorized representative and coordinate registration and reporting – also in the other EU countries you ship to.

More on the role: authorized representative explained (register-epr.com).

Deadlines relevant for Portugal

All countries in one view: EPR deadline calendar 2026–2027.

Penalties in Portugal

Portuguese environmental offences are governed by the Framework Law on Environmental Offences, Lei 50/2006. For serious offences, the fines for companies are:

How a specific breach is classified depends on the facts. On marketplaces, Amazon may need to stop selling non-compliant products, and eBay may hide listings where the required EPR number is missing.