👥 Who Must Comply

You are typically in scope if you are the first entity placing packaged goods or packaging on the Portuguese market, such as:

• Brand owners / manufacturers placing products under their name
• Packers/fillers (“quem manda embalar” / “embaladores”)
• Importers introducing packaged products into Portugal
• Suppliers of service packaging (e.g., certain carry bags or packaging supplied at point of sale)

✅ Key Requirements

1) 🧾 Register and submit data in SILiAmb/SIRER

Producers/packers and service-packaging suppliers must register and submit required data through the national system (commonly referenced as SIRER, operationally via SILiAmb).

2) 🔁 Choose your compliance route (Individual vs. Integrated system)

Packaging obligations can be met via an individual system or by contracting an integrated system (SIGRE) operated by a licensed entity.

3) 🏢 Contract with a licensed SIGRE entity (if using the integrated route)

Portugal lists licensed packaging entities (SIGRE) such as:

• Sociedade Ponto Verde
• Novo Verde
• Electrão

4) 🗓️ Submit annual declarations (standard deadline: 31 March)

In the producer/packer register, declarations are typically due by 31 March each year (e.g., “Correção” for the previous year and “Estimativa” for the current year). For example, APA guidance specifies submission in SILiAmb by 31 March 2026 for the relevant declarations.
Authorities may occasionally extend deadlines (e.g., APA extended the 2025 deadline to 31 May 2025).

5) 🔍 Maintain traceability and evidence

You should be able to justify declared quantities and classifications with supporting documentation (BOMs, specifications, calculations, supplier evidence, and change logs) to withstand internal and external checks.

🧩 What You Must Track (Best-Practice Data Model)

To report accurately and reduce rework each year, maintain:

• Packaging hierarchy: primary / secondary / tertiary
• Material composition: plastic, paper/cardboard, glass, metals, wood, composites
• Weights (kg) by SKU and component (BOM-level detail)
• Market placement logic: local packing vs. import vs. other channels
• Evidence library: specs, invoices, product data sheets, weight calculations
• Audit trail: approvals, versions, and changes over time

🛠️ Portugal Packaging EPR Service Scope (Registration • Reporting • Traceability)

🧭 A) Scoping & obligation mapping

• Confirm the obligated role (producer/packer/importer/service packaging)
• Map packaging flows and reporting categories
• Define whether an individual or integrated (SIGRE) route applies per portfolio

🧾 B) Registration setup (SILiAmb/SIRER)

• Build your registration dataset and internal ownership model
• Set up review/approval workflows and evidence retention aligned to declarations

🔁 C) SIGRE onboarding support (if applicable)

• Assist selection and onboarding with a licensed entity
• Align packaging taxonomy to the entity’s reporting requirements

📊 D) Annual reporting delivery

• Prepare “Correção” and “Estimativa” datasets
• Run validation checks (material totals, SKU rollups, variance flags)
• Generate submission-ready outputs for SILiAmb

🔎 E) Traceability systemization

• Centralize packaging BOMs, weights, and material splits
• Link every declared number to evidence and calculation logic
• Keep exportable, audit-ready records year over year

🍾 If You Sell Beverages: Deposit & Return Considerations

Portugal introduced specific regulation for a deposit and return system for non-reusable beverage packaging within the 2024 legal update.

If your portfolio includes beverage packaging, you may need additional operational and data controls alongside standard packaging EPR reporting.

⭐ Why ComplyMarket for Portugal Packaging EPR

ComplyMarket provides an exceptional end-to-end solution for Portugal Packaging EPR, combining expert delivery for registration, SIGRE onboarding, annual declarations, and traceability with its integrated Compliance Management Software and EPR platform.

With ComplyMarket, you can centralize packaging data (materials, weights, SKUs, evidence), automate validations, generate submission-ready outputs, and maintain a complete audit trail—reducing manual workload and compliance risk while scaling smoothly across multiple countries.