Country brief
Register packaging in APA's RPP through SILiAmb/SIRER, contract a compliance system, and file annual declarations by 31 March (2026 window extended to 30 April).
Under the current PPWR rule, an EU company selling packaged products directly to end users in Portugal must appoint an EPR authorised representative there. Portugal requires a locally established AR for a non-EU direct seller. A pending EU proposal may suspend the EU cross-border rule, but it has not changed current law.
PPWR still requires annual packaging data below 10 tonnes; the dataset is simplified rather than exempt, and a Member State can set a lower simplification limit or require quarterly reporting. No general mass exemption was confirmed. Registration is due within one month after first placing.
Legal requirements
This is general information based on the official sources linked below. The answer still depends on the legal entity, transaction, recipient, packaging stream, and rule in force.
Information needed
Typical workflow
Classify and register RPP.
Contract system and appoint AR where required.
File annual declaration and reconcile fees.
What smbf.me can help with
smbf.me can prepare APA files; APA confirms live portal and AR requirements.
These are service boundaries, not a legal conclusion. The local authority, register, scheme, AR, or filing recipient decides acceptance.
Primary evidence
Sources checked on 13 September 2026. Open each source and verify its current effective version before a legal or filing decision.
Common questions
APA RPP in SILiAmb.
For non-EU direct sellers; EU mandate is optional.
31 March; 2026 had an extension to 30 April.
Next step
Open the country view for the local steps and official sources, or connect your orders and let smbf.me organise the route.