Portugal is a mid-size EU market for e-commerce, but it is one that many cross-border sellers reach while focusing on the larger markets of Germany, France, and Spain. If you ship to Iberian customers broadly, Portugal will appear in your order data. That means Portuguese packaging EPR obligations, managed through the Sociedade Ponto Verde (SPV), apply to you.
The Portuguese system is less complex than some other EU markets but still requires registration, regular declarations, and fee payments. The good news: the process is well-documented, the fees are moderate, and the timeline to get registered is reasonable. This article walks through everything you need to know.
What Is Sociedade Ponto Verde (SPV)?
Sociedade Ponto Verde, S.A. is Portugal's licensed Producer Responsibility Organisation for packaging. It was established in 1996 under Decree-Law 366-A/97 (subsequently updated by Decree-Law 152-D/2017 and the transposition of EU packaging waste requirements). SPV operates the "Ponto Verde" (Green Dot) scheme, coordinating the collection, sorting, and recycling of household packaging waste across Portugal.
SPV is the dominant operator in Portugal. There is one alternative licensed PRO — Novo Verde — that handles a portion of the market. For most companies registering for the first time, SPV is the standard registration path. Novo Verde is also a legitimate option and operates similarly. This article focuses primarily on SPV, but the reporting structure and deadlines are the same for Novo Verde.
Portuguese law requires companies that place packaged goods on the Portuguese market to either:
- Join a collective system (SPV or Novo Verde), or
- Set up and operate their own individual packaging take-back system
Running a proprietary take-back system is not practical for the vast majority of companies. SPV membership is the standard route.
Who Must Register
The obligation falls on the "responsible operator" (operador responsavel), which is the entity that first places packaging on the Portuguese market. In practice:
- Manufacturers of packaged goods selling in Portugal— if your company manufactures a product and sells it to Portuguese consumers or businesses, you are the responsible operator.
- Importers bringing packaged goods into Portugal— whether from within the EU or from third countries.
- Cross-border e-commerce sellers — if you operate an online store outside Portugal and ship orders to Portuguese addresses, you are placing packaging on the Portuguese market and the obligation is yours.
- Companies using service packaging in Portugal — restaurants, retailers providing carrier bags, etc.
Portugal has a reporting threshold: companies that place less than 1 tonne of packaging on the Portuguese market per year follow a simplified registration path (via the SIRAPA national register) rather than full SPV membership. Above 1 tonne, SPV or Novo Verde membership is required.
One tonne of packaging is roughly 2,500–5,000 corrugated cardboard shipping boxes, depending on box size. If you ship more than a few hundred orders to Portugal per year, you are likely above this threshold.
How to Register with SPV
Step 1: Register in SIRAPA
All packaging operators in Portugal, regardless of volume, must first register in SIRAPA — the Sistema Integrado de Registo da Agencia Portuguesa do Ambiente. SIRAPA is the national environmental register managed by the Portuguese Environment Agency (APA). Your SIRAPA registration gives you a national operator number that is referenced in all subsequent SPV compliance filings.
To register in SIRAPA, you need your Portuguese NIF (tax identification number, if you have one) or your EU VAT number, your company details, and a description of your activity. The SIRAPA portal is at sirapa.apambiente.pt.
Step 2: Apply for SPV membership
With your SIRAPA number in hand, proceed to the SPV portal (pontoverde.pt) to apply for membership. You will need:
- Company legal name, registered address, and contact details
- Your SIRAPA registration number
- Portuguese NIF or EU VAT number
- An estimate of your annual packaging volumes by material type and packaging level (in tonnes)
- Legal representative details — name and authorization to sign on behalf of the company
Step 3: Sign the SPV adhesion contract
SPV will generate a membership contract for signature. This binds you to SPV's statutes, including timely reporting and payment. Once signed and processed, you receive your SPV member number.
Timeline
Registration typically takes 2 to 4 weeks from submission of complete documentation. SPV's process is somewhat streamlined compared to some other EU PROs. The SIRAPA registration step adds approximately one week.
Reportable Packaging Categories
SPV requires declarations across the following material categories:
- Paper and cardboard — corrugated boxes, folding cartons, paper bags, paper labels, tissue paper
- Plastic — poly mailers, bubble wrap, PET trays, rigid plastic containers, LDPE film, EPS foam
- Glass — glass bottles, jars, vials
- Ferrous metals — steel tins, steel closures
- Aluminium — foil, aluminium lids, aluminium tubes
- Wood — pallets, wooden crates
- Other / composite — multi-material laminates, mixed-material packaging that cannot be classified as a single material
Packaging is classified by level — primary, secondary, and tertiary — consistent with EU packaging definitions. For B2C e-commerce, your shipping carton is secondary packaging (it reaches the end consumer). Your product packaging is primary packaging.
SPV Fee Structure for 2026
SPV charges a per-kilogram rate that varies by material type. The 2026 indicative rates reflect both the cost of the waste management system and eco-modulation adjustments for recyclability:
| Material | SPV rate (per kg) |
|---|---|
| Paper and cardboard | €0.065 |
| Plastic | €0.320 |
| Glass | €0.018 |
| Ferrous metals | €0.055 |
| Aluminium | €0.140 |
| Wood | €0.020 |
| Other / composite | €0.280 |
A worked example
Suppose you ship 1,500 orders per year to Portugal. Your average order packaging includes:
- Corrugated cardboard box: 280g
- Plastic poly mailer: 20g
- Paper tissue wrap: 15g
Annual totals: 1,500 × 0.295 kg cardboard = 442.5 kg; 1,500 × 0.020 kg plastic = 30 kg.
SPV fees: (442.5 × €0.065) + (30 × €0.320) = €28.76 + €9.60 = €38.36 per year.
The fees are genuinely modest. The compliance effort — registration, tracking, annual declaration — is the substantive cost.
Reporting Deadlines
Portugal uses annual reporting. The key deadlines are:
| Activity | Deadline |
|---|---|
| Annual declaration submission | March 31 (for prior calendar year) |
| Fee payment | Within 30 days of receiving the SPV invoice |
| SIRAPA annual update | March 31 (same period as SPV declaration) |
The March 31 deadline aligns Portugal broadly with Spain (March 31) and the Netherlands (March 31), making them a natural cluster for coordinating annual compliance work across Iberian and Western European markets.
Portugal Compared to Other Iberian and Southern EU Markets
| Aspect | Portugal (SPV) | Spain (ECOEMBES) | Italy (CONAI) |
|---|---|---|---|
| Registration body | SPV / Novo Verde | ECOEMBES / ECOVIDRIO | CONAI |
| National register | SIRAPA (APA) | MITERD (national) | None separate |
| Reporting frequency | Annual | Annual | Quarterly |
| Annual deadline | March 31 | March 31 | Quarterly |
| Plastic fee (approx.) | €0.320/kg | €0.295/kg | €0.155/kg |
| Cardboard fee (approx.) | €0.065/kg | €0.055/kg | €0.004/kg |
Non-Portuguese Companies
Non-Portuguese companies can register directly with SIRAPA and SPV using their home country VAT number. You do not need a Portuguese entity to comply. The SIRAPA portal is primarily in Portuguese; budget for translation assistance or work with a compliance consultant familiar with the Portuguese system.
Companies based outside the EU may find it practical to appoint a local representative in Portugal or a pan-EU compliance service provider who can handle SIRAPA registration and SPV declarations on your behalf. The representative does not take on your legal liability but acts as your local contact for the Portuguese authorities.
Common Mistakes with Portuguese EPR
Skipping SIRAPA and going straight to SPV
The SIRAPA registration is a prerequisite for SPV membership. If you try to register with SPV without a SIRAPA number, the application will be incomplete. Start with SIRAPA.
Treating Portugal as an afterthought
Companies that sell to Spain often ship to Portugal too, given geographic proximity and shared logistics routes. But Spain and Portugal are completely separate EPR regimes. Your ECOEMBES registration in Spain gives you nothing in Portugal. Register separately.
Reporting in the wrong unit
SPV declarations are in kilograms, not tonnes. Some PROs use tonnes as the base unit (CONAI, for example). Check the unit expected by the portal you are submitting to. A factor-of-1,000 error in your declaration is embarrassing and will require a correction.
Getting Compliant
The steps to get Portuguese packaging EPR in order:
- Calculate your annual Portuguese packaging volume from your order data and packaging BOMs
- Register in SIRAPA (pontoverde.pt links to SIRAPA, or go directly to sirapa.apambiente.pt)
- Apply for SPV membership once you have your SIRAPA number
- Submit your annual declaration by March 31 each year
- Pay the SPV invoice within 30 days
If you are managing multiple EU country registrations simultaneously, Portugal and Spain share similar registration logic and the same annual deadline, which makes them practical to tackle together. From there, working through Italy (CONAI), Belgium (Fost Plus), and Austria (ARA) covers the main Southern and Central European markets. The multi-country EPR strategy guide covers how to run these registrations in parallel rather than sequentially.
Tools like Pack Declare can automate the calculation of country-level packaging declarations from your order data, reducing the annual reporting work for each market to a review and submission step.