# /news-insights/portugal-epr-sociedade-ponto-verde-weee-pt-spv-compliance-2026  —  Portugal EPR (Sociedade Ponto Verde) and WEEE PT in 2026: A practical compliance guide
# https://o1.eu/news-insights/portugal-epr-sociedade-ponto-verde-weee-pt-spv-compliance-2026
# Operator One — Merchant of Record for European marketplaces.

## Metadata
- Canonical URL: https://o1.eu/news-insights/portugal-epr-sociedade-ponto-verde-weee-pt-spv-compliance-2026
- Published: 2026-06-14
- Updated: 2026-09-13
- Publisher: Operator One (https://o1.eu)

## Summary
Portugal EPR in 2026: SILiAmb registration, SIGRE and SIGREEE schemes, the 31 March declaration, Volta deposits and PPWR duties from 12 August 2026.

## Full article
By Operator One Editorial — 2026-06-14

## Key takeaways

- Portugal runs packaging, WEEE and battery EPR under UNILEX (Decreto-Lei 152-D/2017), and every producer must register in the Registo de Produtores/Embaladores module of SILiAmb, the platform of the Agência Portuguesa do Ambiente (APA).
- Portuguese producers must submit annual SILiAmb declarations of quantities placed on the market by 31 March, and failing to register or declare is a serious environmental offence carrying EUR 12,000 to EUR 216,000 for a company under Lei 50/2006.
- Sociedade Ponto Verde is one choice, not the only one: APA also licenses Novo Verde and Electrão for packaging (SIGRE), Electrão and ERP Portugal for WEEE (SIGREEE, 2025 to 2034), and four schemes for batteries.
- A company established outside Portugal that sells at distance directly to end users in Portugal must appoint an authorised representative established in Portugal with a Portuguese tax number (NIF), according to APA.
- Regulation (EU) 2025/40 (PPWR) has applied since 12 August 2026: Article 45(3) requires distance sellers to appoint a packaging EPR authorised representative per member state, and Article 45(4) makes online platforms collect registration details first.
- Portugal's deposit return scheme, Volta, has operated since 10 April 2026 with a EUR 0.10 deposit on single-use plastic and metal beverage containers of up to 3 litres, alongside and not instead of packaging EPR.

Portugal is one of the smaller EU markets by GMV, but its compliance picture is layered. A seller shipping a carton of headphones to a consumer in Lisbon can trigger Portuguese packaging EPR, WEEE EPR and battery EPR plus the EU General Product Safety Regulation, all separately from the VAT question. Two changes raise the stakes in 2026: Portugal's Volta deposit return scheme has operated since 10 April 2026, and Regulation (EU) 2025/40 (PPWR) has applied across the EU since 12 August 2026.

This piece covers who the Portuguese producer is, how Sociedade Ponto Verde (SPV) and the other licensed schemes fit into SILiAmb, how WEEE and batteries sit alongside packaging, what changes for sellers on Worten or shipping from Amazon.es, where GPSR sits, and why sellers established outside Portugal need an authorised representative or a seller that is itself the Portuguese producer.

## The shape of Portuguese EPR in 2026

Portugal regulates extended producer responsibility through UNILEX, the unified regime for specific waste streams set out in Decreto-Lei 152-D/2017 of 11 December 2017 and amended several times since, including by Decreto-Lei 24/2024, which added rules for the deposit return system. Producers transfer their end-of-life obligations to management entities (entidades gestoras) licensed and supervised by the Agência Portuguesa do Ambiente (APA), or run an authorised individual system. The licensed entities relevant to an e-commerce seller are:

- Packaging (SIGRE): APA lists Sociedade Ponto Verde, licensed since 1997, plus Novo Verde and Electrão as integrated packaging schemes. APA also lists Valormed (medicinal product packaging, SIGREM), Sigeru (plant-protection product packaging, VALORFITO) and SDR Portugal (beverage deposit return) as management entities for specific packaging systems.
- Electrical and electronic equipment (SIGREEE): APA granted licences for 2025 to 2034 to Electrão and ERP Portugal.
- Batteries (SIGRB): APA licensed EGMAIS, Electrão, ERP Portugal and Valorcar from 1 January 2025 to 31 December 2034. Only Electrão and ERP Portugal are licensed for portable batteries; EGMAIS and Valorcar cover SLI, industrial, electric vehicle and LMT batteries, and Electrão and ERP Portugal also cover industrial, electric vehicle and LMT batteries.
- Beverage deposit return (SDR): SDR Portugal runs the Volta deposit and refund system.

The regulator-facing side runs through SILiAmb, APA's integrated environmental licensing platform. Under Article 19 of Decreto-Lei 152-D/2017, every producer, embalador and supplier of service packaging must register in SILiAmb's Registo de Produtores/Embaladores module, record the products and packaging materials it places on the Portuguese market with the scheme chosen for each, and submit annual declarations by 31 March. APA's SILiAmb guidance states that declarations sent to a scheme and declarations in SILiAmb are distinct obligations. The separate MIRR (Mapa Integrado de Registo de Resíduos), also due by 31 March, is the waste-register return under Decreto-Lei 102-D/2020 for waste producers, carriers, brokers and treatment operators, not the product declaration.

## SPV packaging EPR: what it covers and who has to register

Packaging is the obligation most sellers meet first, because every parcel has packaging. Under Portugal's UNILEX regime, the obligation sits with the embalador or producer that first makes packaged goods available on the Portuguese market. APA's SILiAmb guidance confirms this includes a company established in another country that sells at distance directly to end users in Portugal, and that such a company must appoint an authorised representative in Portugal. For goods from outside the EU, APA places the obligation on the Portuguese distributor where it makes the goods available, or on the foreign supplier, through an authorised representative, where it sells to the end user.

Joining Sociedade Ponto Verde is one way to meet the packaging obligation, not a legal requirement in itself: Novo Verde and Electrão hold the same SIGRE licence type. Whichever scheme a producer joins, the producer still registers in SILiAmb, frames its packaging materials there and files the SILiAmb annual declaration by 31 March.

Two points bite sellers in practice. First, scope: according to APA, since 1 January 2025 the Portuguese EPR regime also covers primary, secondary and tertiary packaging whose use results in non-urban waste, not only household packaging. Second, data: declarations are made by packaging material, so tonnage has to be broken down per material. In Operator One's experience, a packaging master per SKU is the cleanest source of that data, because most ERPs do not hold it natively.

From 12 August 2026, Regulation (EU) 2025/40 (PPWR) adds an EU-wide layer. Article 44(2) requires producers to register in each member state where they first make packaging available. Article 45(3) requires a producer selling at distance to end users in another member state to appoint, by written mandate, an authorised representative for EPR in each such member state. Article 45(4) requires online platforms in scope of Section 4 of Chapter III of the Digital Services Act to obtain a producer's registration details before allowing it to use their services. PPWR Article 44(1) gives member states 18 months from the first implementing act to set up the PPWR national register; Portugal's existing producer register under UNILEX is SILiAmb.

## Volta: Portugal's deposit return scheme since 10 April 2026

Portugal's deposit and refund system (Sistema de Depósito e Reembolso), branded Volta and managed by SDR Portugal, began on 10 April 2026 according to the Portuguese Government. In a first phase, the system covers single-use plastic and metal beverage containers of up to 3 litres carrying the Volta symbol: consumers pay a EUR 0.10 deposit and recover it on return at a collection point. The Government described a transition period from April to August 2026 for producers, distributors and consumers to adapt. A seller of bottled or canned drinks into Portugal therefore has a deposit obligation on top of its SIGRE packaging EPR and SILiAmb registration, not instead of them.

## WEEE and batteries: separate streams, not an upgrade

If a catalogue contains electrical or electronic equipment, Portuguese EPR requires EEE to be covered by a contract with a licensed SIGREEE scheme (Electrão or ERP Portugal) and framed and declared in SILiAmb as its own stream. APA's SILiAmb guidance explains that registration is made per organisation, identified by its NIF, so a producer does not open a second account for WEEE, but each stream carries its own product framing, scheme and annual declaration lines. Batteries, whether supplied loose, as spares or incorporated in equipment, are covered by a SIGRB scheme.

Equipment must be classified into the six categories in Annex III of WEEE Directive 2012/19/EU, which have applied to all EEE since 15 August 2018: temperature exchange equipment, screens and monitors, lamps, large equipment, small equipment, and small IT and telecommunication equipment. Declaring in the wrong category distorts the fees a producer pays. Article 17 of the WEEE Directive requires a producer selling EEE at distance into another member state to appoint an authorised representative there, which in Portugal means a representative established in Portugal with a Portuguese NIF.

For batteries, Chapter VIII of Regulation (EU) 2023/1542, which contains the producer register and extended producer responsibility rules, has applied since 18 August 2025. A consumer electronics seller shipping mains-powered and battery-powered goods to Portugal therefore carries three parallel streams: packaging under SIGRE, EEE under SIGREEE and batteries under SIGRB. Electrão holds licences in all three streams and ERP Portugal in the WEEE and battery streams, so one scheme relationship can cover more than one stream.

## Worten: how a Portuguese marketplace asks for EPR

Worten, the Portuguese consumer electronics retailer, runs one of the larger domestic marketplaces in Portugal and is where many EEE sellers first meet Portuguese EPR. In Operator One's experience of marketplace onboarding, Worten expects a clear answer on who the seller and Portuguese producer is, producer registration details for packaging and for any EEE listed, and Portuguese-language product information, and it can hold listings where those details are missing or do not match the product category. These are marketplace practices rather than law. The legal duty is now explicit: since 12 August 2026, PPWR Article 45(4) requires online platforms in scope of the Digital Services Act to obtain packaging EPR registration details before allowing producers to sell.

## Amazon.es cross-border into Portugal

The other common route into Portugal is Amazon.es with cross-border shipping, or Amazon fulfilment programmes that serve Portuguese customers from fulfilment centres in Spain or other member states. Two legal points matter.

First, Portugal is a separate EPR jurisdiction from Spain. A Spanish packaging or WEEE registration gives no coverage in Portugal. Where the seller makes goods available to end users in Portugal, it needs its own SILiAmb registration and Portuguese schemes, even if the parcel leaves a Spanish warehouse. PPWR Article 44(2) now states the same principle for packaging EU-wide.

Second, the legal seller determines who the Portuguese producer is. Under APA's reading of UNILEX, a seller established abroad that sells at distance directly to end users in Portugal is the producer. If the brand sells on its own account, the brand is the Portuguese producer. If a Merchant of Record is the legal seller, the registrations sit with the MoR's entity for those sales. In Operator One's experience, the most common mismatch is selling on the brand's account while relying on another entity's registrations, which do not cover the brand's sales because EPR registration does not transfer between legal entities.

## GPSR runs in parallel, not instead

The EU General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024. It is a product safety regime rather than an EPR regime, but it uses the same kind of operator identification:

- Under GPSR Article 16, a product within its scope may be placed on the EU market, Portugal included, only if an economic operator established in the Union is responsible for the tasks that article lists. For harmonised products such as radio equipment, the equivalent hook is Article 4 of Regulation (EU) 2019/1020 together with the sector directive.
- The technical documentation and conformity assessment remain the manufacturer's responsibility; an importer or responsible economic operator verifies they exist and makes them available to market surveillance authorities on request.
- Under GPSR Article 19, online listings must show the manufacturer's name and postal and electronic address, the name and address of the responsible economic operator where the manufacturer is not established in the Union, product identification, and any warnings or safety information in a language the consumer understands.

GPSR does not replace EPR. A seller can meet GPSR and still be non-compliant in Portugal for a missing SILiAmb registration or scheme contract, and the reverse. Both need to be in place before a listing goes live. See the compliance glossary (https://o1.eu/compliance-glossary) for definitions.

## Sellers established outside Portugal: the authorised representative is the gating step

APA's SILiAmb guidance defines the authorised representative as a natural or legal person established in Portugal, with a Portuguese NIF, appointed by written mandate to meet the obligations of a producer established in another EU member state or a third country. That means the constraint is not only for non-EU sellers: a brand established in Germany or the Netherlands that sells directly to Portuguese consumers also needs a Portuguese authorised representative. There are two workable routes:

- Authorised representative: the brand remains the legal seller and producer, and a Portuguese representative registers and reports in SILiAmb on its behalf under a written mandate.
- A seller that is itself the Portuguese producer: a Merchant of Record or distributor becomes the legal seller for Portuguese sales and holds the SILiAmb registration and scheme contracts in its own name for those sales. VAT is a separate question whose answer depends on the goods flow, and GPSR and market surveillance duties follow whoever places the product on the EU market. More on that model at Merchant of Record (https://o1.eu/merchant-of-record).

Non-EU sellers shipping small parcels straight to Portuguese consumers face an additional 2026 change: from 1 July 2026, the EU applies a temporary EUR 3 customs duty per item on low-value consignments of up to EUR 150 under Council Regulation (EU) 2026/382, replacing the previous customs duty exemption for such consignments; according to the European Commission, the flat duty applies until 1 July 2028. In Operator One's view, the clearest sign that a Portuguese setup is coherent is that the legal seller, the SILiAmb registrant, the scheme contracts and the GPSR operator details all resolve to entities with a documented role, rather than fragmenting across a brand, a freight forwarder and an unrelated representative.

## How to register for Portuguese EPR, step by step

- Confirm who the Portuguese producer is. Identify the legal entity that makes the goods available on the Portuguese market: the Portuguese distributor, or the foreign seller where it sells at distance directly to end users in Portugal (APA SILiAmb guidance).
- Appoint an authorised representative if needed. If that producer is established outside Portugal and sells directly to end users in Portugal, appoint by written mandate an authorised representative established in Portugal with a Portuguese NIF.
- Register in SILiAmb. Create SILiAmb access for the organisation and register in the Registo de Produtores/Embaladores module under Article 19 of Decreto-Lei 152-D/2017.
- Contract a licensed scheme per stream. Join a SIGRE packaging scheme (Sociedade Ponto Verde, Novo Verde or Electrão), a SIGREEE scheme for EEE (Electrão or ERP Portugal) and a SIGRB scheme for batteries (EGMAIS, Electrão, ERP Portugal or Valorcar), or obtain an individual system.
- Frame your products in SILiAmb. Record each product or packaging material and the chosen scheme in the SILiAmb enquadramento, and update it within 30 days whenever the products placed on the market change.
- Declare quantities every year. Submit declarations to your schemes on their own terms and submit the SILiAmb annual declarations of quantities placed on the Portuguese market by 31 March.
- Check deposit and product safety rules before listing. Confirm whether beverage containers fall under the Volta deposit scheme, and make sure listings show the GPSR Article 19 information before the first order ships.

## Frequently asked questions

### Do I need to register with Sociedade Ponto Verde to sell into Portugal?

Not necessarily with Sociedade Ponto Verde itself. Portuguese law (UNILEX, Decreto-Lei 152-D/2017) requires the producer or embalador to register in SILiAmb and to transfer its packaging obligations to a licensed scheme or run an individual system. APA lists Sociedade Ponto Verde, Novo Verde and Electrão as SIGRE packaging schemes, so joining SPV is a commercial choice rather than the only legal route.

### What is the annual declaration deadline for Portuguese EPR?

Under Article 19 of Portugal's UNILEX regime, producers and embaladores must submit their annual declarations of products and packaging placed on the Portuguese market in SILiAmb by 31 March. APA states these SILiAmb declarations are a separate obligation from the declarations sent to Sociedade Ponto Verde or any other scheme. Changes to the products a producer places on the market must be updated in SILiAmb within 30 days.

### What happens if I sell into Portugal without an EPR registration?

APA's SILiAmb guidance classifies both failing to register and failing to submit declarations as serious environmental offences under Portugal's general waste regime (Decreto-Lei 102-D/2020, Article 117). Under Article 22 of Lei 50/2006, as amended by Lei 114/2015, a serious offence by a company carries a fine of EUR 12,000 to EUR 72,000 for negligence and EUR 36,000 to EUR 216,000 for intent. Enforcement sits with the inspection bodies, not APA.

### Who is the producer for Portuguese EPR when a Merchant of Record is the seller?

Under Portugal's UNILEX definitions, the producer is the entity that makes the product available on the Portuguese market, including a company abroad selling at distance to end users in Portugal. Where a Merchant of Record is the legal seller, the Portuguese registration and scheme contracts sit with that seller's entity for those sales. If the brand sells on its own account, the brand is the producer, and EPR registrations never transfer between legal entities.

### Is my Spanish EPR registration enough to ship to customers in Portugal?

No. EPR registration is national, so a Spanish packaging or WEEE registration creates no rights or coverage in Portugal. A seller making products available to end users in Portugal needs its own SILiAmb registration, a Portuguese SIGRE packaging scheme and, for electricals and batteries, SIGREEE and SIGRB schemes. From 12 August 2026, PPWR Article 44 also confirms that packaging producers register in each member state where they make packaging available.

### Do electronics need a separate WEEE registration in Portugal?

Electronics need separate treatment, though not a separate account. In Portugal's SILiAmb, registration is per organisation (NIF), but EEE must be framed and declared as its own stream and covered by a contract with a licensed SIGREEE scheme, which APA lists as Electrão and ERP Portugal for 2025 to 2034. Equipment is classified into the six categories of Annex III of WEEE Directive 2012/19/EU, applicable since 15 August 2018.

### Does the PPWR change Portuguese packaging EPR from August 2026?

Yes. Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, applies from 12 August 2026 in Portugal and every other member state. Article 44 requires registration in each member state of first making available, Article 45(3) requires distance sellers to appoint an authorised representative for EPR in each such member state, and Article 45(4) requires in-scope online platforms to obtain producers' registration details before letting them sell.

### Does Portugal have a deposit return scheme for drinks packaging?

Yes. Portugal's deposit and refund system, branded Volta and run by SDR Portugal, started on 10 April 2026 according to the Portuguese Government. In a first phase, consumers pay a EUR 0.10 deposit on single-use plastic and metal beverage containers of up to 3 litres carrying the Volta symbol and recover it when returning the container. A transition period ran from April to August 2026. Volta sits alongside, not instead of, packaging EPR in SILiAmb.

### Can a non-EU company register for EPR in Portugal directly?

Not on its own. APA's SILiAmb guidance says a supplier established in another EU country or a third country that sells directly to end users in Portugal meets its obligations through an authorised representative, a person established in Portugal with a Portuguese NIF appointed by written mandate. The alternative is for a Merchant of Record or other seller that is itself the Portuguese producer to hold the registrations for the sales it makes.

## Where a Merchant of Record carries the obligation

When a Merchant of Record (https://o1.eu/merchant-of-record) such as Operator One is the legal seller of goods to customers in Portugal, the Portuguese producer obligations for those sales attach to the Merchant of Record's entity, because Portuguese EPR obligations are national, each waste stream is covered separately, and registrations do not transfer between legal entities. Where Operator One imports goods into the EU, it is the importer and therefore the responsible economic operator under Regulation (EU) 2019/1020 Article 4 and GPSR Article 16. CE marking, the conformity assessment, the technical file and the EU Declaration of Conformity stay with the manufacturer: as importer, Operator One verifies the file exists, adds its own name and postal address, keeps the Declaration of Conformity for 10 years, makes the file available to authorities and runs corrective action. Where a market requires a locally established authorised representative, Operator One commonly arranges one during onboarding, though not in every market. Listings show the client as the brand and Operator One as the seller. VAT treatment depends on the goods flow and is assessed per case. Terms are explained in the compliance glossary (https://o1.eu/compliance-glossary).

Sources: Regulation (EU) 2025/40 (PPWR), EUR-Lex (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040); Regulation (EU) 2023/1542 on batteries, EUR-Lex (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1542); WEEE Directive 2012/19/EU, EUR-Lex (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012L0019); Regulation (EU) 2023/988 (GPSR), EUR-Lex (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R0988); APA, packaging and packaging waste (https://apambiente.pt/residuos/embalagens-e-residuos-de-embalagens); APA, SIGREEE management entities (https://apambiente.pt/en/node/849); APA, battery management entities (https://apambiente.pt/en/node/1358); APA, producer register (https://apambiente.pt/residuos/registo-de-produtores-de-produtos); APA, SILiAmb producer register FAQ v5.4 (https://apambiente.pt/sites/default/files/_Residuos/FluxosEspecificosResiduos/RAP/FAQRegisto.pdf); Lei 50/2006, consolidated text (https://faolex.fao.org/docs/pdf/por66244.pdf); Portuguese Government, Volta launch (https://portugal.gov.pt/gc25/comunicacao/noticias/volta-sistema-de-deposito-e-reembolso-de-embalagens-entra-em-vigor); European Commission, low-value consignment customs duty (https://taxation-customs.ec.europa.eu/news/guidance-and-legal-text-temporary-flat-fee-low-value-imports-which-will-apply-until-1-july-2028-2026-06-08_en).

## FAQ (structured)
Q: Do I need to register with Sociedade Ponto Verde to sell into Portugal?
A: Not necessarily with Sociedade Ponto Verde itself. Portuguese law (UNILEX, Decreto-Lei 152-D/2017) requires the producer or embalador to register in SILiAmb and to transfer its packaging obligations to a licensed scheme or run an individual system. APA lists Sociedade Ponto Verde, Novo Verde and Electrão as SIGRE packaging schemes, so joining SPV is a commercial choice rather than the only legal route.

Q: What is the annual declaration deadline for Portuguese EPR?
A: Under Article 19 of Portugal's UNILEX regime, producers and embaladores must submit their annual declarations of products and packaging placed on the Portuguese market in SILiAmb by 31 March. APA states these SILiAmb declarations are a separate obligation from the declarations sent to Sociedade Ponto Verde or any other scheme. Changes to the products a producer places on the market must be updated in SILiAmb within 30 days.

Q: What happens if I sell into Portugal without an EPR registration?
A: APA's SILiAmb guidance classifies both failing to register and failing to submit declarations as serious environmental offences under Portugal's general waste regime (Decreto-Lei 102-D/2020, Article 117). Under Article 22 of Lei 50/2006, as amended by Lei 114/2015, a serious offence by a company carries a fine of EUR 12,000 to EUR 72,000 for negligence and EUR 36,000 to EUR 216,000 for intent. Enforcement sits with the inspection bodies, not APA.

Q: Who is the producer for Portuguese EPR when a Merchant of Record is the seller?
A: Under Portugal's UNILEX definitions, the producer is the entity that makes the product available on the Portuguese market, including a company abroad selling at distance to end users in Portugal. Where a Merchant of Record is the legal seller, the Portuguese registration and scheme contracts sit with that seller's entity for those sales. If the brand sells on its own account, the brand is the producer, and EPR registrations never transfer between legal entities.

Q: Is my Spanish EPR registration enough to ship to customers in Portugal?
A: No. EPR registration is national, so a Spanish packaging or WEEE registration creates no rights or coverage in Portugal. A seller making products available to end users in Portugal needs its own SILiAmb registration, a Portuguese SIGRE packaging scheme and, for electricals and batteries, SIGREEE and SIGRB schemes. From 12 August 2026, PPWR Article 44 also confirms that packaging producers register in each member state where they make packaging available.

Q: Do electronics need a separate WEEE registration in Portugal?
A: Electronics need separate treatment, though not a separate account. In Portugal's SILiAmb, registration is per organisation (NIF), but EEE must be framed and declared as its own stream and covered by a contract with a licensed SIGREEE scheme, which APA lists as Electrão and ERP Portugal for 2025 to 2034. Equipment is classified into the six categories of Annex III of WEEE Directive 2012/19/EU, applicable since 15 August 2018.

Q: Does the PPWR change Portuguese packaging EPR from August 2026?
A: Yes. Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, applies from 12 August 2026 in Portugal and every other member state. Article 44 requires registration in each member state of first making available, Article 45(3) requires distance sellers to appoint an authorised representative for EPR in each such member state, and Article 45(4) requires in-scope online platforms to obtain producers' registration details before letting them sell.

Q: Does Portugal have a deposit return scheme for drinks packaging?
A: Yes. Portugal's deposit and refund system, branded Volta and run by SDR Portugal, started on 10 April 2026 according to the Portuguese Government. In a first phase, consumers pay a EUR 0.10 deposit on single-use plastic and metal beverage containers of up to 3 litres carrying the Volta symbol and recover it when returning the container. A transition period ran from April to August 2026. Volta sits alongside, not instead of, packaging EPR in SILiAmb.

Q: Can a non-EU company register for EPR in Portugal directly?
A: Not on its own. APA's SILiAmb guidance says a supplier established in another EU country or a third country that sells directly to end users in Portugal meets its obligations through an authorised representative, a person established in Portugal with a Portuguese NIF appointed by written mandate. The alternative is for a Merchant of Record or other seller that is itself the Portuguese producer to hold the registrations for the sales it makes.

## Steps (structured)
1. Confirm who the Portuguese producer is: Identify the legal entity that makes the goods available on the Portuguese market: the Portuguese distributor, or the foreign seller where it sells at distance directly to end users in Portugal (APA SILiAmb guidance).
2. Appoint an authorised representative if needed: If that producer is established outside Portugal and sells directly to end users in Portugal, appoint by written mandate an authorised representative established in Portugal with a Portuguese NIF.
3. Register in SILiAmb: Create SILiAmb access for the organisation and register in the Registo de Produtores/Embaladores module under Article 19 of Decreto-Lei 152-D/2017.
4. Contract a licensed scheme per stream: Join a SIGRE packaging scheme (Sociedade Ponto Verde, Novo Verde or Electrão), a SIGREEE scheme for EEE (Electrão or ERP Portugal) and a SIGRB scheme for batteries (EGMAIS, Electrão, ERP Portugal or Valorcar), or obtain an individual system.
5. Frame your products in SILiAmb: Record each product or packaging material and the chosen scheme in the SILiAmb enquadramento, and update it within 30 days whenever the products placed on the market change.
6. Declare quantities every year: Submit declarations to your schemes on their own terms and submit the SILiAmb annual declarations of quantities placed on the Portuguese market by 31 March.
7. Check deposit and product safety rules before listing: Confirm whether beverage containers fall under the Volta deposit scheme, and make sure listings show the GPSR Article 19 information before the first order ships.