Emissions and environmental permits (Portugal)
A list of checks and obligations with their cadence, ready to add to your agenda.
Kit for industrial sites in Portugal with air emission points, water discharges or equipment containing fluorinated gases. It covers air-emission self-monitoring and reporting (Decreto-Lei n.º 39/2018), the Título Único Ambiental issued under the single environmental licensing regime, PRTR reporting, F-gas duties and wastewater discharge self-monitoring. It does not cover the EU emissions trading system, noise, VOC solvent management plans or sector-specific emission limit values.
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- 10 planned checks, the most frequent every 6 months since the last inspection
Planned checks
Informative summary verified on 11/09/2026. It does not replace legal advice: the regulation cited prevails. If you spot an error, report it.
Some checks are only mandatory in certain countries: pick yours and the list follows.
In Italy this product has no planned checks: the ones listed apply to other countries.
In France this product has no planned checks: the ones listed apply to other countries.
In Germany this product has no planned checks: the ones listed apply to other countries.
In Switzerland this product has no planned checks: the ones listed apply to other countries.
In Austria this product has no planned checks: the ones listed apply to other countries.
In United Kingdom this product has no planned checks: the ones listed apply to other countries.
In Spain this product has no planned checks: the ones listed apply to other countries.
- 01
Check equipment containing F-gases for leaks
The operator of stationary equipment containing fluorinated gases in quantities of 5 tonnes of CO2 equivalent or more must have certified personnel carry out periodic leak checks and keep the report signed by the technician. Above 500 tonnes of CO2 equivalent a leak detection system is mandatory, and its operation must be verified at least every 12 months, or at least every 6 years for electrical switchgear. The interval varies with the charge: every 12 months from 5 to under 50 tonnes of CO2 equivalent (24 months with a detection system), every 6 months from 50 to under 500 (12 with detection) and every 3 months from 500 upwards (6 with detection), while hermetically sealed equipment below the threshold is excluded.
every 12 months since the last inspectionLegal obligationRegulation (EU) 2024/573, Article 5Portugal onlySourceverified on 11/09/2026 - 02
Comply with and renew the TUA conditions
The site must keep in force the Título Único Ambiental issued under the single environmental licensing regime, which gathers every applicable environmental permit — impact assessment, integrated pollution prevention and control, waste, water resources, emissions, emission allowances — and comply with its conditions, monitoring and deadlines. The TUA is a container and the decree sets no general cadence: the annual check is there to re-read the permit and put its deadlines back in the calendar; the evidence is the TUA in force together with the records proving compliance. Applies to sites subject to one or more of the environmental regimes integrated into the LUA.
continuous check, confirm every 12 monthsLegal obligationDecreto-Lei n.º 75/2015 (Regime de Licenciamento Único de Ambiente)Portugal onlySourceverified on 11/09/2026 - 03
Keep continuous emission monitoring in operation
Where a pollutant's mass flow exceeds the maximum threshold of Annex II, monitoring must be continuous: keep the measuring system calibrated and running and notify the competent regional authority (CCDR) of any malfunction within 48 hours. The annual check shown here is the suggested compliance check on calibration and operation, while the measuring obligation itself is permanent; evidence: system records, calibration certificates and malfunction notifications. Applies to sources whose mass flow exceeds the maximum threshold of Annex II, part 1, of Decreto-Lei n.º 39/2018.
continuous check, confirm every 12 monthsLegal obligationDecreto-Lei n.º 39/2018, art. 14.º n.º 2 e art. 8.º al. d)Portugal onlySourceverified on 11/09/2026 - 04
Carry out spot emission monitoring every 3 years
Where the pollutant mass flow stays below the average threshold but at or above the minimum threshold and the plant's operating conditions do not change, spot monitoring may be performed once every three years. Keep the test report together with a statement confirming that operating conditions are unchanged. Applies to sources with a mass flow below the average threshold and at or above the minimum threshold; if the mass flow stays below the minimum threshold the interval drops to once every five years, while medium combustion plants follow the specific frequencies of Decreto-Lei n.º 39/2018.
every 36 months since the last inspectionLegal obligationDecreto-Lei n.º 39/2018, art. 15.ºPortugal onlySourceverified on 11/09/2026 - 05
File the annual PRTR report
Operators of PRTR facilities report each year, through a SILiAmb form, the previous year's pollutant releases and off-site waste transfers, even where the European regulation's reporting thresholds are not exceeded; the evidence is the submitted form. The window is not a statutory deadline but a campaign announced each year by APA, so the date must be reconfirmed; Regulation (EU) 2024/1244 will replace Regulamento (CE) n.º 166/2006, becoming mandatory from 1 January 2028. Applies to facilities carrying out one of the activities of Annex I to Regulamento (CE) n.º 166/2006 above the capacity thresholds set out there.
every year by 1 JuneLegal obligationRegulamento (CE) n.º 166/2006; Decreto-Lei n.º 127/2008, alterado pelo Decreto-Lei n.º 6/2011Portugal onlySourceverified on 11/09/2026 - 06
Run wastewater discharge self-monitoring
The holder of a water resources use title for wastewater discharge must implement the self-monitoring programme set out in the title and send the results to the licensing authority in the format and at the frequency stated in the licence. The frequency is not set uniformly by law but case by case in the TURH, so read the title before setting the dates; evidence: analysis reports and self-monitoring submissions. Applies to sites discharging wastewater to a water body or to the ground under a TURH, bearing in mind that the title is issued for a maximum of 10 years and is renewable. Cadence to be confirmed on the cited source.
continuous check, confirm every 12 monthsLegal obligationLei n.º 58/2005 (Lei da Água); Decreto-Lei n.º 226-A/2007Portugal onlySource - 07
Keep F-gas records and report them to APA
For each item of equipment subject to leak checks, keep records for at least 5 years covering gas quantity and type, dates and results of the checks, recovery operations and the technician's identity, and report the data each year in SILiAmb. The evidence is the equipment logbook together with the form receipt; 31 March is the practice of APA's campaigns, not a deadline written in the European regulation, so it must be reconfirmed every year. Applies to operators of F-gas equipment subject to leak checks and to those required to file the annual return with APA.
every year by 31 MarchLegal obligationRegulation (EU) 2024/573, Article 7Portugal onlySourceverified on 11/09/2026 - 08
Submit the Annual Environmental Report
Holders of an IPPC environmental licence must send APA the Relatório Ambiental Anual covering the previous year's operation, emissions, consumption and monitoring, and keep the submitted report with its receipt. Decreto-Lei n.º 127/2013 sets no uniform date: the deadline is written in the conditions of each environmental licence or TUA, which must be read before setting the due date. Applies only to installations holding an IPPC environmental licence, that is those carrying out an activity of Annex I to Decreto-Lei n.º 127/2013. Cadence to be confirmed on the cited source.
continuous check, confirm every 12 monthsLegal obligationDecreto-Lei n.º 127/2013 (Regime de Emissões Industriais, PCIP); condições da licença ambiental/TUAPortugal onlySource - 09
Report monitoring results by 30 April
Report each year, by 30 April of the following year, the spot and continuous emission monitoring information in the form and content set by Portaria n.º 221/2018, and keep the submission receipt. Mind the other two deadlines in the same article: continuous monitoring results are sent monthly by the end of the following month, and spot monitoring results within 45 consecutive days of the measurement; the former go to APA, the latter to the territorially competent CCDR. Applies to all operators of installations with emission points subject to limit values under Decreto-Lei n.º 39/2018.
every year by 30 AprilLegal obligationDecreto-Lei n.º 39/2018, art. 16.º n.º 4; Portaria n.º 221/2018Portugal onlySourceverified on 11/09/2026 - 10
Carry out spot emission monitoring twice a year
Have an accredited laboratory perform spot emission monitoring twice per calendar year, with at least two months between measurements, and keep the test report of each campaign. Decreto-Lei n.º 39/2018 was amended by Decreto-Lei n.º 124/2026, which sets its own minimum frequencies for medium combustion plants: check the consolidated text if you operate such plants. Applies to sources whose mass flow is at or above the average threshold and below the maximum threshold of Annex II, part 1, of Decreto-Lei n.º 39/2018.
every 6 months since the last inspectionLegal obligationDecreto-Lei n.º 39/2018, art. 15.ºPortugal onlySourceverified on 11/09/2026
In United States this product has no planned checks: the ones listed apply to other countries.
In Other country this product has no planned checks: the ones listed apply to other countries.
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