Waste — obligations and registrations (Portugal)
A list of checks and obligations with their cadence, ready to add to your agenda.
Kit for businesses and sites in Portugal that produce, transport or manage non-urban waste under the RGGR (Decreto-Lei n.º 102-D/2020). It covers SIRER/SILiAmb registration, the annual MIRR return, e-GAR waybills, on-site storage limits, hazardous-waste duties, the permit for waste management operations and packaging producer registration. It does not cover the TGR levy, sector-specific streams (construction waste on site, end-of-life vehicles, WEEE as an operator) or ADR transport rules.
Questions about this product?
Ask what is in the manuals, how often the maintenance is due and what it takes to do it.
What it already has at hand
- No manual on this page
- 8 planned checks, the most frequent every year by 31 March
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
Submit the annual MIRR waste return by 31 March
Fill in and submit the Mapa Integrado de Registo de Resíduos in SILiAmb for each site, covering the previous calendar year; the evidence is the submission receipt per site. The forms may be pre-filled from e-GAR data but must be checked and corrected before filing. The RGGR does not set 31 March: art. 101.º n.º 2 refers the deadline to a portaria, and the date is the one of the MIRR campaign published each year by APA, so it must be reconfirmed. Applies to the same parties that must register in SIRER, with one submission per site rather than per company.
every year by 31 MarchLegal obligationDecreto-Lei n.º 102-D/2020, Anexo I (RGGR), arts. 98.º e 99.º; art. 101.º n.º 2Portugal onlySourceverified on 11/09/2026 - 02
Do not exceed the on-site waste storage limit
Waste produced may be stored at the place of production, under the applicable technical standards, for no longer than three years; beyond that it must be sent on for treatment, and exceeding the limit is an administrative offence. Keep the temporary storage in and out log and the dates of the outbound e-GARs as evidence. Applies to waste producers not covered by art. 9.º n.º 2 of the RGGR; where the activity is subject to a licensing regime approving different storage conditions, those conditions prevail.
every 36 months from installationLegal obligationDecreto-Lei n.º 102-D/2020, Anexo I (RGGR), art. 29.º n.º 2 al. a)Portugal onlySourceverified on 11/09/2026 - 03
Check the permit for waste management operations
Anyone carrying out waste management operations — collection, professional transport, storage, treatment, recovery — must hold the relevant permit, today normally issued as a Título Único Ambiental under the single environmental licensing regime, and keep it valid and up to date. The real conditions and deadlines (renewal, monitoring, reports) are written in each site's TUA, so the annual check is there to re-read them; the evidence is the permit in force. Applies to waste management operators and to sites that store or treat waste produced by third parties, whereas simply storing one's own waste at the place of production is not in itself subject to a licence.
continuous check, confirm every 12 monthsLegal obligationDecreto-Lei n.º 102-D/2020, Anexo I (RGGR); Decreto-Lei n.º 75/2015 (LUA/TUA)Portugal onlySourceverified on 11/09/2026 - 04
Issue an e-GAR for every waste shipment
Every waste shipment within Portugal must be accompanied by an electronic waste tracking waybill (e-GAR) issued in SILiAmb. Issuing it is the producer's or holder's responsibility, who may allow the carrier or the recipient to fill it in on their behalf; if SILiAmb is unavailable the alternative form is used and the waybills must be uploaded within 30 days of the platform being restored. The evidence is the e-GAR record in SILiAmb. Applies to any producer or holder sending waste for transport by road, rail, sea, inland waterway or air within Portugal, save for the specific exemptions of Portaria n.º 145/2017.
continuous checkLegal obligationDecreto-Lei n.º 102-D/2020, Anexo I (RGGR), art. 38.º n.º 2; Portaria n.º 145/2017, alterada pela Portaria n.º 28/2019Portugal onlySourceverified on 11/09/2026 - 05
Do not mix hazardous waste and label it correctly
Every producer or holder of hazardous waste must package and condition it and apply the labelling required by the international and European rules in force, and must not mix it — dilution included — with hazardous waste of other categories, with non-hazardous waste or with substances, materials and products that are not waste, except for authorised operations carried out by a licensed operator. Evidence: container labelling, the internal procedure and the e-GAR chain; the six-monthly check is a suggested cadence, not a statutory deadline. Applies to sites that produce or hold waste classified as hazardous under the European waste list.
continuous check, confirm every 6 monthsLegal obligationDecreto-Lei n.º 102-D/2020, Anexo I (RGGR), art. 57.º n.os 7 e 8Portugal onlySourceverified on 11/09/2026 - 06
Register the company and its sites in SIRER (SILiAmb)
Register the organisation, by NIF/NIPC, in the Integrated Electronic Waste Registry through SILiAmb and enrol every site subject to data reporting. Registration is due within one month of the event that makes it mandatory and must be revisited whenever headcount, activity code, sites or waste types change; the evidence is an active SILiAmb account listing the registered sites. Applies to organisations with more than 10 employees producing waste outside the municipal systems, to producers of hazardous waste or waste containing persistent organic pollutants regardless of headcount, to treatment operators even where exempt from licensing, to professional carriers, dealers and brokers of hazardous waste, to producers of products and packers, and in any case to everyone involved in an e-GAR.
continuous check, confirm every 12 monthsLegal obligationDecreto-Lei n.º 102-D/2020, Anexo I (RGGR), arts. 97.º e 98.º; art. 101.º n.º 1 (prazo de inscrição)Portugal onlySourceverified on 11/09/2026 - 07
Ensure e-GARs are closed within 30 days
After issuing the e-GAR, the producer or holder must check on the platform any change to the data made by the recipient on receipt, accepting or rejecting it within 10 days, and ensure the e-GAR is completed within a maximum of 30 days from receipt of the waste. If the deadlines pass, APA notifies the producer, who has 15 days to put things right before the case is referred to the enforcement authorities; the evidence is the e-GAR in completed status. A monthly check is the suggested operating cadence. Applies to every producer that issues e-GARs.
continuous check, confirm every 1 monthsLegal obligationPortaria n.º 145/2017, art. 9.º n.º 2 al. a) e b), alterada pela Portaria n.º 28/2019Portugal onlySourceverified on 11/09/2026 - 08
Register as producer or packer and file the declaration by 31 March
Producers, packers and service-packaging suppliers must register with APA in the product producer registry and report each year by 31 March the type and quantity of products, or the material and quantity of packaging, placed on the national market, together with the chosen management system. The declaration includes corrections for the previous year and estimates for the current one; the evidence is the submitted declaration together with membership of a compliance scheme or an individual system. Applies to anyone placing on the Portuguese market packaging, electrical and electronic equipment, lubricating oils, batteries and accumulators, tyres and vehicles, since 6 January 2023 also filtered tobacco products and since 1 January 2025 plastic cups and fishing gear.
every year by 31 MarchLegal obligationDecreto-Lei n.º 152-D/2017, art. 19.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.
Something not right on this page?
Help us keep it accurate: every report is read by a person.