The principle of extended producer responsibility (EPR) in Portugal holds the electrical and electronic equipment (EEE) producer responsible for the management of the waste when the products reach the end of life. The producer can assume this, or transfer the responsibility to an integrated system that manages collective WEEE, through a contract between the producer and the WEEE management company and by paying the corresponding fees.
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Joining a waste management system
In Portugal, the following licensed entities manage the collective WEEE management systems:
- Electrão, waste management association;
- ERP Portugal, waste management association; and
- WEEECYCLE.
In addition to ensuring there is a collective/individual WEEE management system, EEE producers are subject to registration obligations, to allow monitoring and inspection of their responsibilities.
According to the Dispatch on Bank Guarantees, EEE producers that choose to establish their own take-back programmes, create a bank account and deposit it with sufficient funds which might be withdrawn by ANREEE – National Association for the Register of Electrical and Electronic Equipment - for the purpose of funding the take back programme on behalf of the company should the company be unable to fulfil its obligations.
Registration
Failure to comply with the obligation to register or to join a collective/individual WEEE management system implies an entity is prohibited from placing EEE on the national market.
Registration must be carried out using the SILiAmb platform, from APA (the Portuguese environment agency). It involves two steps:
- step 1: framework – identification of the type of products placed on the market by the company; and
- step 2: submission of periodic declarations (reports) – on quantities of products placed on the market annually.
Information to be submitted at the start of the registration process (step 1):
- name, address and contact details of the producer (or authorised representative), as well as the contact person. In the case of an authorised representative, contact details of the represented producer must also be included;
- national identification code, including the European or national tax identification number;
- category of EEE;
- Type of EEE (intended for private users or non-private users);
- EEE trade name (brand);
- waste management system: individual or collective, including information on financial guarantee when applicable;
- sales technique used (for example, distance selling); and
- declaration that the information provided is true.
Information to be presented in the annual reports (step 2):
- national producer identification code;
- time period covered by the report;
- category of EEE;
- quantity, in units and weight, of EEE placed on the national market, by category;
- quantity, by weight, of waste EEE collected selectively, recycled (including prepared for reuse), recovered and disposed of in Portugal, as well as transferred into or outside the EU , by category.
After registration is complete and accepted by the agency, a registration number is issued to the company. This number must be used on invoices, transport documents and other such documentation issued by the EEE producer.
Annual reporting
Producers (or authorised representatives (AR), when applicable) must submit, by 31 March each year, two declarations regarding the EEE they placed on the Portuguese market:
- a correction declaration for year x-1, to report the quantities placed on the market in year x-1 (not applicable to producers/ARs registering for the first time in year x); and
- an estimate declaration for year x, to report the quantities it expects to place on the market in year x.
Thus, in 2020, producers/ARs had to submit the following declarations by 31 March:
- ‘declaration producer/AR correction 2019’, for producers/ARs that placed products on the market in 2019;
- ‘declaration producer/AR estimate 2020’, for producers/ARs that place products on the market in 2020.