With effect from July 1st, 2021, the Portuguese environmental authority APA announced the early implementation of the official registration of an authorized representative for waste streams other than Electrical and Electronic devices. The product categories that benefit from this go beyond Batteries and Accumulators as well as Packaging. From January 1st, 2022, registration for such products is mandatory in this way.
However, the bill for this has existed since 2017, whereby take-e-way and its Portuguese partners have been implementing the associated requirements and their practice for more than two years, so that our customers have already fulfilled their obligations ahead of time.
Because the question that has existed since then - “Am I obliged to register as a manufacturer?” - is answered in accordance with Art. 19.1 Decreto-Lei n.° 152-D / 2017 with a general registration obligation. This is especially true for non-Portuguese manufacturers who sell directly to end users. Otherwise, the Portuguese importer is required to register and report the sales. This obligation can only be accepted voluntarily by companies from EU member states. According to Art. 20.2 Decreto-Lei n.° 152-D / 2017, foreign manufacturers are obliged to appoint an authorized representative based in Portugal.
If you want to sell products to Portugal and need advice Mario Schultz and Rafael Loaiza are at your disposal via international@take-e-way.de or +49/40/750687-149 or +49/40/750687-115.
For more information on our international compliance services in connection with the placing on the market of electronic devices, batteries and packaged products or packaging, please click here: https://www.take-e-way.com/services/international-compliance/
