Frequently asked questions

It is a strategy developed to integrate the environmental costs associated with goods/products throughout their life cycle into their market value and establishes that the producer/importer of packaging, electrical and electronic equipment and/or batteries and accumulators is responsible, in whole or in part, physically or financially, for the environmental impacts and the generation of waste resulting from the production process and the subsequent use of the respective equipment, as well as for its management when it reaches the end of its life.

The producer/importer must not only promote changes in the design of the product to minimise its impact when it becomes waste, but also ensure its correct treatment. The producer/importer is responsible for organising and financing the recycling of packaging, electrical and electronic equipment and/or used batteries and accumulators resulting from the products he places on the market, and it follows from this obligation that the Producer/Importer must join an integrated system or set up an individual waste management system.

The circular economy is an economic model that aims to reduce waste and promote the reuse, recycling and regeneration of materials and products. Unlike the traditional linear economy, which follows the ‘extract, produce, discard’ pattern, the circular economy seeks to keep resources in use for as long as possible, extracting the maximum value from them while they are in circulation and minimising their environmental impact. This model not only helps to conserve natural resources, but also promotes innovation, sustainability and economic resilience.

According to Decree-Law No. 67/2014, of the 7^th of May, Electrical and Electronic Equipment is ‘equipment that depends on electric current or electromagnetic fields to function, and all equipment for generating, transferring and measuring such currents and fields, and designed for use with a nominal voltage not exceeding 1,000 V for alternating current and 1,500 V for direct current’.

Decree-Law No. 152-D/2017 of the11^th of December stipulates that, as of the15^th of August 2018, all electrical equipment must be reclassified into 6 new categories (the 10 previous categories cease to exist and the 6 new categories apply).
In addition, the Decree-Law also broadens the scope of the electrical equipment register to include equipment that was not previously covered.
These changes mean that all producers must re-register the products they place on the market on the APA's (Portuguese Environment Agency) SILiAmb platform, in accordance with the new system of 6 categories of electrical equipment.

Read more about the 6 new categories of electrical equipment here.

Under the terms of Article 3, paragraph v), of Decree-Law No. 67/2014, of the 7^th of May, producers of electrical equipment are natural or legal persons, regardless of the sales technique used (including remote sales), who fall under at least one of the following categories:

- Manufacturer under own name or brand, established in Portugal: Manufactures equipment under its own name or brand and places it on the market in Portugal.

- Dealer under own name or brand, established in Portugal: Has equipment designed or manufactured and sells it on the Portuguese market under its own name or brand.

- Reseller under own name or brand, established in Portugal: Resells equipment produced by other suppliers on the Portuguese market under its own name or brand.

- Importer established in Portugal: Places equipment from a third country or another European Union country on the Portuguese market.

- Remote sale to end users: A natural or legal person, established in another European Union country or in a third country, who sells equipment, via remote communication techniques, directly to end users, individuals or non-individuals, in Portugal.

- Manufacturer/dealer not established in Portugal: A foreign company established in the European Union that places electrical equipment in Portugal in companies that act as importers on the national market and that wishes to bear all the obligations of a Producer in Portugal.

According to article 17 of Decree-Law No. 67/2014 of the 7th of May, electrical equipment distributors are required to guarantee the reception of waste electrical equipment free of charge and for end users, on a one-to-one basis, as part of the supply of new electrical equipment, as long as the waste is from equivalent equipment.
Retail stores with a surface area of more than 400 square metres are also required to guarantee the free take-back of small electrical equipment waste for end users, without any obligation to purchase equivalent electrical equipment. This waste electrical equipment can be received in the store or in its immediate vicinity.
In addition to these obligations, there are also obligations as a producer of electrical equipment, if you act as such within the meaning of Article 3, paragraph v) of the aforementioned Decree-Law, as explained in the FAQ "Am I a producer of electrical equipment?".
 

1. Join the WEEE Management System

If you are a Producer of Electrical Equipment, you should transfer your responsibility for the management of waste electrical equipment to an entity that manages a collective system, such as ELECTRÃO, in accordance with Article 22, paragraph 1 of Decree-Law 67/2014 of the 7^th of May.

Alternatively, you can set up an individual waste management system, as provided for in Article 29 of the same law.

2. Register with the National Registration Entity

In addition to transferring responsibility to a Management Entity, you must also register as a Producer with the National Registration Entity, currently APA – Portuguese Environment Association, by formalising your registration with SILiAmb (siliamb.apambiente.pt), in accordance with Article 32 of Decree-Law No. 67/2014 of the 7^th of May.

3. Producer Registration Number

Once you have registered with SILiAmb (siliamb.apambiente.pt), you receive a registration number (PT followed by 6 digits) that must appear on the invoices issued and on the transport documents for the equipment for which you are considered to be the producer.

4. Product Marking

You must ensure that all the equipment for which you are the producer is marked with the symbol shown in Annex VII of Decree-Law No. 67/2014 of the 7^th of May (a rubbish bin barred with an X), which must appear on the electrical equipment of which you are considered a producer, as provided for in Article 30, Number 2, paragraph e) of the same Decree-Law.

According to Article 17 of Decree-Law No. 67/2014 of the 7^th of May, electrical equipment distributors are required to guarantee the reception of waste electrical equipment free of charge and for end users, on a one-to-one basis, as part of the supply of new electrical equipment, as long as the waste is from equivalent equipment.

Retail stores with a surface area of more than 400 square metres are also required to guarantee the free take-back of small electrical equipment waste for end users, without any obligation to purchase equivalent electrical equipment. This waste electrical equipment can be received in the store or in its immediate vicinity.

In addition to these obligations, there are also obligations as a producer of electrical equipment, if you act as such within the meaning of Article 3, paragraph v) of the aforementioned Decree-Law, as explained in the FAQ "Am I a producer of electrical equipment?".

By transferring your responsibility to ELECTRÃO, you ensure compliance with the requirements set out in Decree-Law 67/2014 on the management of waste electrical equipment. Electrão can support you in fulfilling your legal obligations under Extended Producer Responsibility.

To join the ELECTRÃO management system and transfer your responsibility for the management of waste electrical equipment, all you have to do is access the Electrão website and complete the online registration process (register HERE).

The process involves filling in a form in which you will have to: identify the producer joining the system and identify the legal categories of electrical equipment.

After completing the process, a welcome e-mail will be sent with the credentials to access the Members Portal and all the necessary information.

The Standard Membership Regime applies to our Members who meet the following market placement specifications:

• Electrical equipment: Total annual placing on the Portuguese market for the six legal categories of electrical equipment greater than or equal to 1 000 kilograms;
• Batteries and accumulators: Total annual placing on the Portuguese market of portable and industrial batteries and accumulators greater than or equal to 250 kilograms or 500 units;
• Packaging: Total annual placing on the Portuguese market for all categories of packaging materials greater than or equal to 1 000 kilograms.

The Small-Scale Regime applies to our Members who meet the following market placement specifications:

• Electrical equipment: Total annual placing on the Portuguese market for the six legal categories of electrical equipment of less than 1 000 kilograms;
• Batteries and accumulators: Total annual placing on the Portuguese market of portable and industrial batteries and accumulators of less than 250 kilograms and 500 units (simultaneously);
• Packaging: Total annual placing on the Portuguese market for all categories of packaging materials of less than 1 000 kilograms.

Eco-fees are the financial contributions, which vary according to the category, that enable the Integrated Waste Management System to operate.

In practice, they are the financial compensation charged by management organisations for taking responsibility on behalf of producers for the management of waste electrical equipment placed on the market.

These fees are determined according to the quantities placed on the national market, the characteristics and nature of the materials present in the waste, and the treatment operations it undergoes, and are borne by the producers.

The cost of joining Electrão's Waste Electrical Equipment Management System is directly related to the type and quantity of electrical equipment placed on the market, according to an eco-fee defined annually for each category. The eco-fee table can be viewed here, depending on the applicable Regime.

Taking into account the principle of Extended Producer Responsibility, a register becomes necessary, which, given the nature of the products placed on the market, identifies the companies that place them on the market and that are meeting their environmental obligations.

As well as being mandatory, it also has advantages:

• You will have your own registration number, which is mandatory on invoices and transport documents, proving that the company complies with the waste management legislation;
• Customers and distributors will know that their producer has solutions for the collection and management of waste from the products it places on the market;
• You will avoid possible fines, which can be high and, in extreme cases, could lead to the suspension of your activities.

Between the 1^st of January and the 31^st of March of each year, you must submit to the APA (at SILiAmb SILIAMB.APAMBIENTE.PT) the annual statement of electrical equipment placed on the market during the previous year and the estimate for the current year.
Standard Membership Regime: Each quarter, between the 1^st and 15^th of the month following the reporting period, you must report to Electrão the electrical equipment placed on the national market during that period.

​​​​​​Batteries and accumulators are divided into two types and, within these, into various chemical systems.

• Type 1: Portable batteries and accumulators

Any battery, button cell, cell battery or accumulator that is hermetically sealed, can be carried by hand and is not an industrial battery or accumulator, nor a battery or accumulator for motor vehicles, namely batteries consisting of a single element. AA and AAA batteries, as well as batteries and accumulators used in mobile phones, laptops and notebooks, cordless power tools, toys and household appliances.

Portable batteries and accumulators chemical systems: Alkaline, Button, Lead-Acid, Lithium Ion, Lithium, NiCd, NiMH and Zinc-carbon.

• Type 2: Industrial batteries and accumulators

Batteries and accumulators designed exclusively for industrial or professional use that are placed directly on the market or incorporated into electrical and electronic equipment. Batteries or accumulators used as an emergency or back-up power source in hospitals, airports or offices, or designed exclusively for portable payment terminals in stores and restaurants and for barcode scanners in stores, those used in instrumentation or in other types of measuring apparatus, and those used in connection with renewable energy applications such as solar panels. 
Industrial batteries and accumulators chemical systems: Lead-Acid, Lithium Ion and NiCd

According to Decree-Law No. 152-D/2017 of the 11^th of December, a Producer is any natural or legal person who, within the scope of his professional activity, places batteries or accumulators on the national market for the first time, including those incorporated into appliances or vehicles, regardless of the sales technique used, including remote sales.

It should be noted that the definition of Producer given by Decree-Law No. 6/2009 is not based on the etymological meaning of the word producer, which refers to the entity responsible for producing the equipment, but rather on the entity that places it on the national market for the first time.

As such, a company in Portugal that distributes batteries and accumulators purchased from a foreign supplier is considered a Producer under Decree-Law No. 152-D/2017 of the 11^th of December, and only companies that exclusively resell batteries and accumulators purchased from domestic producers are excluded from this concept.

1. Join the Batteries and Accumulators Management System

If you are a producer of batteries and accumulators, you should transfer your responsibility for the management of batteries and accumulators to an entity that manages a collective system, such as Electrão, or alternatively you can set up an individual waste management system.

The collection of waste portable batteries and accumulators can be carried out in conjunction with the management systems for waste electrical and electronic equipment provided for in Decree-Law No. 152-D/2017 of the 11^th of December.

2. Register with the National Registration Entity

In addition to transferring responsibility to a Management Entity, you must also register as a Producer with the National Registration Entity, currently APA – Portuguese Environment Association, by formalising your registration with SILiAmb (SILIAMB.APAMBIENTE.PT), in accordance with Decree-Law No. 152-D/2017 of the 11^th of December.

3. Product Marking

Batteries and accumulators placed on the EU market must be labelled to indicate their separate collection as waste. This marking must be visible, legible and indelible and consists of a rubbish bin symbol barred with an X, in accordance with Decree-Law No. 152-D/2017 of the 11^th of December.

To join the Electrão Management System and transfer your responsibility for the management of batteries and accumulators, all you have to do is access the Electrão website and complete the online registration process (register Here). The process involves filling in a form in which you will have to: identify the producer joining the system and identify the batteries and accumulators segments. After completing the process, a welcome e-mail will be sent with the credentials to access the Members Portal and all the necessary information.

The cost of joining Electrão’s Waste Batteries and Accumulators Management System is directly related to the type and quantity of batteries and accumulators placed on the market, according to an eco-fee defined annually for each segment. The table of eco-fees according to the applicable regime can be found here.

Between the 1^st of January and the 31^st of March of each year, you must send to APA (at SILiAmb, SILIAMB.APAMBIENTE.PT ) the annual statement of batteries and accumulators placed on the market during the previous year and the estimate for the current year.

Between the 1^st of January and the 15^th of March, you must report to Electrão the batteries and accumulators placed on the market during the previous year and the estimate for the current year.

According to Article 3, paragraph q) of Decree-Law No. 152-D/2017 of the 11^th of December, a packager is ‘...anyone who professionally packs or has his products packaged, or imports packaged products and is responsible for placing them on the market'. These agents are responsible for managing the waste generated by the packaging they place on the market. Therefore, if they do not opt for an individual waste management system, all producers/packagers who:

- Package products under their own brand;

- Have other companies package products under their brand;

- Directly import products which they place on the domestic market;

- Produce or directly import service packaging.

In order to fulfil their legal obligation, packagers have to contract with SIGRE Electrão to transfer responsibility for packaging management and annually report all non-reusable packaging for products for which their company is responsible for the initial placing on the domestic market.

The transfer of responsibility for packaging management from a Packager to SIGRE Electrão is effected by paying the fees due for placing packaging on the national market, according to the type and quantity of packaging. You can find the SIGRE Electrão fees here, depending on the applicable Regime.

Between the 1^st of January and the 31^st of March each year, you must send to APA (at SILiAmb, SILIAMB.APAMBIENTE.PT ) the annual statement of packaging placed on the market during the previous year and the estimate for the current year.

Between the 1^st of January and the 15^th of March, you must report to Electrão the packaging placed on the market during the previous year and the estimate for the current year.

The issuance of Decree-Law 152-D/2017 of the 11^th of December exempts packagers from the obligation to mark primary packaging, with effect from the 1^st of January 2019. Nevertheless, we have created an Electrão packaging marking that can be used free of charge by SIGRE members during 2018 or afterwards if they wish to continue marking their packaging.