Agência Portuguesa do Ambiente (APA)

Divisão de Fluxos Específicos e Mercado de Resíduos

Rua da Murgueira, 9 - Zambujal - Alfragide | 2610-124 Amadora Portugal

3 July 2025

3 July 2025

3 July 2025

The WFD allows, by way of derogation, that the weight of recycled waste may be measured at the output of any sorting operation. Portugal (PT) has applied the derrogation since PT has standard technical specifications for packaging that municipal sorting facilities must fulfill, so that the material is considered acceptable for recycling facilities. These specifications set quality standards for the material, including a maximum level of contaminants allowed. In the preparation of these specifications a number of stakeholders were involved including recyclers and contaminants were defined taking into account recycling processes of the different materials.

It is just discounted on bales prepared by the SGRU - Sistemas de Gestão de Resíduos Urbanos (Municipal Waste Management Systems) that are mixed bales ( with packaging and non-packaging), for example paper/cardboard bales or plastic film bales, the amount of non-packaging. The information reported by the PROs to APA, within the scope of the annual reports, is already only referring to the amount of packaging, but we have information on the percentage of packaging and non-packaging in another type of report. We only count for recycling the amount of packaging.

Table : Institutions involved in the collection of data and distribution of tasks.

It is used the standard R codes in Annexes I and II of Directive 2008/98/CE: R1, R3, R4, R5 and R12.

The standard R codes defined in Annexes I and II of Directive 2008/98/CE (R1, R3, R4, R5 and R12) are used.

We have considered information related to municipal waste and non municipal waste.

We don't take into account the amount of wooden packaging that is repaired for reuse. We still don't have information about the amounts involved.

We take into account the amount of metals in incineration bottom ash (IBA) for the calculation of the targets. 

Reusable packaging are essentially:

• Plastic - essentially pallets, IBC, bottle crates, big water bottles (18 liters, 25 liters...), containers, barrels, transport boxes, PP plastic buckets, Big bags;
• Wood - pallets;
• Glass - beverage bottles;
• Ferrous metal - essentially metal grid from the IBC, metal drums, beverage barrels, cylinders;
• Aluminium - beverage barrels and cylinders;
• Paper/cardboard - cardboard boxes, cardboard separators.

Almost all reported systems are closed loop systems.

We have not "other recovery".

100% for the 3 material reported (plastic packaging, paper packaging and wood packaging).

The reports made from PROs (SPV, Novo Verde and Electrão) to APA concerning quantity of waste packaging recycled, doesn´t take into account the temporary storage (stocks) made in the waste treatment operators.
Regarding data taken from the electronic platform MIRR (Integrated Waste Registration Map), in one of the registration forms all the waste treatment operatores must register the quantity of waste received, by LoW code, its producer and operation to which it is subjected (as mentioned in annex II of the Waste Framework Directive 2008/98/EC). In other registration form there are information about stocks, but that information has not been analyzed. But we believe that it does not greatly influence the values since many operators do not have stocks (what is received in one year is treated that year) and the waste treatment operators who have stocks, have stocks that come from the previous year but also keep stock at the end of the year.

Producer responsibility organisation (PRO).

National legislation (Decree-law 152-D/2017)  and each licence of each PRO defines the legal framework and the entire functioning of the system for the EPR for packaging.

Based on the legal framework, and for the packaging waste stream, these entities are considered producers and have to assign with a PRO:

• Portuguese companies that produce and package goods and are responsible for the first availability of the packaged products on the Portuguese market;
• Portuguese companies that order another company to package goods with their own brand and are responsible for their first availability on the market;
• Portuguese companies that import (from other Member State or third country) packaged products and are responsible for the first availability of the packaged product on the Portuguese market;
• Portuguese companies that manufacture or import (from other Member State or third country) service packaging (packaging to be filled at the point of sale) and are responsible for their first availability on the market;
• Foreign companies (through the appointment of an authorized representative) that sell packaged goods to Portugal directly to end users;
• Foreign companies (through the appointment of an authorized representative) that sell service packaging to Portugal directly to end users.

All PROs.

For Waste generation:

We have used the placed on the market approach, the population is the universe for which we want to know packaging placed on the market. "Total packaged products placed on the national market for the first time by all economic operators" and service packaging  placed on the national market (to be filled in PT)

For Treatment:

• National treatment plants treating nationally generated packaging waste.
• Treatment plants aboard treating nationally generated packaging waste (packaging nacionally generated and treated outside - transboundary movement of waste).

Portugal.

2023

Not applicable.

Tonnes.

Calendar year

Packaging Diretive 94/62/CE.

Decree-law 152-D/2017 and PROs permits which establishes the obligation of producers/packers to report information on the quantity of packaging placed on the market on the APA electronic platform and the obligation of PRO to report information about quantities placed on market and quantities recycled.

Decree-Law No. 102-D/2020 which establishes the obligation of waste producers to report on the APA electronic platform (MIRR and MTR) the waste produced, the obligation of waste management operators to report on the APA electronic platform (MIRR and MTR) the waste received and treated and the obligation of SGRU (Sitemas de Gestão de Resíduos Urbanos - municpal waste management systems) to report on the APA MRRU electronic platform information about municipal waste collected and treated (sorted, incinerated and placed in landfill) and forwarded for recycling.

Institutional Mandate - data sharing :  Statistics on packaging and packaging waste are in accordance with the Commission Decision 2005/270/EC.

European General Data Protection Regulation (GDPR).

All data are aggregated before being published.

The reporting table of Packaging report is published on the APA website within 5 days after the data is validated (this is established in legislation decree-law 152-D/2017 -article 97ºA (5). However, it is usually published on the website immediately after submission to Eurostat, stating that the data is still being validated and that note is removed after the data has been validated by Eurostat.  

The PROs must send to the APA, to DGAE - Direção Geral das Atividades Económicas (General Directorate of Economic Activities) and to ERSAR - Entidade Reguladora  dos Serviços de Águas e Resíduos (Water and Waste Regulatory Entity), by April 15th of the year immediately following the year to which they report, the annual activity report and must publish the respective summary on your website by that date.The summary report contains, namely, information on the quantities of packaging placed on the market and the quantities of packaging waste recycled and recovered. This deadline is also established in legislation (decree-law 152-D/2017 - article 12º (1 (j)) and in the PRO permit.

Decree law 152-D/2017 establishes the deadlines referred to in question 8..1 regarding the disclosure of information.

There is not a general data release policy of APA.

However, for certain matters, such as the management of specific waste flows, the legislation provides for the disclosure of information on the APA website and on the PRO website 

Anual.

Not applicable.

• Please find information at this link to the website.
• Publications (available in Portuguese).
• Publications on Recycling and sorting (available in Portuguese).
• Reports on the Management of Waste Electrical Equipment, Batteries and Accumulators and Packaging (available in Portuguese).

We don't have a online database.

Not applicable.

The 2023 data of EPR schemes is published on the APA website in a space related to packaging. 

The data reported to COM/Eurostat is published also on the APA website:

• Reporte_comunitario_2022_ERE.
• Relatorios-de-gestao.

Technical standars for waste packaging bales, methodology for quantifying slag and accounting for organically recovered packaging waste are also on the APA website:

• Fluxos Especificos Residuos.
• Metodologia Afericao Percentagem Embalagens
• Valorizacao Organica.

Not available.

1.Cross-checks and Time-series checks are made to the data reported on APA's electronic platforms:

MRRU Data:

• Waste produced and managed analisys with validation of the time series both by MWMS and by establishment;
• Cross-checks between the various MRRU forms, analysing what enters in one form and what is identified as an exit in another form (cross-checking);
• The mass balance of the various treatments and respective verification at the level of time series;
• The suitability of the waste for a given recipient and operation;
• Cross-checks between the Integrated Waste Recording Map (MIRR), Electronic waste tracking guides (e-GAR), MTR-LV forms and the MRRU. Quantities are checked as well as the existence of duplication of information, particularly between the MIRR and MRRU.

The quantities reported in the MIRR by the waste treatment operators are in many cases already filled in automatically from the electronic waste tracking guides. The waste tracking guides became electronic since 2018, and communicate directly with MIRR.

MIRR Data

1. APA promotes analysis of the data reported, with emphasis on the analysis of treatment operations that do not exist in Portugal or are prohibited, large-scale producers of WEEE, the MIRR of the SGRUs, cross-comparison of quantities between forms and with e-GAR.
2. INE (National Statistics Institute) carries out validations at the time series level: comparisons on absolute values for businesses and on average values for economic activities level (producers that stand out within the economic activity itself), and validations on internal coherence: unlikely LoW codes vs. operation combinations, max values analysis (above 50 k tons; dominant producers by activity) whole number analysis and average waste generation according turrnover by businesses and reference numbers by economic activity, etc.

MTR Data
APA:

• Validates the data reported based on analysis of the notification processes, and subsequently checks that the information on the receipt and treatment of waste is loaded onto the platform.
• Vhecks situations such as quantities incorrectly registered (by checking against the documents loaded into the SILIAMB).
• Checks possible incompatibilities between waste codes (Basel/OECD code) and destination countries.

2.Audits are also made:

1. APA promotes audits with the objective of:
   • Evaluating the veracity, degree of reliability and accuracy of the data reported by TGR tax payers (landfills, incineration, co-incineration), particularly with regard to the correct accounting, weighing and classification of the waste received and dispatched and its origin and destination;
   • To verify, within the scope of the waste treatment operators, the implementation of procedures and licensing conditions and the validation of information and data provided to the Administration;
   • Evaluating the activity balance sheet, within the scope of specific waste streams management systems and, at least, a balance sheet for the first three years of the period of validity of the licence for the management of the specific streams, as well as a balance sheet at the end of the respective period.
2. PROs promote audits to to their producers/packers to assess the reliability of the PoM data, to SGRU - Sistemas de Gestão de Resíduos Urbanos (Municipal Waste Management Systems) to assess the reliability of data relating to the quantities of packaging waste sent for recycling and compliance with technical specifications and to waste treatment operators to assess the reliability of data relating to the quantities of packaging waste recycled and compliance with technical specifications.
3. Annual activity report submitted by the PROs to APA are audited by an independent entity.

Not available.

Academia, media, general public, NGOs, PROs, government.

Information is sought for academic work, for the production of news by the media (especially in magazines with environmental content), for knowledge of information by NGOs.

PROs also seek information to learn about other PROs, especially their competing PROs.

Not available.

Data are complete.

Waste generated - PoM methodology

Since 2017 APA has implemented the National Electronic Register of Producers, for reporting of the packaging quantities placed on market (PoM), by packers and/or those responsible for placing packaged products on the national market and manufacturers and importers of service packaging. However, the data still presents some weaknesses. Although the collaboration between APA and INE- Instituto Nacional de Estatística (Statistics Portugal) regarding waste statistics has been going on for several years, the analysis and validation of these statements has not been carried out. Consequently, the estimate of waste generated has been made based on the data reported by the 3 PROs (SPV, Novo Verde and Elétron) and an extrapolation to the global scope. The PROs (SPV, Novo Verde and Electrão) scope is non-reusable primary, secondary and tertiary packaging (including items designed and intended to be filled at the point of sale), placed on the national market and respective packaging waste whose responsibility for management is attributed by law to SGRU – household waste and similar waste whose daily production per producer does not exceed 1100 litres.

The first basis for calculating the ratio between the PROs universe and the total universe of packaging PoM comes from 2013. If the amount of packaging in the PRO universe increases every year (and this is what has been happening), the amount of packaging outside the PRO scope also increases, which may not be true.

Within the scope of Own Resources, we are working with INE reviewing the methodology for quantifying the amount of plastic packaging waste generated by the 2 approaches : PoM and Waste Analysis. We are also working with the INE on a methodology for freeriding accounting.

From next year's report (reference year 2024) we intend to replicate (with the necessary adaptations) the Waste Analysis methodology developed for plastic within the scope of Own Resources for the other materials and start reporting based on this methodology which we consider more robust.

Waste treatment

Relating to waste treatment, PROs report to APA the quantity of packaging waste by LoW codes but also by material name (plastic, glass,...). The waste treatment operators and SGRU - Sistemas de Gestão de Resíduos Urbanos (Municipal Waste Management Systems) report to APA on electronic platforms (MRRU, MIRR and MTR) by LoW codes.

In 15 01 05, 15 01 06 and 150110 waste codes we have packaging but we don't know of wich materials. Also, we believe that some metal packaging is being classified in waste scrap codes or in other codes that could contain metal, like, for example, the construction and demolition waste codes  (LoW codes 17). We are losing some quantities of packaging in these LoW codes for the fulfillment of the targets by material.
Another equally important factor is that waste packaging that enters, for example in the municipal waste mangamente system, with a LoW 15 01... , after an appropriate separation and cleaning this waste that exits these facilities to the recycler must be classified  whith LoW code 19 12.... This LoW code includes other wastes than packaging. If we have just this information (just the LoW code and no information about if it is packaging or not) we don't use those quantities.

Reusable packaging

Some economic operators doesn't clearly distinguish between reusable and single-use packaging. But the information received from economic operators was analysed and only the information we consider that in fact refers to reusable packaging was reported in table 3 of the report excel file submited by EDAMIS (WASTE_PACKDAT_A_PT_2023_0000_V0001).

The information in this section is to provide an overarching understanding of the accuracy of any statistical surveys used relating to packaging waste. Some of the information may be available in previous questions.

The information in this section is to provide an overarching understanding of the accuracy of any statistical surveys used relating to packaging waste. Some of the information may be available in other concepts.

Not applicable.

Not applicable.

The different electronic platforms that APA has for reporting information must be completed according to the following schedule:

• MIRR - annually until March 31 of year n+1 with data relating to year n.
• MTR - annually until March 31 of year n+1 with data relating to year n.
• MRRU - This platform is made up of several forms, with January 31st being the deadline for submitting most of the forms, including those considered annual.The forms for the characterization of waste produced, landfilled/incinerated are sent via excel file, until March 31st, as set out in the Characterization Ordinance. Other forms are sent monthly until the end of the following month to which the information relates to.
• Regarding the report by producers/packers on the APA  electronic platform (report of the quantities of packaging placed on market), the deadline is March 31 of year n+1 with data relating to year n.
• The reporting of PROs on the APA electronic platform is until April 15  of year n+1 with data relating to year n.

2023 data was sent to eurostat on 30 june 2025

Not applicable.

An important note for these year is thar we did't sum the quantities of reusable packaging PoM for the first time in 2023 to the quantity of non reusable packaging PoM in 2023.

The submission of the form relating to reusable packaging (identical to the form present in the Reporting Guide) became madatory since 2024 (reference year 2023).In previous years it was not mandatory. There was a very significant increase in the number of forms submitted and consequently a very significant increase in the quantities declared. This fact made us rethink and conclude that we could not add to the quantity of non-reusable packaging placed on the market in 2023 the quantity of reusable packaging placed on the market for the first time in that year, since this quantity will not be available for recycling (unlike non-reusable packaging PoM that, by approximation, becomes waste in the same year). In the case of reusable packaging, we would have to add the quantity of reusable packaging that became waste in 2023 (waste generated). We do not have this information yet. we will change the form to request this information for the next report.  Please note that the electronic platforms (MRRU, MIRR and MTR), as well as the information provided by the PROs, do not allow the distinction between reusable and non-reusable packaging when these are already waste.

Not applicable.

We have no information about "other materials" PoM (G17 cell of table 1 of WASTE_PACKDAT_A_PT_2023_0000_V0001) .  However we have quantities of waste packaging recicled, classified with LoW codes 150105, 150106 and 150110 (W17 cell of table 1 of WASTE_PACKDAT_A_PT_2023_0000_V0001). There is a high probability that the quantity of  these packaging (when PoM) have been considered in the cells G8, G9, G10, G11, G12, G15 and G16, since it is mandatory the report by material (even in composite packaging). So we have considered in cell  G17 the value zero.  That why for this line ("Other") the recycling quantity is higher than generation.

We consider the quantity of cell W17 only for quantifying the overall quantity of recycled packaging waste and not the quantity per material.

Explanation detailing the causes of the tonnage difference (in relation to which waste streams, sectors or estimates have caused the difference, and what the underlying cause is) for any component of packaging waste generated and recycled which shows greater than a 10 % variation from the data submitted for the previous data year.

Not applicable.

Not available.

We do not yet a planned policy for revising information.

We intend however from next year's report (reference year 2024)  to replicate (with the necessary adaptations) the waste analysis methodology developed for plastic within the scope of Own Resources for the other materials and start reporting based on this methodology.

We did not change the reporting methodology.

Within the scope of Own Resources, we are working with INE reviewing the methodology for quantifying the amount of plastic packaging waste generated by the 2 approaches : PoM and waste analysis. We are also working with the INE on a methodology for freeriding accounting.

From next year's report (reference year 2024) we intend to replicate (with the necessary adaptations) the waste analysis methodology developed for plastic within the scope of Own Resources for the other materials and start reporting based on this methodology.

• The reports made from EPR schemes (SPV, Novo Verde and Electrão) to APA concerning quantity of packaging POM (quantities reported by their members/producers) and quantity of waste packaging recycled.  The scope of these PRO is sales, group and transport non reusable packaging that give rise to municipal waste from waste producers with a daily waste production under 1100 liters. It is not in the scope of the PROs the industrial packaging, municipal packaging waste from waste producers with a daily waste production above 1100 liters (called "big producers of municipal waste) and also the reusable packaging.
• The APA electronic platform MRRU-Mapa Integrado de Registo de Resíduos (Integrated Waste Registration Map) where all the SGRU - Sistemas de Gestão de Resíduos Urbanos (Municipal Waste Management Systems) report the quantity of waste (including packaging), the destination (waste treatment operator) and operation as mentioned in annex II of the Waste Framework Directive 2008/98/EC, by LoW code.  MRRU consists of a set of forms, filled in monthly by SGRU and also annually by  the end of january. Data registered comprehends municipal waste quantities collected\received {by the SGRU itself (usually separate collection) or the municipalities (usually the mixed collection)} and managed according to the waste treatment facilities existing and in operation at each SGRU (landfills, energy recovery plants, sorting facilities, composting or anaerobic digestion plants, etc).  The data structure, design and system concept for MRRU database allows to assess the amounts of waste on municipal waste input\output by each kind of facility and by waste flow and type. MRRU also collects data on WCA resulting from Portaria n. º 851/2009.
• The APA electronic platform MIRR (Integrated Map of Waste Register). In one of the registration form the portuguese waste treatment operatores must register the quantity of waste received, by LoW code, its producer and operation as mentioned in annex II of the Waste Framework Directive 2008/98/EC. This platform does not allow distinguishing between single-use packaging waste and reusable packaging waste.
• The APA electronic platform MTR (transboundary movement of waste) where the waste, by LoW code, that is exported is declared (quantity of exported material, the operations as mentioned in annex II of the Waste Framework Directive 2008/98/EC. If the first operation is an R12 or R13 there is also information about the subsequent operation). This platform does not allow distinguishing between single-use packaging waste and reusable packaging waste.  In the MTR-LV module (MTR -green list), documents are issued for international shipments of green listed waste leaving Portugal, under Regulation (EC) No. 1013/2006. The forms correspond to the Annex VII of the referred Regulation and are completed and submitted for each individual shipment of green listed waste leaving Portugal.  The MTR-LL ( MTR - Amber list) module is based on forms that allow submission of the data in Annexes I-A and I-B of Regulation (EC) No. 1013/2006, regarding transboundary movements of waste subject to the prior written notification and consent procedure (PIC procedure).
• We also receive information from Autonomous Region of the Azores as this region uses its own reporting platforms for waste.
• For reusable packaging we have obtained data from a form (identical to the one presented in the Commision Guidance). This form became mandatory (following changes in national legislation) from 2024 (reference year 2023)

PT didn´t use until now the metodology based on waste analysis.

PT doesn´t use a metodology based on waste analysis.

Annual.

(although there is information collected monthly (in MRRU platform), the annual information is what is important for this report)

See details in sections below.

No packaging waste analysis is used.
But within the scope of Own Resources, we are working with the National Institute of Statistics reviewing the methodology for quantifying the amount of plastic packaging waste generated by the 2 methodologies (PoM and waste analysis) and then it is our intention to apply these methodologies to other materials.

For composite packaging and other packaging made up of more than one material, the report from producers/packers to PRO and to APA platforms must be made for the different materials separately. As an example, differentiate the glass bottle, the paper label and the aluminum cap and report each quantity separately.
In the specific case of ECAL (carton packaging to liquid food), like tetrapack, there is a specific material category on the reporting platform of PRO and on APA platform which is "ECAL" . Since reference 2020 and in order to comply with the 5% rule, we considered that these packages are made up of 75% paper, 20% plastic and 5% aluminum and we allocated the weight of the ECAL to these 3 materials, taking these percentages into account. These percentages were obtained through consultation with the industry.

Additional information about the methodology, including the combination of methods used:

For municipal waste packaging we use the reports made from PRO (SPV, Novo Verde and Electrão) to APA concerning quantity of waste packaging recycled (the PRO pay to SGRU a monetary value for the quantity of packaging waste wich fullfill the technical standards/specifications for the quality requirements of sorted waste and goes to recycling and PRO sell packaging waste at auctions).
We use also the APA electronic platform MRRU where all the SGRU report the quantity of waste (including packaging), by LoW code, their destination (waste treatment operator), the operation as mentioned in annex II of the Waste Framework Directive 2008/98/EC (R codes). The SGRU can send directly (not via the PRO ) for recycling some waste. Some SGRU manage some non municipal waste and so we use SGRU to obtain these quantities that are not in the scope of PROs. Reusable packaging waste is not allowed to be deposited in municipal waste collection systems.
For non municipal waste packaging and  municipal waste packaging produced in "big municpal waste producers" (waste producers witrh a daily production above 1100l iters) we use the APA electronic platform MIRR . In one of the registration form the waste treatment operatores must register the quantity of waste received, by ELW code, its producer and operation as mentioned in annex II of the Waste Framework Directive 2008/98/EC (R codes). We use only the waste produced in Portugal. This platform does not allow distinguishing between single-use packaging waste and reusable packaging waste.
The waste produced in Portugal and treated outside Portugal is obtained in the APA electronic platform MTR (transboundary movement of waste). This platform does not allow distinguishing between single-use packaging waste and reusable packaging waste.
We also receive information from Autonomous region of the Azores as this region uses its own reporting platforms for waste.

Not applicable.

From 2024 (reference year 2023) onwards, it became  mandatory by law for those packers that use reusable packaging to fill in a form with data about reusable packaging ,for reference year n,  by April 30 of year n+1.

Calculation of recycling of metals from incinerator bottom ash : Detailed description of the method to collect data in order to calculate the amount of metals separated from incineration bottom ash in accordance with the Commission Implementing Act adopted in accordance with Article 37(7) of Directive 2008/98/EC.

See the sections below.

The waste produced and treated in Portugal are accompanied by an electronic waste tracking guides (e-GAR). The waste tracking guides became electronic since 2018, and communicate directly with MIRR platform.
Applicable to road, rail, sea, river and air transportation of waste in national territory.
The e-GAR are issued on APA's platform, with APA having access to all information .

PROs make audits to waste treatment operators to assess the quality and veracity of the information reported and compliance with technical specifications.  

PROs make audits to SGRU to assess the quality and veracity of the information reported and compliance with technical specifications.

For transboundary movements of waste we comply with the Regulation n.º 1013/2016(see question 18.4.3). The APA has an electronic platform - MTR (transboundary movement of waste) where the waste, by ELW code, that is exported is declared (quantity of exported material and what is the type of operations that the material is receivingas mentioned in annex II of the Waste Framework Directive 2008/98/EC.

For all the waste transboundary movements, Portugal has to comply with Regulation n.º 1013/2016, of the European Parliament and of the Council on shipment waste, and also the Decree Law 45/2008, 11th march, ensuring the implementation and compliance in the domestic law the obligations of Portugal in the Regulation.
As known, the Regulation establish procedures to control the shipment waste, taking in account the origin, destiny and itinerary of that shipment and, in addition, the type of waste and treatment that the waste in going to receive.
All the shipments have to be declared in the APA platform for this purpose, MTR , where those who want to make the shipment can generate forms to the waste that fits the green list or filling the notifications document for waste that falls on the amber list.
Portugal has a data report for shipment waste, where is possible to see the waste flow in the green list and the notifications associated to the amber list, for type of material, operation and destiny.
Although we have the report with the information on the waste shipments, is difficult to see which is ready to be recycle which is “untreated” in the packaging case. Normally after separation and cleaning the waste packaging that has been classified with a 15 01… exits the separation plant with a different LoW code (for example 19 12...).

The columns in the table relate to information on verification procedures used by PROs.

The columns in the table relate to information on verification procedures used within the national statistical reporting system to validate the accuracy of the data.

See details in sections below.

Primary sources and their shares in the total.

(*) Necessity of a certain minimum amount of waste, turnover etc. to be registered 

Not applicable.

Not applicable.

The quantity of packaging PoM in 2023 was calculated taking into account the declarations of the quantity of packaging PoM, by material, in 2023, made by the producers/packers to the 3 PRO (Sociedade Ponto Verde, Novo Verde and Electrão). Since PROs only covers sales (including service packaging), group and transport non reusable packaging that give rise to municipal waste from waste producers with a daily waste production under 1100 liters (waste packaging in the scope of SGRU), an estimate of the weight of this universe in relation to the total non reusable packaging PoM is used. We calculate that estimate of the weight/racio using the data from previous year (2022). With the declarations from the producers/packers (PRO universe) in 2023, we made an estimate for the total PoM in the same year, using the percentages found for the previous year (2022). 

Total PoM (n)= PRO PoM (n) x Total PoM (n-1) / PRO PoM (n-1).

Racio of PRO universe in the total non reusable packaging PoM in 2022:

• Glass 99,7%
• Plastic 43,9%
• Paper 24,9%
• Metals 49,9% (Ferrous 48,2% Aliminium 52,8%)
• Wood 9,3%
• Global 46%.

An important note for these year is thar we did't sum the quantities of reusable packaging PoM for the first time in 2023 to the quantity of non reusable packaging PoM in 2023.

The submission of the form relating to reusable packaging (identical to the form present in the Reporting Guide) became madatory since 2024 (reference year 2023).In previous years it was not mandatory. There was a very significant increase in the number of forms submitted and consequently a very significant increase in the quantities declared. This fact made us rethink and conclude that we could not add to the quantity of non-reusable packaging placed on the market in 2023 the quantity of reusable packaging placed on the market for the first time in that year, since this quantity will not be available for recycling (unlike non-reusable packaging PoM that, by approximation, becomes waste in the same year). In the case of reusable packaging, we would have to add the quantity of reusable packaging that became waste in 2023 (waste generated). We do not have this information yet. we will change the form to request this information for the next report.  Please note that the electronic platforms (MRRU, MIRR and MTR), as well as the information provided by the PROs, do not allow the distinction between reusable and non-reusable packaging when these are already waste.

We don't have yet any estimation for freeriding, private shipments and on line sales. 

We have no theshold or exemptions from reporting of producers to PROs or to APA.

PT doesn't have a minimis and there are no exemptionts for reporting. 

SGRU for some material (for example paper, plastic films) make bales of packaging and non-packaging items together. Analyzes / samplings are made by SGRU to find out the packaging content (%) and only the quantity of packaging is counted and reported from PRO to APA in the scope of their anual report (but we have information on the percentage of packaging and non-packaging in another type of report). We only count for recycling the amount of packaging.
The characterizations are made in all the SGRU existing in Portugal that have mixed bales and the result depends on the SGRU.
The characterization methodology is written and agreed between the SGRU and the PROs. These characterizations are made whenever deemed relevant, as a result of changes in selective collection, like implementation of new circuits.

PROs carry out SGRU audits and also carry out characterizations themselves.

We have considered paper and wood packaging composting. It is considered that these paper/wood packaging are recycled if the compost where they are incorporated is used into agricultural, forestry and / or landscaped soils as an organic corrective, so that the moment of accounting for recycling these packaging residues is only carried out in the year the compost is sold to incorporation into soils. Quantities are validated by the 3 PROs (SPV, Novo Verde and Electrão).

paper / wood packaging in compost (t) = municipal waste entering MBT (t) x % paper / wood packaging in municipal waste - rejected from MBT (t) x % paper / wood packaging (rejected) - paper/wood packaging recovered from MBT (t).

The proportion of paper and wood packaging waste in mixed municipal waste ( entering mechanical and biological treatment, MBT, and in the rejected) are obtained through the characterization of these municipal waste flows in accordance with Ordinance No. 851/2009, of 7 August.

SGRU are responsible for developing the campaigns to assess the physical composition of municipal waste, accordingly to the guidelines set out in the mentioned Order. The campaigns are carried out in two different periods of the year: for seasonality and climate conditions reasons, one campaign is carried out in the spring/summer season and a second one in the autumn/winter season. Atypical or exceptional periods, such as festive or holiday seasons, should be avoided which may interfere with the characteristics of the MW produced.

Some SGRU have their own trained and dedicated human resources to supervise and carry out the composition characterization campaigns. Others, contract this task to auditing companies with recognized technical capacity to perform the analysis and produce reports accordingly.

Taking into consideration the legislation and common practice, the majority of the SGRU perform, every year, a due assessment on waste composition analysis. SGRU may request to APA an exemption on doing assessment on an annual basis if there is evidence on stabilization of results and statistical evidence of no significant modifications on relevant parameters in previous years. Though, most of SGRU recognise the importance of doing such assessment every year as crucial to management decisions whether operational or investment programming.

The categories and subcategories to be characterized are defined in the mentioned Order.

In the specific case of ECAL (carton packaging to liquid food), like tetrapack, since reference year 2020 in order to comply with the 5% rule, we considered that these packages are made up of 75% paper, 20% plastic and 5% aluminum and we allocated the weight of the ECAL to these 3 materials, taking these percentages into account.
For waste packaging classified with LoW 150105, 150106 and 150110 we didn't identify the materials (plastic, wood, metal, glass or paper) . That's why we considered only the respective quantity that is recycled in the total quantity and not by material.

Description of the sorted packaging waste to which ALRs are applied, types of sorting plants to which different ALRs apply, the methodological approach to calculating ALRs at such point(s), including the statistical accuracy of any surveys used, or the nature of any technical specifications.

PT does not yet have adjustments, namely for humidity, online commerce, free riding.

Description, where applicable, of the methodology to exclude non-packaging waste from the reported amount of recycled packaging waste and of the methodology to correct the amount of packaging waste at the measurement point in order to reflect the natural humidity rate of packaging (including by using relevant European standards). Aggregated data across facilities of a similar type is acceptable.

Description of the methodology to exclude waste originating from other countries, where applicable. Aggregated data across facilities of a similar type is acceptable.

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