New Packaging Labelling in Portugal: Companies Have a Choice from 2025

As of 1 January 2025, a significant change to packaging labelling regulations will take effect in Portugal. Companies that were previously required to provide waste disposal information through alternative channels will now also have the option to display this information directly on the packaging. 

What is changing? 

Until the end of 2024, companies were required under Article 28(5)(b) UNILEX to provide waste disposal instructions through alternative means, such as: 

• On their website, 

•  In the product’s instruction manual, 

• At points of sale. 

This obligation will remain in force beyond 1 January 2025. However, companies now have an additional option to fulfil their obligation to provide disposal information and can choose between the following two equally valid alternatives: 

• Option 1 – Direct labelling on the packaging (Article 28(5)(a) UNILEX)
  → Waste disposal instructions, particularly indicating the correct recycling bin, can be displayed directly on primary or secondary non-reusable packaging.
• Option 2 – Providing waste disposal information through alternative means (Article 28(5)(b) UNILEX)
  → Waste disposal instructions will continue to be provided via websites, instruction manuals, or at points of sale.

Conclusion: Information Obligation Remains, but Companies Have More Flexibility 

While companies are not required to label their packaging, they must continue to provide waste disposal information – either directly on the packaging or through alternative channels.

This regulation applies only to packaging that generates municipal waste and falls under the Portuguese Integrated Packaging and Packaging Waste Management System (SIGRE).