1 - I am a foreign company selling to Portugal, without a local delegation. Do I need to register?

Any company, national or foreign, placing EEE into Portugal, has to register.

Foreign companies, selling directly to Portuguese end-users, without any local representatives, delegations or agents, have to register.

Foreign companies selling to Portugal through local representatives, delegations or agents, does not need to register but, the Portuguese companies involved have to be registered.



2 - Do I have to register?

Please read the information in “Register/Do I have to register”, in this website.

All companies have to register if two criteria are simultaneously achieved:

a) To be considered an EEE Producer, according exiting definition in Portuguese Decree-Law 230/2004 and herewith quoted:

«… any entity that, regardless of its sales technique, including distance-selling:

i) Manufactures and places EEE on the national market under its own brand name;
ii) Resells, under its own brand name, EEE manufactured by other suppliers;
iii) Professionally imports or places EEE on the national market. »

EEE (Electric and electronic Equipment) have the meaning defined in article 3 a):

 «…equipment that depends upon electrical currents or electromagnetic fields in order to function correctly, as well as equipment for the generation, transfer and measurement of these currents and fields belonging to the categories as set out in Annexure I of this statute and as designed for use with a standard voltage that does not exceed 1000 V for alternating current and 1500 V for direct current; »

b) To place in the Portuguese market EEE with functionality mentioned in Annex I of Decree-Law 230/2004.

Annex I is only an indicative list. As a non-exhaustive list, any EEE not specifically listed, does not mean it is not in. Please take in consideration the functionality and not the designation of the equipment.



3 - I am a foreign producer. Can I register in Portugal?

Yes. A foreign producer/company should register and follow the same procedures as a national producer, that is, accede our on line register SIRPEEE, in this website.



4 - How do I register?

Please read “Register/How do I register”, in this website.

The register is made through our online system SIRPEEE (available in this website).




5 - What are my obligations?

Please consult “Register/What are my obligations”.

Producer’s obligations are:

a) To report periodically (every six months) his company’s activity to ANREEE;
b) To pay the Annual Register Fee;
c) To join a WEEE management system (through a collective scheme or by licensing an individual scheme);
d) To label all EEE with the separate collection symbol (crossed bin container);
e) To show the registration number PT000000 in all issued invoices.



6 - I’m registered in ANREEE. What’s the next step?

Registered producers have to follow all the instructions in the “What are my obligations?” diagram.
Portuguese law foresees severe penalties for producers who do not accomplish with their responsibilities.



7 - What’s the use for the Annual Register Certificate?

This document is a statement of accomplishment towards ANREEE.
Accomplish with your obligations means not only report your activity as Producer, according to schedule, but also make the payment of the invoices related with your annual register activity as Producer.
The Annual Register Certificate is renewable every year and allows to Producers to keep records of their register in ANREEE.

Please, make sure to keep your Certificate updated.



8 - Where should I put the symbol of the crossed-out bin if it compromises the functionality of my EEE? And when the EEE is too small?

When there are limitations as to place the symbol of separate collection in EEE, WEEE Directive 2002/96/EC states (Article 10, paragraph 3) that the symbol shall be printed on the packaging, the instructions for use and on the warranty of the EEE.
Please consult the EN standard that indicates which are the dimensions of the symbol to be applied on EEE, in folder "Documents".




9 - To whom should I report my activity?

You must report your activity to ANREEE and to your WEEE Collective Scheme.

ANREEE and Collective Schemes are two entities with distinct purpose.
Therefore, your activity report must be done separately, to EACH ONE of them.

Report’s periodicity:
ANREEE = every sixth months (July e January)
WEEE Collective Schemes = please consult your compliance scheme.
WARNING: reporting only to one entity only, does not fulfil your obligations



10 - Why do ANREEE and Collective Schemes have different classification for EEE?

ANREEE’s classification is the official, based in Annex I of DL 230/2004.

Collective schemes, adopted other classifications based on weee cost and commercial strategies.

Therefore, all classification tables/lists used by Collective Schemes are an issue that does not concern ANREEE.

Please consult your Collective Scheme if you have doubts in this matter.



11 - What are the Portuguese inspective government entities?

Inspective government entities, in what WEEE management is concerned, are ASAE – Economic and Food Security Authority and IGAOT – Environment and Territory General Inspection.



12 - If my company has an inspection, what should I do?

Companies can be checked by government authorities ASAE and IGAOT.
If your company receives a visit from these authorities, you should:
▪    Present your Annual Register Certificate
▪    Present a proving document or contract with your WEEE Compliance Scheme.
▪    Prove that your EEE have the symbol of crossed container
▪    Prove that your invoices and transport docs have the register number PT100000



13 - Are my company data available to everybody?

The names of registered companies are public and available at ANREEE’s website.
Other data like EEE type, units, weights, etc., are strictly confidential.
No one, except ANREEE who is bound by confidentiality, has access to your reporting data.



14 - I want to take responsibility for my WEEE management. How can I have my own scheme?

Any producer may have is own individual scheme. In order to achieve it, he must:

i)    Get a licence from APA – Portuguese Environment Agency;
ii)    Guarantee that obligations in the individual scheme are similar to the ones in a collective scheme;
iii)    Assume all scheme responsibility, issuing guarantees like:
- Bank guarantee on ANREEE’s behalf;
or
- blocked bank account on ANREEE’s behalf.



15 - What is the bank guarantee amount for companies who choose an individual scheme?

The guarantee amount is established by ANREEEE. This amount will be related with type and nature of WEEE treatment, as well as the forecast quantities (in units and weights). Therefore the amount is calculated according to each company.



16 - I am an EEE assembler. Should I register?

If your company gathers/assembles several products or components, in order to form an EEE and if the EEE’s functionality is mentioned in Annex I of Portuguese Decree-Law 230/2004, than your company is considered EEE producer. Consequently you should register.



17 - I am a manufacturer and I’m producing EEE ordered by one of my clients. This ordered EEE have my client’s brand name, when they leave the factory. Who should register: me or my client?

The register should be made by the company who ordered the EEE under its own brand name, for the company is considered responsible for the EEE placement on Portuguese market. The manufacturer works only as an outsourcer of the product.



18 - I am a producer of EEE that have no brand name. Should I register?

If you are placing EEE on the market and EEE’s functionality is mentioned in Annex I of Portuguese Decree-Law, yes, you should register.

Despite the fact your EEE has no brand name you are responsible for its placement on Portuguese market.



19 - I am an EEE reseller. Should I register?

You must consider the way your EEE become available on the market.
If you buy EEE to a national supplier and you rebrand them, you should register (please consult article 3 d ii) of Portuguese Decree-Law 230/2004).
If you buy EEE to a national supplier and you simply resell them (with supplier’s brand name) than you don’t need to register.
Please note that your supplier, who in such cases works as producer, must have his registration number PT000000 in issued invoices.
If you buy your EEE to a foreign supplier, than you are acting as an importer and consequently have the obligation of register.



20 - I am an EEE reseller. My products are resell under my supplier’s brand name. My supplier doesn’t have the registration number PT000000 in his issued invoices. Who should register: me or my supplier?

A supplier who is placing EEE on Portuguese market (rather national or foreign) has obligation of register.

Therefore, you should request your supplier his registration. Otherwise you both might have some difficulties placing EEE next to your consumers, since your supplier is in an illegal situation towards Portuguese Decree-Law 230/2004.

Since 13th of August of 2005, all company’s invoices and transport documents must be identified with the registration number (PT000000).

If your supplier is a foreign company, without legal representation in Portugal, you are acting as importer. In such case, the obligation of register falls on your company.

Please notice that skipping registration might represent an EEE placement prohibition (Article 26th -5 of Portuguese Decree-Law 230/2004)



21 - My EEE are to be used in industry only. Do I need to register?

The Portuguese Decree-Law 230/2004 do not exclude EEE based in industry use. The only exemption is stated in Category 6 where Industrial, large-scale stationary tools are out of the scope. To meet this condition EEE must simultaneously be a large-scale, stationary and tool used in industry.

Therefore, if EEE functionality is mentioned in Annex I of the Decree-Law, you should register, regardless of EEE’s industrial or household use.



22 - My company’s activity does EEE’s maintenance and sells components and spare parts. Do I need to register?

The strictly maintenance, repair, replacement of parts and components does not require obligation of registering in ANREEE.



23 - What does “placed into the market” mean?

“Placed into the market” refers to the action of making an EEE available, for the first time, into the Portuguese market.
An EEE can be available on the Portuguese market through a sale, leasing, loan, hire, gift, etc.



24 - I know a lot of companies that should be registered and are not. To whom can I complain?

ANREEE has the duty of communicate to government entities about any infraction regarding the Decree-Law.
If you know about any company that should be registered and is not, you should contact ANREEE. Your contact is strictly confidential.




25 - I want to cancel my register. What is the procedure?

If your company is not acting as an EEE producer, you can cancel your register.
To cancel, issue a company stationary letter, dully signed requesting the cancellation.
Only procedures with all obligations towards ANREEE fulfilled can be cancelled.



26 - How much will I pay for my register?

Please consult in our website the box “Prices”.



27 - What are visible fees?

Visible fee is the value of the WEEE management of an EEE.

Only registered producers can show fees visible in their invoices, list of prices, etc.

The value of the visible fee is the cost of weee management you pay to a collective scheme or your own cost if you have an individual scheme.

26 – My imported EEE have already visible fees included. Is this correct?



28 - My imported EEE have already visible fees included. Is this correct?

No. Visible fees are the cost of weee management the producer pays to a collective scheme or its own costs if he has an individual scheme.

If you are importing EEE, you are a producer and therefore you need to have your own collective or individual scheme to take care of this equipment.

Please inform your supplier that no visible fees should be charged, as he is not taking care of the weee in Portugal.



29 - I’m an EEE producer. I’m placing some of my EEE into the Portuguese market and other are send to exportation. Regarding these last ones, should I tax them with fees?

On those EEE destine to exportation, equipment should have exemption fee because WEEE management will not take place in Portugal.
Please contact your collective scheme on this subject.



30 - I resell EEE under my national supplier brand name. Can I charge fees to my costumers?

Only EEE producers are allowed to make visible and charge fees to costumers.

As you are acting as a simple reseller (you sell EEE under your national supplier brand name), you should not make fees visible.



31 - I’m an EEE producer. Can I put fees visible in my invoices?

Yes. EEE producers can, if they want to, put visible fees in invoices, price lists, etc., but only until 13th of February 2011.
For EEE of Category 1 – Large household appliances, this deadline goes to 13th of February 2013.




32 - Why must I pay to two different entities – ANREEE and Collective Schemes (ERP Portugal and AMB3E)?

This is due to the participation of these two entities in the EEE life cycle.

ANREEE and Collective Schemes have different roles in what legislation is concerned and consequently different fee:

a)    ANREEE has an Annual Register Fee, as a result of the activity as register entity. This fee is ANREEE’s unique source of profits and is calculated according to the quantity of EEE placed on the market. Prices are available in this website.
b)    Collective Schemes have their own fees, according to EEE type, which are based on the costs of WEEE management. One fee doesn’t replace the other and producers must pay both.



33 - How much will I pay for my WEEE management?

This is an issue out of ANREEE’s competences. Please consult licensed collective
Schemes ERP Portugal or/and AMB3E.



34 - Where should I deliver my waste?

Concerning the danger they have in their composition, end of life EEE should be properly disposed of, so they have a correct treatment.
We all have a role in the management of these wastes.
Thus, the places where the waste of EEE should be sent are:

    * Replacing the old for a new one: when a consumer buys a new equipment / appliance, he can deliver its old equipment in the store or establishment where the acquisition is carried out. Ex: If you buy a new refrigerator, you can return an old refrigerator.
    * Pick up points: Are collection points for in end of life allocated in places as accessible as large supermarkets and schools, where you can deposit the old EEE.
    * Collection facilities: Places specifically designed to receive this type of product, spread throughout the country. You should check that the reception center closest to your area of residence.

With all these solutions, since there is no excuse to throw in the trash a relevance wrecks. Remember: we are all stakeholders and share responsibility for good environmental performance of Portugal.

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