Portugal's deposit moves a drinks brand's bottles and cans out of the Ponto Verde fee, and makes PET cheaper and cans about eleven times dearer

Where SIGRE stops and Volta starts

The legal base is one decree-law with two systems in it. Decree-Law 152-D/2017 of 11 December, as republished by Decree-Law 102-D/2020 and in force in that form since 1 July 2021, makes the embalador, the business that packs or has packed its own products or brings packaged goods into Portugal, responsible for its packaging waste. It must either transfer that responsibility to a licensed managing entity by written contract and pay a financial contribution (article 10) or run an authorised individual system backed by a guarantee lodged with APA (article 9) (APA UNILEX manual).

The deposit came in by stages. APA’s May 2026 briefing lists Law 69/2018 of 26 December, which created the incentive scheme for returning drinks packaging as the first amendment to the UNILEX, then Decree-Law 24/2024 of 26 March, which amended the waste regimes, and Decree-Law 34/2024 of 17 May, which changed the licensing regime for the deposit system for non-reusable drinks packaging. SPI has not yet confirmed the article text of the two 2024 decree-laws in the Diário da República, and takes the article numbers of the SDR block, 30.º-B onward, from APA and SDR Portugal documents.

Scope is set by container, not by brand. APA’s FAQ covers non-reusable primary drinks packaging of plastic, ferrous metal and aluminium under 3 litres, for waters, juices and nectars, concentrates, soft drinks, energy and isotonic drinks, beer, cider, sangria and alcoholic mixes. From 12 August 2026, Article 50 of Regulation (EU) 2025/40 brings fresh juice in service packaging and plant-based drinks into scope, takes wine-sector products, spirits under CN 2208 and dairy products out, and limits technical exclusion to containers below 0.1 litres (APA FAQ v2.6). The government’s launch release of 13 April 2026 describes the first phase as plastic and metal packaging up to three litres, while APA, the licence and SDR Portugal say under 3 litres.

Sociedade Ponto Verde's 2026 table, line by line

SPV prices by declared weight, material and flow. Each material has a base value, payable when the pack does not meet every eco-modulation criterion set for that material, and for most materials a bonificado value 10% lower, payable when it does. VAT is added at the legal rate (SPV Tabela VPV 2026). The table first appeared in December 2025 and was reissued in June 2026 with the same values.

Two features shape a drinks brand’s bill. The plastic line is flat: PET, HDPE, PP and film all pay EUR 0.5432 per kg, so resin choice moves the fee only through the 10% bonificado. And the flow matters more than the material: urban plastic costs 106.5 times the non-urban rate, and urban paper 40.3 times. SPV’s guidance ties the fee to the declared weight, the material and whether the waste is urban or non-urban, on a polluter-pays basis (SPV FAQ). SIGRE takes urban-type packaging where the holder produces less than 1,100 litres of waste a day, and larger holders use licensed operators (APA management report 2024).

Billing follows the declarations. For a detailed declaration, SPV’s annual contribution has two parts: an adjustment of the amount invoiced for the previous year, and an estimate for the current year that multiplies the previous year’s declared weights by the current year’s values (SPV, Adira ao Sistema Ponto Verde). The December 2025 edition also sets, in its non-urban section, a minimum annual contribution of EUR 120 for 2026 under the simplified declaration regime, where the calculated amount is lower.

SPV’s activity report for 2025 gives the cost side. Its members paid EUR 98 million more to the municipal, intermunicipal and concession systems in 2025, resale prices for recovered materials fell by about 26%, and SPV estimates its urban recovery rate at 59%, still below the legal target (SPV Relatório de Atividades 2025). The same report links the 2025 revision of the glass and aluminium values to a derogation from those materials’ targets, and says its Pack4Sustain tool is used to check the 2026 eco-modulation criteria.

Three entities, one urban system

SPV is the largest of three SIGRE entities but not the only route. APA’s 2024 management report, version 1.1 of July 2026, records SPV at 80.8% of the 910,801 tonnes declared in SIGRE (Exhibit 5). SPV’s licence, granted on 28 June 2024 and amended on 21 January 2026, runs to 31 December 2034 and adds tea, coffee and other drink pods and capsules to its scope from 12 August 2026; its 2025 to 2029 targets are 65% overall recycling and 50% for plastic (APA, primeira alteração à licença SPV).

Novo Verde’s table shows how fast rates can move inside one year. Its urban plastic base was EUR 0.46734 per kg from 1 January, EUR 0.51408 from 22 February and EUR 0.59261 from 1 August 2026, and its aluminium base fell from EUR 0.08242 to EUR 0.06052 on 1 August (Novo Verde, update of 1 July 2026). Electrão’s standard scheme table, dated 23 January 2026, changes rates from 8 February 2026, and its small-member regime charges a flat EUR 125 a year plus VAT for members placing under 1,000 kg.

SDR Portugal's fees and the deposit

The SDR charges two things, and only one of them is a cost. The deposit of EUR 0.10 per container is charged by the packer, shown separately on each invoice down the chain, refunded in full to the consumer for an intact container with a readable barcode, and is not subject to VAT (APA FAQ v2.6, answers B17 and C1). SDR Portugal invoices packers monthly for the deposits on units they report (SDR Portugal Manual do Embalador). The financial contribution, the prestação financeira, is the cost: SDR Portugal publishes its 2026 values per unit placed on the market, in three recyclability lists (Exhibit 6).

The licence sets how those values are made. The consolidated licence of 20 November 2024 requires a calculation model for the whole licence period, approved by the economy directorate with APA informed, effective from 1 January 2026; any update with a cumulative change above 10% must show economic balance (APA, licença consolidada SDR). The first amendment of 27 March 2026, signed by APA and the Director-General for the Economy, requires approved values to be published within three days and given to members at least 30 days before they apply, with bonuses shown separately.

Payment runs on its own calendar. SDR Portugal invoices the financial contribution in four equal quarterly instalments, estimated in year one from the initial declaration and from year two from the previous year’s annual declaration, with a reconciliation for the prior year (SDR Portugal Manual do Embalador). Packers file an annual declaration by 15 March, register each packaging reference at least 30 days before sale, pay a registration value per new reference, and owe compensation plus a penalty if returns exceed the units declared. SPI has not yet confirmed the 2026 registration value per reference.

The deposit amount itself has a gap in the paper trail. SDR Portugal’s 2025 manual said the order fixing the deposit was awaiting publication, and SPI has not yet confirmed the despacho that sets EUR 0.10 in the Diário da República. The amount is stated by APA, the government and SDR Portugal.

The legal path and the start date

APA’s FAQ states the start in plain terms: the SDR began operating in Portugal on 10 April 2026, across the whole country, with a transition period until 9 August 2026, and only containers with the Volta symbol are refundable (APA FAQ v2.6, answer B2). APA’s Circular 01/2026/DFEMR gives 10 April 2026 as the planned start and a 120-day transition: 60 days for producers and packers, 90 for distributors and wholesalers and 120 for retail and hospitality. SPI has not yet confirmed a Diário da República text that fixes 10 April 2026; the licence amendment of 27 March 2026 says only that the system starts in April 2026, and makes the packer contracts effective from the date it starts operating.

The targets were reset for the late start. The consolidated licence set collection targets of 70% for 2026, 80% for 2027, 85% for 2028 and 90% from 2029 to 2034, for the total and for each of plastic, ferrous metal and aluminium, by weight placed on the market. The March 2026 amendment cut the 2026 figure to 40% because the system started only in April, leaving the later years unchanged (APA, primeiro aditamento SDR).

How containers leave the fee base

The exit has three steps, and they run on different clocks. First, the register: APA’s FAQ tells packers to update their entry on the SILiAMB portal, disassociating the packaging from SIGRE and enrolling it under SDR Portugal, with an adhesion date no earlier than 10 April 2026 that matches the contract change made with the SIGRE entity (APA FAQ v2.6, answer C3). Second, the entity: SPV’s FAQ says single-use plastic drinks bottles under three litres stop being declared to SPV and are declared to the SDR entity once the SDR is operating. Third, the annual data in APA’s register (Exhibit 8).

The timing creates a 2026 overlap. Because SPV’s current-year estimate rests on the previous year’s declared weights, a brand’s 2026 SPV invoice was built on 2025 weights that still included its PET bottles and cans, while SDR Portugal’s fees began with the system. SPI calculation: if the example brand’s units are spread evenly through the year, the 99 days to 9 April keep EUR 36,204.22 of SPV fees on its deposit containers and the 266 days from 10 April carry EUR 98,543.89 of SDR fees. The 2026 correction is where any SPV overpayment should come back; SPI has not yet confirmed how each SIGRE entity credits it.

Pre-deposit stock had its own end. After the transition, packers and importers may not donate, offer or otherwise make non-SDR drinks packaging available on the national market, and may only use it internally or export it; stock whose packaging responsibility was transferred to SIGRE may still be sold to final consumers (APA Circular 01/2026/DFEMR, updated 24 July 2026).

Four kinds of drinks pack in Portugal

SPI groups a drinks brand’s packaging into four archetypes by which system charges it and what moves the charge (Exhibit 9). The device is drawn from APA’s scope rules and the two 2026 tables, and it tells a packaging team where each design or sourcing decision lands.

Archetype A rewards fewer, larger units and green-list design. A 1.5 litre PET bottle pays the same EUR 0.01012 as a 500 ml one, and lightweighting a bottle saves nothing in SDR fees. Moving a can from the red to the green list saves EUR 0.00171 per unit.

Archetype B rewards weight and criteria. A 190 g glass bottle costs EUR 0.0165 at the SPV base and EUR 0.0148 at the bonificado value, and in the worked example below glass is the largest SIGRE line by weight.

Archetype C is the easiest to miss. Article 50(4) took wine-sector products, spirits under CN 2208 and dairy products out of the SDR on 12 August 2026, and drinks with more than 25% dairy ingredients were outside the licence from the start (APA FAQ v2.6; APA, licença consolidada SDR). A sangria or spirit-based mix in a can therefore needs its route checked with SDR Portugal and its SIGRE entity.

Archetype D is a classification question. SPV’s guidance charges by the flow in which the waste arises, and the gap between urban and non-urban plastic is EUR 0.5432 against EUR 0.0051 per kg, so the brand should agree with its SIGRE entity which grouping and transit items reach households.

Worked example: one drinks brand, two systems

SPI priced a hypothetical Portuguese soft drinks packer that places 10 million 500 ml PET bottles, 6 million 330 ml aluminium cans and 176 tonnes of other packaging a year (Exhibit 10). Unit counts and weights are SPI assumptions for illustration, not industry averages; container weights include cap and label. Rates are SPV’s 2026 urban and non-urban base values and SDR Portugal’s 2026 green list. Everything is in euros, excluding VAT.

SPI calculation: before the move, the SPV bill is 240,000 x 0.5432 + 78,000 x 0.0399 + 95,000 x 0.0868 + 1,000 x 0.5219 + 20,000 x 0.3104 + 15,000 x 0.5432 + 40,000 x 0.0077 + 5,000 x 0.0051 = EUR 156,937.60. After it, SDR fees are 10,000,000 x 0.01012 + 6,000,000 x 0.00567 = EUR 135,220.00 and the SPV bill on the remaining lines is EUR 23,457.40, a combined EUR 158,677.40. The PET line saves EUR 29,168.00 and the can line costs EUR 30,907.80 more, a net rise of EUR 1,739.80, or 1.1%.

The deposit sits on top as cash rather than cost. The brand charges its customers 16,000,000 x 0.10 = EUR 1,600,000 in deposits a year and pays the same amount to SDR Portugal on its monthly invoice, so the cost is the timing gap between the two. SPI has not yet confirmed how SDR Portugal accounts for deposits that are never redeemed, which the deposit return piece compares across European schemes.

Scenarios: how the bill moves

SPI ran three cases on the example portfolio, in euros only (Exhibit 11). Low puts the containers on the green list and every remaining SIGRE line that has one at SPV’s bonificado value. Base is Exhibit 10. High puts the containers on the red list and keeps SPV base values. A separate lightweighting case shows what a 20 g PET bottle would have saved under SPV and saves under the SDR.

The list matters most. A move from green to red adds EUR 40,660 a year on 16 million containers, while meeting every SPV criterion on the remaining lines saves EUR 2,295.50. Lightweighting the PET bottle from 24 g to 20 g would have cut SPV’s PET line from EUR 130,368.00 to EUR 108,640.00; under the SDR the fee stays EUR 101,200.00 whatever the bottle weighs.

On the volume side, each extra million green-list PET bottles adds EUR 10,120 and each extra million cans EUR 5,670. SPI analysis: for a brand choosing a format for a new 330 ml line, a green-list can now costs EUR 0.00445 less per unit in fees than a green-list PET bottle, the reverse of the SPV position, where a 13 g can cost EUR 0.00052 and a 24 g bottle EUR 0.01304.

The gaps in this view

The legal texts. SPI has not yet confirmed the article text of Decree-Laws 24/2024 and 34/2024, or the despacho fixing the EUR 0.10 deposit, in the Diário da República. This article relies on APA’s FAQ, circular, licence documents and briefing for those points.

Caps, labels and the 2026 credit. SPI has not yet confirmed whether SPV expects caps and labels on Volta containers to leave its declaration with them, or how each SIGRE entity credits 2026 fees on units corrected out.

Electrão’s urban lines. SPI has not yet confirmed Electrão’s 2026 urban-flow values by material, so Exhibit 5 shows only its small-member fee.

Scope of the example. The portfolio, weights and flows are SPI assumptions. SDR Portugal’s registration value, penalties and guarantees, and any SPV minimum, are left out.