Who is affected?

• Manufacturers, distributors, importers and online stores - whether based in Portugal or abroad
• Non-resident companies require a local authorized representative

What are the obligations?

From December 31, 2025, manufacturers and importers of furniture and mattresses must comply with the following obligations

• Registration with an authorized take-back scheme
• Data reporting on product types, quantities and, if applicable, material composition
• Recycling & take-back rate:
  • from 2026: at least 25% of products sold must be collected and treated
  • from 2030: quota increases to 40%
• System participation: Establishment or connection to take-back/recycling system
• Labeling: Detailed label specifications to follow

Consequences of non-compliance

• Fines of up to €50,000
• Sales bans
• Responsible: Portuguese environmental authority (APA)

Background & classification

Portugal is following the European trend - comparable systems already exist in France, Belgium (EPR mattress), Hungary, etc.

It is important that affected companies act in good time in order to remain compliant. Our experts are at your disposal to support you in implementing the necessary measures. Make a free inquiry now.

Why the revision?

• Until now, Switzerland has only had a statutory take-back and financing obligation for beverage packaging .
• All other packaging (approx. 75 % of the total volume) is only covered by voluntary or cantonal systems.
• Political initiatives are calling for more recycling, especially of plastic.
• Switzerland wants to align itself with the new EU Packaging Ordinance in order to avoid trade barriers.

Which products are affected?

• Previously: only glass, PET and metal drinks packaging.
• New: all packaging materials - glass, paper/cardboard, metals, plastic, beverage cartons, wood, composites.
• Milk and dairy product packaging is also no longer exempt.

Obligations for companies

With the planned new Swiss Packaging Ordinance (VerpV), companies that manufacture, import or sell packaging in Switzerland will be subject to specific obligations.

1. Adapt packaging

In future, packaging must meet certain basic requirements:

• as little material as necessary (less over-packaging),
• good recyclability,
• the highest possible proportion of recycled material.

Producers may have to make technical changes to their packaging designs in order to meet these requirements.

2. Use or set up take-back systems

For certain packaging (e.g. disposable plastic packaging and beverage cartons), manufacturers/importers/retailers must ensure that it is taken back and recycled.

• This can be done in two ways:
• Setting up their own collection system, or
• Joining an industry organization (e.g. RecyPac) that organizes this centrally.
  
  

3. Submit quantity reports

• Companies must report annually how much packaging (weight, material types) they place on the Swiss market.
• For plastics, a breakdown by polymer type is also required (e.g. PET, PE, PP, PS).
• This data is used to check whether the recycling targets are being met.
  
  

Transitional periods

• Entry into force of the ordinance: 1.1.2027
• Obligation to take back plastic/beverage cartons: 1.1.2028
• Notification obligations: 1.1.2029

With this revision, Switzerland is introducing a nationwide, mandatory EPR regulation for almost all packaging for the first time - similar to the EU. Plastic and beverage carton packaging will be collected separately from 2028, glass fees will be extended, reporting obligations will be introduced and there will be clear basic requirements for all packaging.

Legislation

Some states have additional requirements - especially for primary batteries (e.g. alkaline):

• "Blue states" (e.g. California, New York) require a take-back or recycling obligation for disposable batteries
• Registration possible for primary batteries only in:
  • Illinois
  • District of Columbia (DC)
  • Vermont
• "Green states" essentially follow federal law (only for SSLA/Pb and Ni-Cd)

The obligations

• Registration with an authorized take-back system per company (not per state or battery type)
• Reporting obligations: Quarterly reporting
• System participation: Establishment or connection to take-back/recycling system
• Labeling: Detailed label specifications to follow

Who is obliged?

• The brand owner, i.e. the manufacturer, distributor or importer, is obligated.
• Applies to sales to end customers (B2C) and businesses (B2B).
• No US branch or authorized representative (AAR) required

Sanctions & control

• Currently no legal sanctions or inspections by authorities
• This is a voluntary industry system (self-regulation)

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