COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review Country Report - PORTUGAL Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Environmental Implementation Review for prosperity and security
Date: 2025-07-07
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Portugal, application of EU law, biodiversity, circular economy, climate change policy, environmental law, governance, pollution control measures, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 7.7.2025  SWD(2025) 321 final  COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review        Country Report - PORTUGAL               Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Environmental Implementation Review for prosperity and security {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 302 final} - {SWD(2025) 303 final} - {SWD(2025) 304 final} - {SWD(2025) 305 final} - {SWD(2025) 306 final} - {SWD(2025) 307 final} - {SWD(2025) 308 final} - {SWD(2025) 309 final} - {SWD(2025) 310 final} - {SWD(2025) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 319 final} - {SWD(2025) 320 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}  
 
 
Portugal  2 

Contents 

EXECUTIVE SUMMARY ........................................................................................................................................... 3 

PART I: THEMATIC AREAS ...................................................................................................................................... 4 

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ....................................................................................................... 4 
Transitioning to a circular economy ..................................................................................................................... 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL .................................................................................................................... 14 
Global and EU biodiversity frameworks ............................................................................................................. 14 
Nature protection and restoration – Natura 2000 ............................................................................................. 15 
Recovery of species ............................................................................................................................................ 16 
Recovery of ecosystems ..................................................................................................................................... 18 
Prevention and management of invasive alien species ...................................................................................... 22 
Ecosystem assessment and accounting ............................................................................................................. 23 
3. ZERO POLLUTION .............................................................................................................................................. 25 
Clean air ............................................................................................................................................................. 25 
Industrial emissions ............................................................................................................................................ 26 
Major industrial accidents prevention – Seveso ................................................................................................. 29 
Mercury Regulation ............................................................................................................................................ 30 
Noise .................................................................................................................................................................. 31 
Water quality and management ........................................................................................................................ 31 
Chemicals ........................................................................................................................................................... 35 
4. CLIMATE ACTION .............................................................................................................................................. 38 
The EU emissions trading system ....................................................................................................................... 39 
Effort sharing ..................................................................................................................................................... 39 
Land use, land use change and forestry ............................................................................................................. 40 
Adaptation to climate change ............................................................................................................................ 40 

PART II: ENABLING FRAMEWORK – IMPLEMENTATION TOOLS ............................................................................ 41 

5. FINANCING ...................................................................................................................................................... 41 
Climate finance landmarks ................................................................................................................................. 41 
Environmental financing and investments ......................................................................................................... 41 
Public financial management ............................................................................................................................. 46 
6. ENVIRONMENTAL GOVERNANCE ........................................................................................................................... 50 
Information, public participation and access to justice...................................................................................... 50 
Compliance assurance ........................................................................................................................................ 52 
EU-supported environmental capacity building ................................................................................................. 55 

2025 Environmental Implementation Review – Portugal 

 
 
 
Portugal  3 

Executive summary 

In  May  2016,  the  European  Commission  launched  the 
Environmental  Implementation  Review  (EIR),  a  regular 
reporting 
tool  based  on  analysis,  dialogue  and 
collaboration  with  EU  Member  States  to  improve  the 
implementation  of  existing  EU  environmental  policy  and 
legislation (1). Following previous cycles in 2017, 2019 and 
2022,  this  report  assesses  the  progress  made  while 
the  main  outstanding  challenges  and 
describing 
opportunities 
legal 
implementation in Portugal. The purpose of this report is 
to  provide 
implementation 
performance  and  highlight  the  most  effective  ways  to 
address  the  implementation  gaps  that  impact  human 
health  and  the  environment  and  hamper  the  economic 
development  and  competitiveness  of  the  country.  The 
report relies on detailed sectoral implementation reports 
collected  or  issued  by  the  Commission  under  specific 
environmental legislation. 

information  on 

environmental 

regarding 

the 

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  taking  into 
consideration 
factors  such  as  the  gravity  of  the 
environmental implementation issue in light of the impact 
on the quality of life of citizens, the distance to target and 
financial  implications.  In  Portugal  such  challenges  have 
been  lingering  since  the  first  EIR  in  2017  and  require 
urgent action. 

Despite progress made, Portugal needs further efforts on 
improving  waste  management  and  developing  the 
potential  of  the  circular  economy.  Portugal  adopted  a 
national Circular Economy Action Plan in 2017, and a new 
one is still under preparation. New national legislation on 
waste  management  was  approved  in  2020.  The  new 
national  waste  management  plan  (PNGR  2030)  and  the 
plans for municipal and non-municipal waste (PERSU 2030 
and PERNU 2030)  were  adopted in 2023.  Moreover, the 
new  regional  waste  management  plans  for  Madeira  and 
Azores  were  adopted,  in  2021  and  2023,  respectively. 
Portugal  missed  the  EU  target  of  recycling  50 %  of 
municipal waste by 2020 and it is  at high risk of missing 
the new EU waste targets for 2025. 

Portugal  has  a  rich  biodiversity.  21.2 %  of  its  territory 
belongs to the EU Natura 2000 network (the EU average is 
18.6 %). However, some species and habitats, particularly 
in the marine environment, are not sufficiently protected. 
Portugal has recently approved additional designations for 
marine  sites.  Furthermore,  Portugal  needs  to  adopt 
management  plans  for  the  sites  already  designated, 

(1) 

from 

the  Commission 

the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Delivering  the 
benefits  of  EU  environmental  policies  through  a  regular 

to 

identifying  the  site-specific  conservation  objectives  and 
measures  and  providing  the  necessary  technical,  human 
and financial resources. 

remain 

Despite  the  progress  that  Portugal  has  made  in  recent 
years,  challenges 
in  water  management, 
especially  in  the  areas  of  water  governance,  waterbody 
rehabilitation and water efficiency. Further infrastructure 
investment  is  needed  to  improve  water  management, 
such as in wastewater collection and treatment, reducing 
leaks  in  the  networks  and  general  water  supply  and 
improving  monitoring  (quality  and  quantity),  as  well  as 
adopting  nature-based  solutions  and  undertaking  river 
restoration. Moreover, Portugal should take advantage of 
the  potential  of  water  reuse.  Portugal  adopted  in  2024, 
following  a  certain  delay,  the  third  cycle  of  River  Basin 
Management Plans under the Water Framework Directive. 
Portugal also approved in 2024 the PENSAARP 2030, a new 
national strategic Plan for water supply, wastewater and 
pluvial waters management. Portugal has also presented 
in March 2025 a far-reaching national strategy on water. 

Anticipating and adapting to the adverse effects of climate 
change,  such  as  floods,  coastal  erosion,  droughts,  heat 
waves  and  forest  fires,  remains  a  core  challenge  in 
Portugal. In addition, sustainable development could be 
further mainstreamed into other policy areas. 

The support of EU funding has significantly contributed to 
improving  the  implementation  of  EU  environmental  law 
and  policy  in  Portugal.  Nevertheless,  Portugal  still  faces 
considerable  environmental  challenges  and  investment 
needs. To meet the four environmental objectives beyond 
climate change, the additional investment need over the 
current  levels  (the  investment  gap)  is  estimated  at 
EUR 1.6 billion  per  year,  representing  around  0.65 %  of 
gross  domestic  product,  which  is  lower  than  the  EU 
average (0.77 %), with the highest shares for biodiversity 
and ecosystems. EU financing will continue to play a key 
role  in  addressing  the  shortcomings  and  closing  the 
investment gaps. 

In terms of good practices by Portugal, in addition to those 
mentioned  in  previous  EIRs,  it  can  be  highlighted  the 
improve  forest  management, 
measures  adopted  to 
including  fighting  forest  fires.  It  is  also  outstanding  the 
high  share  of  agricultural  land  under  organic  farming. 
Moreover,  in  the  field  of  environmental  governance, 
Portugal  has  continued  adopting  measures  to  improve 
access  to  justice  and  compliance  assurance,  including 
compliance promotion and inspections. 

implementation  review,  COM(2016) 316 
environmental 
final  of  27 May  2016,  http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN. 

2025 Environmental Implementation Review – Portugal 

 
 
Portugal  4 

Part I: Thematic areas 

1. Circular economy and waste management 

Transitioning to a circular economy 

Figure 1: CMUR (%), 2013–2023 

Advancing the transition to a circular economy in the EU 
will reduce the environmental and climate impact of our 
industrial  systems  by  reducing  input  materials,  keeping 
products and materials in the loop for longer and reducing 
waste generation, thus decoupling economic growth from 
resource 
circular  economy  has 
considerable  potential  to  increase  competitiveness  and 
job creation and will also promote innovation and provide 
access to new markets. With the 2020 circular  economy 
action  plan  (CEAP) (2)  going  through  the 
legislative 
process, Member States will now have to focus on a swift 
and effective implementation. 

consumption.  A 

The 2020 CEAP launched the legislative process for a set 
of  initiatives  that  will  now  have  to  be  implemented  by 
national  governments  across  the  EU.  These  initiatives 
were all introduced following a holistic life-cycle approach, 
with  measures  addressing  the  different  stages  of  a 
product’s life cycle, from design through use to end of life. 

In the CEAP, the EU sets as its overarching objective the 
doubling of its circular material use rate (CMUR) by 2030. 

The CMUR is a  measure of one aspect of  circularity: the 
share of the total amount of material used in the economy 
that is accounted for by recycled waste. A higher CMUR 
value means that more secondary materials were used as 
a  substitute  for  raw  materials,  thus  reducing  the 
environmental impacts of extracting primary material. 

Portugal’s  circular  use  of  materials  has  been  relatively 
steady since 2013, with a small increase since 2017. With 
a rate of 2.8 % in 2023, it is well below the EU average of 
11.8 % (Figure 1). 

14
12
10
8
6
4
2
0

2013

2015

2017

2019

2021

2023

Portugal

EU-27

Source: Eurostat, ‘Circular material use rate’, env_ac_cur,  last updated 
13 November 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_cur. 

10 December 

2024, 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic product (GDP). Improving resource productivity 
can help to minimise negative impacts on the environment 
and reduce dependency on volatile raw material markets. 
In 2023, Portugal generated EUR 1.26 per kg of material, 
against the EU average of EUR 2.23 (Figure 2). 

Figure 2: Resource productivity (EUR/kg), 2013–2023 

2,5

2,0

1,5

1,0

0,5

0,0

2013

2015

2017

2019

2021

2023

Portugal

EU-27

NB: The unit of measurement used is EUR/kg chain-linked volume (2015). 
Chain-linked  volumes  focus  on  changes  on  quantities  and  prices  of 
commodities  in  previous  years,  taking  account  of  inflation,  and  are 
indexed to the nearest appropriate year, in this case 2015. 

(2) 

from 

the  Commission 

the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  A  new  circular 
economy action plan for a cleaner and more competitive Europe, 

to 

COM(2020) 98 
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A98%3AFIN. 

11 March 

2020, 

final 

of 

https://eur-

2025 Environmental Implementation Review – Portugal 

 
 
 
 
 
 
Source:  Eurostat,  ‘Resource  productivity’,  env_ac_rp,  last  updated 
7 August 
2024, 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_rp. 

10 December 

accessed 

2024, 

Policies and measures 

In  parallel  with  European  initiatives  under  the  CEAP, 
Member States are encouraged to adopt and implement 
circular strategies at the national, regional and city levels. 
These should be tailored to each national and local reality, 
to  harness  the  proximity  economy’s (3)  potential,  while 
following  the  principles  of  a  holistic  whole-value-chain 
approach. 

Since the launch of the online European Circular Economy 
Stakeholder  Platform  in  2017 (4)  national,  regional  and 
local  authorities  have  used  the  platform  to  share  their 
strategies,  roadmaps,  and  good  practices,  for  example 
alternative business models and innovative technologies. 

Portugal  is  set  to  adopt  a  new  Circular  Economy  Action 
Plan for 2024–2030 (2030 CEAP). The Action Plan will have 
as main objectives those of avoiding the over-exploitation 
of  non-renewable  sources,  reducing  waste  generation, 
preventing  pollution,  raising  awareness  and  creating 
socio-economic benefits. 

The proposal for the new Action Plan for 2030 includes a 
set  of  indicators  that  aim  to  monitor  and  assess  the 
transition  to  a  circular  economy.  This  set  of  indicators 
impact,  namely  resources, 
considers  four  areas  of 
environment,  economy  and  society.  It  is  set  to  include 
measures  at  three  levels:  macro,  meso  and  micro.  This 
mirrors  the  approach  of  the  previous  Portuguese  Action 
Plan.  The  macro  level  includes  transversal  initiatives 
applicable  to  all  sectors  and  regions,  whereas  the  meso 
level includes  measures targeted at priority sectors, and 
the micro level aims to stimulate strategies at the regional 
and local levels. 

The  upcoming  2030  CEAP  is  set  to  replace  the  2017 
CEAP (5),  which  was  reviewed  in  2019  and  extended  to 
2021. According to an evaluation published in 2021 (6), of 
the  57  guidelines  recommended,  44  were  addressed 
(about  77 %  of  cases).  Action 1 –  Design,  repair,  reuse: 
extended producer responsibility – was the one in which a 
lower percentage of guidelines was implemented (50 %), 

(3) 

(4) 

(5) 

(6) 

website, 

Economy 

Stakeholder 

Commission 

European Commission, ‘Proximity and social economy ecosystem’, 
European 
https://single-market-
economy.ec.europa.eu/sectors/proximity-and-social-
economy_en. 
Circular 
(https://circulareconomy.europa.eu/platform/en/strategies). 
APA,  ‘Action  plan  for  a  circular  economy’  (in  Portuguese),  APA 
website, https://apambiente.pt/apa/economia-circular. 
APA, Balanço das Atividades do PAEC e dos resultados alcançados 
entre  2018  e  2020  Coordenação  [Evaluation  of  PAEC´s  Activities 
and  Results  Achieved  between  2018  and  2020],  2022, 
https://apambiente.pt/sites/default/files/_SNIAMB_A_APA/Inici
ativas_transectoriais/PAEC_RelatorioFinal.pdf. 

Platform 

Portugal  5 

while  Action 7 –  Investigate  and  innovate  for  a  circular 
economy –  was  the  only  one  in  which  all  the  guidelines 
were addressed. 

Four  economic  sectors  were  considered  strategic  in  the 
2017  CEAP,  namely  construction,  food  and  agriculture, 
tourism  and  textiles.  The  plan  also  had  a  regional 
dimension to complement EU and national measures. 

InC2 –  the  National  Circular  Cities 
The  Programme 
Initiative of the Portuguese Ministry for Environment and 
Climate Action – implements the objective of the national 
CEAP  to  develop  circular  cities.  Four  Circular  Cities 
Networks  (RC2)  were  developed,  each  focusing  on  a 
specific priority theme and addressing one or more of the 
defined transversal themes. Between 2019 and 2023, 28 
Portuguese municipalities participated in the initiative. 

The  2022  Environmental  Implementation  Review  (EIR) 
also  highlighted,  as  good  practices,  several  initiatives  in 
Portugal  to  support  the  circular  economy  in  certain 
economic sectors. 

It is worth recalling that there are measures promoting the 
circular  economy  in  Component 12  on  Bio-economy  of 
Portugal’s Recovery and Resilience Plan (RRP) (7). 

Portugal’s  National  Energy  and  Climate  Plan  (NECP) (8) 
clearly  links  climate  action  to  the  circular  economy, 
because of the potential of circularity for making progress 
towards climate neutrality and territorial cohesion. 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
authorities’ 
consumption,  with  public 
European 
purchasing  power  representing  around  14 %  of  EU  GDP. 
Public  procurement  using  green  or  circular  criteria  (life-
cycle analysis, PaaS (platform as a service), second hand) 
can help drive the demand for sustainable products that 
meet reparability and recyclability standards. 

As announced in the 2022 EIR, a new national strategy on 
green  public  procurement  (GPP)  has  been  adopted  in 
2023.  This  is  also  a  reform  under  Component 12  of 
Portugal’s  RRP.  The  National  Strategy  for  Green  Public 
Procurement –  ECO360 –  approved  by  Resolution  of  the 
Council  of  Ministers  No 13/2023,  defines  the  vision, 

(7) 

(8) 

European  Commission,  ‘Portugal’s  recovery  and  resilience  plan’, 
European 
website, 
Commission 
https://commission.europa.eu/business-economy-
euro/economic-recovery/recovery-and-resilience-
facility/country-pages/portugals-recovery-and-resilience-
plan_en.  
European  Commission,  ‘National  energy  and  climate  plans’, 
European 
website, 
Commission 
https://commission.europa.eu/energy-climate-change-
environment/implementation-eu-countries/energy-and-climate-
governance-and-reporting/national-energy-and-climate-
plans_en. 

2025 Environmental Implementation Review – Portugal 

 
 
objectives  and  main  vectors  of  action  for  green  public 
procurement in Portugal. This instrument plays a strategic 
role in the pursuit of the sustainable development of the 
Portuguese  economy.  One  of  the  objectives  of  this 
strategy  is  to  promote  resource  efficiency,  a  sustainable 
bioeconomy  and  the  transition  to  a  circular  economy 
through:  (i)  the  adoption  of  circularity  criteria  and 
products  from  the  sustainable  bioeconomy  in  public 
procurement,  (ii)  the  stimulation  of  the  development  of 
new circular products, services and business models and 
(iii) the promotion of efficiency in the use of resources and 
retention  of  the  value  of  materials.  For  each  strategic 
objective,  goals  and  indicators  are  defined.  Actions  and 
measures  are  detailed  in  the  Action  Plan  adopted  in 
October  2024  through  Resolution  of  the  Council  of 
Ministers No 162/2024. 

Resolution  of  the  Council  of  Ministers  No 132/2023 
defined the green criteria applicable to the conclusion of 
contracts  by  entities  in  the  direct  and  indirect  public 
administration  for  16  product  groups,  such  as  paper 
products;  furniture;  textiles;  catering  services;  copying 
and printing services and equipment; acquisition or rental 
of computer equipment; and public works contracts. For 
each  product 
voluntary  and 
group  mandatory, 
recommended criteria were established. 

The  EU  Ecolabel  and  the  eco-management  and  audit 
scheme 

The  number  of  EU  Ecolabel (9)  product  groups  and  the 
number  of  eco-management  and  audit  scheme (10) 
(EMAS)-licensed  organisations  in  each  country  provide 
some indication of the extent to which the private sector 
and  national  stakeholders  in  that  country  are  actively 
engaged  in  the  transition  to a  circular  economy.  The  EU 
is  awarded  to  products  with  best-in-class 
Ecolabel 
is  a  voluntary 
environmental  performance.  EMAS 
environment management scheme aimed at reducing the 
environmental impacts of organisations. 

By September 2024, Portugal had 6 950 products, a lot of 
them in the textile category, and 34 licences out of 98 977 
products and 2 983 licences registered in the EU Ecolabel 
scheme.  Moreover,  in  October  2024,  44  organisations 
from  Portugal  were  registered  in  EMAS,  3  fewer  than  in 
October 2021. 

It is also worth mentioning that the city of Guimarães has 
been designated as European Green Capital for 2026 (11). 

(9) 

(10) 

European Commission, ‘EU Ecolabel facts and figures’, European 
Commission 
website, 
https://environment.ec.europa.eu/topics/circular-economy/eu-
ecolabel/businesses/ecolabel-facts-and-figures_en.  
EMAS  is  a  European  Commission  programme  to  encourage 
organisations  to  behave  in  a  more  environmentally  sustainable 
way (https://green-business.ec.europa.eu/emas_en). 

Portugal  6 

The  CMUR of Portugal had decreased by 0.5 percentage 
points in 2023, remaining one of the lowest in the EU. This 
does not represent any progress towards the 2022 priority 
action to take measures to increase the rate. 

While Portugal has a strong policy basis for the transition 
to a circular economy, progress has not been made on the 
2022 priority action, suggesting the need to put in place 
an updated national action plan. 

2025 priority actions 

•  Adopt measures to increase the circular material use 

• 

rate. 
Speed  up  the  transition  to  a  circular  economy  by 
implementing  an  updated  national  strategy  and  the 
EU framework and recommendations, in particular to 
complement it with upstream circularity measures. 

Waste management 

Turning waste into a resource is supported by: 

(i)  addressing  the  full  life  cycle  of  products,  from 
conception to end of life, by setting requirements on 
the design of products to ensure that they are more 
sustainable; 

(ii)  fully 

implementing  EU  waste 

legislation,  which 
includes the waste hierarchy, the obligation to ensure 
separate collection of waste, landfill diversion targets, 
etc.; 

(iii)  reducing waste generation per capita and in absolute 

terms; 

(iv)  increasing  the  recycling  rates  of  waste  containing 
critical raw materials (CRMs), with a view to reducing 
dependencies and building resilient value chains, and 
stimulating  demand  for  recycled  content 
in  all 
products; 
limiting energy recovery to non-recyclable materials; 
and 

(v) 

(vi)  phasing  out  landfilling  of  recyclable  or  recoverable 

waste. 

One of the main objectives of EU waste Law is to decouple 
economic growth from its environmental impacts.  

The EU’s approach to waste management is based on the 
waste  treatment  hierarchy:  prevention,  preparing  for 
reuse,  recycling,  recovery  and,  as  the  least  preferred 

(11) 

European  Commission,  European  Green  Capital  Award, 
https://environment.ec.europa.eu/topics/urban-
environment/european-green-capital-award/winning-
cities/guimaraes-  

2025 Environmental Implementation Review – Portugal 

 
 
includes 
option,  disposal 
incineration without energy recovery). 

(which 

landfilling  and 

CRMs  ending  up  as  waste.  It  also  looks  at  options  for 
substituting CRMs with non-critical materials. 

Portugal  7 

All legislative proposals in the field of waste management 
put forward by the Commission since 2021 are intended 
to encourage Member States to promote better product 
design,  to  require  producers  to  cover  the  costs  of 
managing the waste resulting from their products and to 
ensure that waste is managed at the higher levels of the 
waste hierarchy. 

The  total  amount  of  waste  generated  in  Portugal  has 
increased over the last 12 years (Figure 3). 

Figure 3: Generation of waste (total and excluding major 
mineral wastes), population and GDP, 2010–2022 

Source: Eurostat, ‘GDP and main components (output, expenditure and 
income)’, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__cust
om_9301905/default/table. 

nama_10_gdp, 

15 October 

accessed 

This trend is mainly driven by the significant increase in the 
large waste categories: mixed waste and recyclable waste. 
Excluding  major  mineral  wastes  does  not  strongly  affect 
the overall trend. However, a notable increase in 2022 was 
caused  by  a  doubling  of  the  amounts  of  mineral  and 
solidified waste, mainly due to a strong increase in soil and 
dredging spoils. Overall, Portugal’s GDP increased over the 
period covered with a small drop in 2020, most likely due 
to the COVID-19 outbreak. In general, it seems that there 
has  been  no  decoupling  of  waste  generation  from 
economic growth. 

Critical raw materials 

The  eMaPriCE  project  on  the  management  of  waste 
containing  CRMs  was  developed  during  2021/2022  with 
the 
for 
identifying 
implementing  circular  economy  strategies  to  prevent 

opportunities 

objective 

of 

(12) 

(13) 

European 

European  Commission:  Joint  Research  Centre,  Techno-economic 
and  environmental  assessment  of  construction  and  demolition 
waste management in the European Union, Publications Office of 
the 
2024, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC1354
70. 
European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  EU  Construction  & 
Demolition Waste Management Protocol including guidelines for 

Luxembourg, 

Union, 

Portugal’s  upcoming  2030  CEAP  includes  measures  to 
promote the use of recycled materials over raw material 
extraction.  A  key  action  proposed  is  to  study  potential 
policies  and  financial  incentives  that  favour  recycled 
content and reduce reliance on CRMs. 

The 2030 national waste management plan supports the 
CEAP’s  implementation,  aiming  to  reintegrate  materials 
into the economy, covering areas like food, construction, 
plastics,  textiles  and  CRMs.  Furthermore,  the  2030 
Strategic Plan for Urban Waste (plano estratégico para os 
resíduos  urbanos  (PERSU  2030)  outlines  strategies  to 
prevent  CRMs  from  becoming  waste  and  explores  their 
substitution with non-critical materials. 

Construction and demolition waste 

Construction  and  demolition  waste  accounts  for  almost 
40 % of all waste generated in the EU. A study (12) by the 
Joint Research Centre (JRC) shows that preparing for reuse 
and  recycling  operations  are  preferred  over  incineration 
and  landfilling  from  an  environmental  perspective  for 
most  of  the  individual  fractions  of  construction  and 
demolition waste. However, the economics often  do not 
favour preparing for reuse and recycling over incineration 
and landfilling. If available technology  was adopted, it is 
estimated  that  the  increase  in  preparing  for  reuse  and 
recycling  would  lead  to  an  additional  saving  of  33 Mt  of 
greenhouse gas (GHG) emissions annually (more than, for 
example, the combined annual GHG emissions of Estonia, 
Latvia and Luxembourg). 

The  rate  of  preparing  for  reuse  and  recycling  of  mineral 
construction and demolition waste in Portugal in 2022 was 
42.6 %  compared  with  the  EU  average  of  79.8 %. 
Measures  to  further  increase  the  rate  of  preparing  for 
reuse and recycling of construction and demolition waste 
include separate collection at source, for instance through 
digitalised pre-demolition audits (13) (known as ‘resource 
assessments’) and other economic instruments as well as 
upstream  measures  such  as  increasing  the  recycled 
content 
in  construction  products  and  the  circular 
design (14) of construction works. 

pre-demolition and pre-renovation audits of construction works – 
Updated edition 2024, Publications Office of the European Union, 
Luxembourg,  2024,  https://op.europa.eu/en/publication-detail/-
/publication/d63d5a8f-64e8-11ef-a8ba-01aa75ed71a1/language-
en. 
European Commission, Circular Economy – Principles for building 
design, 
2020, 
Brussels, 
https://ec.europa.eu/docsroom/documents/39984. 

(14) 

2025 Environmental Implementation Review – Portugal 

 
 
 
Boosting 
Warning Report 

implementation –  the  2023  Waste  Early 

 Member states at risk for both targets 
 Outside coverage 

Portugal  8 

This  section  focuses  on  the  management  of  municipal 
law  sets  mandatory  recycling 
waste,  for  which  EU 
targets (15). It is worth recalling that Portugal is one of the 
countries  that  missed the  EU  target  of  recycling  50 %  of 
municipal waste by 2020. 

In June 2023, the Commission published the Waste Early 
Warning Report (16) identifying the general trends in waste 
management  and  the  Member  States  at  risk  of  missing 
2025 waste targets (see Figure 4). 

Portugal is in the category of countries at risk of missing 
the municipal waste targets. Portugal is also at risk of not 
meeting  the  2035  target  of  a  maximum  of  10 %  of 
municipal waste landfilled. 

Figure 4:  Member  States’  prospects  of  meeting  the 
preparing  for  reuse  and  recycling  targets  for  municipal 
waste and packaging waste 

 Member  States  not  at  risk  of  missing  both  the  55 % 
preparing  for  reuse  and  recycling  target  for  municipal 
waste, and the 65 % packaging waste recycling target 

 Member States at risk for the municipal waste preparing 
for  reuse  and  recycling  target  but  not  at  risk  for  all 
packaging waste recycling target  

(15)  Municipal  waste  consists  of  (i)  mixed  waste  and  separately 
collected waste from households, including paper and cardboard, 
glass, metals, plastics, biowaste, wood, textiles, packaging, waste 
electrical  and  electronic  equipment,  waste  batteries  and 
accumulators,  and  bulky  waste, 
including  mattresses  and 
furniture;  and  (ii)  mixed  waste  and  separately  collected  waste 
from  other  sources,  where  such  waste  is  similar  in  nature  and 
composition  to  waste  from  households  (Directive  2008/98/EC, 
Article 3.2(b)).  
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en. 

(16) 

Source: European Environment Agency (EEA), ‘Many EU Member States 
not on track to meet recycling targets for municipal waste and packaging 
waste’, briefing No 28/2022, Copenhagen, 2023. Reference data © ESRI. 

Under  certain  conditions,  EU  waste  legislation  enables 
some  Member  States  to  postpone  the  deadlines  for 
reaching certain waste management targets for municipal 
and packaging waste. Member States that want to use this 
possibility,  have  to  notify  the  Commission  24 months  in 
advance  of  the  deadline  and  submit  an  implementation 
plan laying down the steps they envisage for reaching the 
postponed targets within a new time frame. Regarding the 
2025 targets, 11 Member States, including Portugal, have 
used this prerogative. 

its 

implementation  plan 

intention  to  postpone 

On 29 December 2023, Portugal notified the Commission 
of 
its  attainment  of  the 
aluminium and glass packaging waste recycling target for 
2025, established by the Packaging and Packaging Waste 
Directive. Attached to this notification, Portugal submitted 
an 
laying  down  the  measures 
necessary  to  attain  the  targets  within  a  postponed  time 
frame  (i.e.  2030  instead  of  2025).  According  to  the 
implementation plan, the main measures Portugal will put 
in  place  include  implementing  a  deposit  return  scheme 
(DRS), improving data reporting systems and extending its 
extended producer responsibility scheme to all packaging 
from 2025 onwards. 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 
efforts to improve their recycling performance. 

On  the  one  hand,  the  Commission  is  working  with  the 
national  authorities  and  stakeholders  to  speed  up  the 
implementation  of  appropriate  measures  to  meet  the 
targets, including through dedicated financing. 

On  the  other  hand,  the  Commission 
is  pursuing 
enforcement  actions  against  those  Member  States  that, 
based  on  data  submitted  to  the  Commission,  do  not 
achieve the targets of the Waste Framework Directive (17), 
the Packaging and Packaging Waste Directive 2024 (18) and 
the  Directive  on  Waste  Electrical  and  Electronic 
Equipment (19). 

(17)  Directive  2008/98/EC  of  the  European  Parliament  and  of  the 
Council  of  19  November  2008  on  waste  and  repealing  certain 
Directives, Directive - 2008/98 - EN - Waste framework directive - 
EUR-Lex 

(18)  European  Parliament  and  Council  Directive  94/62/EC  of  20 
December  1994  on  packaging  and  packaging  waste,  Directive  - 
94/62 - EN - EUR-Lex. 

(19)  Directive  2012/19/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  waste  electrical  and  electronic 
-  EUR-
equipment 

(WEEE),  Directive 

-  2012/19 

-  EN 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
Therefore,  an 
against Portugal was launched in July 2024 (20). 

infringement  procedure 

(2024/2145) 

Municipal waste 

Municipal waste generation in Portugal shows a moderate 
increase since 2013 (Figure 5). In 2022, Portugal generated 
510 kg  per  capita  of  municipal  waste,  just  below  the 
(estimated)  EU-27  average  of  513 kg  per  capita.  In  2020 
and  2021,  Portugal  reported  more  municipal  waste 
treated than generated. This situation is due to quantities 
of waste that are stored for one year and treated the next, 
and it may also be due to methodological issues that are 
currently being analysed in more detail by the Portuguese 
Environment  Agency  (Agência  Portuguesa  do  Ambiente 
(APA)) along with the National Statistics Institute to ensure 
convergence of methodological approaches. 

The rate of preparing for reuse and recycling of municipal 
waste  in  Portugal  shows  a  moderate  increase  between 
2012 and 2022 (Figure 6), reaching 30 % in 2022, which is 
significantly below the estimated EU-27 average of 49 %. 
Portugal relies heavily on mechanical biological treatment 
(MBT),  and  the  amounts  reported  as  composted  and 
digested  include  MBT  outputs.  In  2020  and  2021,  less 
waste was sent to MBT plants as a measure to contain the 
COVID-19 pandemic, as well as undertaking improvement 
and  requalification  work  at  the  plants (21).  Compost 
derived  from  mixed  waste  will  not  be  allowed  to  count 
towards the preparing for reuse and recycling target of the 
Waste  Framework  Directive  from  2027  onwards,  which 
could  result  in  a  decrease  in  Portugal’s  overall  recycling 
rate in the future (22). 

Portugal  9 

Figure 5:  Municipal  waste  management  and  recycling 
(including preparation for reuse), 2010–2022 

Source:  Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
env_wasmun, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table. 

22 October 

accessed 

Moreover, it appears that a significant number of irregular 
and substandard landfills are operating in Portugal. These 
sites  do  not  meet  the  EU  landfilling  standards  (i.e.  they 
lack  pretreatment  of  waste  or  do  not  treat  the  organic 
fraction). A 2017 study (23)revealed shortcomings in four 
of  the  five  landfills  visited  in  Portugal.  At  least  59 %  of 
municipal  waste  is  landfilled  without  any  treatment. 
Furthermore, Portugal has not set up a suitable integrated 
network  of  waste  management  installations  for  mixed 
municipal  waste.  In  February  2022,  the  Commission 
initiated  an  infringement  procedure  (2021/2258)  for 
failing  to  comply  with  the  Landfill  Directive (24)  and  the 
Waste Framework Directive (25), sending a letter of formal 
notice  to  Portugal (26).  The  case  is  now  at  the  reasoned 
opinion stage. 

However,  both  the  strategic  plan  (2030  PERSU)  and  the 
specific  plans  of  the  entities  managing  municipal  and 
multi-municipal systems (PAPERSU, the action plans for its 
implementation  prepared  by  the  local  authorities  and 

(20) 

(21) 

(22) 

(23) 

‘July 

European 

Commission 

Lexhttps://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex%3A32012L0019. 
infringements  package:  Key 
European  Commission, 
decisions’, 
website, 
https://ec.europa.eu/commission/presscorner/detail/en/inf_22_
3768. 
Information provided by the APA during the Eionet review of the 
draft EEA country profile on waste management for Portugal. 
European  Environment  Agency  (EEA),  Early  warning  assessment 
related  to  the  2025  targets  for  municipal  waste  and  packaging 
2022, 
Portugal, 
waste – 
https://www.eea.europa.eu/publications/many-eu-member-
states/portugal/view. 
European Commission, Study to assess the implementation by the 
EU Member States of certain provisions of Directive 1999/31/EC on 
the  landfill  of  waste,  Publications  Office  of  the  European  Union, 

(24) 

Luxembourg,  2017,  https://op.europa.eu/en/publication-detail/-
/publication/cd1748fb-0884-11e7-8a35-01aa75ed71a1. 
Council  Directive1999/31/EC  of  126 April  1999  on  the  landfill  of 
waste 
https://eur-
16.7.1999, 
lex.europa.eu/eli/dir/1999/31/oj/eng.  

L 182, 

p. 1), 

(OJ 

(OJ 

L 312, 

(25)  Directive  2008/98/EC  of  the  European  Parliament  and  of  the 
Council  of  19 November  2008  on  waste  and  repealing  certain 
https://eur-
Directives 
lex.europa.eu/eli/dir/2008/98/oj/eng.  
European  Commission,  ‘February  infringements  package:  Key 
decisions’, 
website, 
https://ec.europa.eu/commission/presscorner/detail/en/inf_22_
601. 

Commission 

22.11.2008, 

European 

p. 3), 

(26) 

2025 Environmental Implementation Review – Portugal 

 
 
 
Portugal  10 

Packaging waste 

Total  packaging  waste  generation 
in  Portugal  has 
significantly increased since 2010. The country generated 
188 kg per capita in 2022 (Figure 7), which is very close to 
the  estimated  European  average  of  186 kg  per  capita  in 
the same year (29). 

Figure 7: Packaging waste generation, 2010–2022 

Source: Eurostat, ‘Packaging waste by waste management operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en. 

Figure 8: Packaging waste recycling rates (%), 2010–2022 

approved  by  APA)  include  a  strong  commitment  to 
separate collection of biowaste or, when this is not viable, 
its  treatment  at  source,  and  many  municipal  and  multi-
municipal  systems  have  started  separate  collection  of 
biowaste.  The  incineration  rate  remained  quite  stable 
during  this  period  and  stood  at  20 %  in  2022.  The 
Portuguese  landfill  rate  has  been  increasing  since  2016, 
having followed a declining trend before that, resulting in 
a  landfill  rate  of  55 %  in  2022.  The  reasons  for  this 
development  include  temporary  closure  of  MBT  plants 
during the COVID-19 outbreak and technical work on the 
equipment at waste treatment plants (27). 

The data shown in Figure 6 differ from the provisional data 
reported  by  the  Portuguese  authorities  that  show 
compliance  with  the  preparing  for  reuse  and  recycling 
target  of  55 %  for  2025,  as  laid  down  in  the  Waste 
Framework  Directive.  Portugal  reported  a  rate  of 
preparing for reuse and recycling in response to the target 
that was in the range of 1–5 percentage points higher than 
the data shown in Figure 6 for reference year 2022. These 
data are still awaiting final validation by Eurostat (28). 

Figure 6: Recycling (including preparation for reuse) and 
landfill rates (%), 2010–2022 

NB: As of reference year 2020, new reporting rules apply for calculating 
in 
recycled  municipal  waste  pursuant  to  the  targets 
Article 11.2(c)–(e) of Directive 2008/98/EC. Portugal has applied the new 
calculation rules from reference year 2021 onwards (APA, 2024). 

laid  down 

Source:  Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
2024, 
env_wasmun, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table. 

22 October 

accessed 

Source: Eurostat, ‘Packaging waste by waste management operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en. 

(27) 

(28) 

Information provided by the APA during the Eionet review of the 
draft EEA country profile on waste management for Portugal. 
Information provided by Eurostat on provisional data in response 
in  Article 37(1)  of  the  Waste 
to  the  reporting  obligation 

(29) 

Framework Directive related to the target on preparing for reuse 
and recycling of municipal waste (Art. 11(2)(c). 
The  EU  average  might  have  been influenced by  not  all  Member 
States fully  applying  the  reporting  rules for  packaging  waste  set 
out in Commission Implementing Decision (EU) 2019/665. 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
 
The  Portuguese  overall  packaging  waste  recycling  rate 
shows  a  moderate  increase  between  2010  and  2022, 
reaching  61 %  in  2022  (Figure 8).  The  recycling  rate  of 
wooden  packaging  has  been  fluctuating  over  the  past 
decade, which  is assumed to be caused by difficulties  in 
distinguishing  between 
reusable  and  non-reusable 
packaging. This is also demonstrated by the high recycling 
rate of this fraction, reaching 132 % in 2014 and 113 % in 
2021.  Paper  and  cardboard, plastics  and  glass  packaging 
waste are the largest fractions and are mainly responsible 
for  the  total  packaging  recycling  rate.  Plastic  packaging 
recycling  shows  a  significant  increase  until  2015  but  has 
stagnated  since  then.  For  reference  year  2020  and 
onwards,  it  is  mandatory  to  report  steel  and  aluminium 
packaging separately. The recycling rate of steel packaging 
waste exceeded the 2025 target. 

Legal framework and waste management plans 

By 5 July 2020, Member States had to bring their national 
laws  into  line  with  modifications  included  in  the  revised 
Waste Framework Directive, the Packaging and Packaging 
Waste Directive and the Landfill Directive (30). 

Waste  management  plans  and  waste  prevention 
programmes are instrumental to the full implementation 
of  EU  waste  legislation.  They  set  out  key  provisions  and 
investments to ensure compliance with existing and new 
legal requirements (e.g. on waste prevention, on separate 
collection for certain waste streams, on recycling and on 
landfill targets). Revised plans and programmes were also 
due on 5 July 2020. 

In  Portugal,  as  explained  in  the  2022  EIR,  new  national 
legislation on waste management was approved in 2020. 
The  national  macro-strategy  on  prevention  and  waste 
management  is  established  by  the  2030  national  waste 
management plan (Plano nacional de gestão de resíduos 
(PNGR)), adopted in March 2023, which defines the 2030 
PERSU,  also  adopted  in  March  2023,  and  the  2030 
strategic plan for non-municipal waste (Plano estratégico 
para  os  resíduos  nao  urbanos  (PERNU),  adopted  in 
October 2023. They promote changes in Portuguese waste 
management by means of encouraging waste prevention 
and  the  circular  economy.  Moreover,  the  new  regional 
waste  management  plans  for  Madeira  and  Azores  were 
adopted in 2021 and 2023, respectively. 

Policies to encourage waste prevention 

Portugal’s National Waste Prevention Programme (NWPP) 
is  integrated  into  the  2030  PERSU,  PERNU  and  PNGR, 
replacing the previous (2020) versions and their updates. 
The NWPP aligns with updated EU directives and includes 
evaluations in 2026 and 2028 to inform future strategies. 

Portugal  11 

lack  details  on  policy 
Although  current  documents 
effectiveness  evaluation  and  budgets,  action  plans  with 
associated  budgets  for 
implementing  measures  are 
planned.  The  NWPP  focuses  on  resource  efficiency, 
prevention 
circular 
awareness,  reducing  municipal  waste,  and  minimising 
hazardous  substances  in  materials  and  waste.  Priority 
waste  streams  include  food/organic  waste,  hazardous 
waste,  paper,  packaging,  waste  electrical  and  electronic 
equipment, textiles and bulky waste. 

promotion,  waste 

economy 

The 2030 PNGR sets several ambitious quantified targets 
for waste prevention: 
• 

reduce, by 2030, total waste generation to 85.6 % of 
the amount generated in 2018; 
reduce  the  share  of  hazardous  waste  in  total  waste 
from 7.0  % in 2018 to 4.4  % in 2030; 
reduce  waste  generation /  GDP  from  0.08 t  per 
EUR1 000 in the reference year (2018) to 0.059 t per 
EUR1 000 in 2030. 

• 

• 

The 2030 PERNU sets another set of ambitious targets for 
preventing non-municipal waste generation: 
• 

reduce  non-municipal  waste  generation 
11 427 435 t in 2019 to 9 320 010 t in 2030; 
reduce  non-municipal  hazardous  waste  generation 
from 1 066 055 t in 2019 to 599 261 t in 2030; 
reduce  non-municipal  waste  generation /GDP  from 
0.056 t per EUR1 000 in 2019 to 0.040 t per EUR1 000 
in 2030. 

• 

• 

from 

Focusing  on  food  waste,  in  2018,  Portugal  developed  a 
strategy, ‘Combat food waste’, as well as an action plan. 
The  strategy,  inter  alia,  aims  to  increase  education  and 
awareness  campaigns,  to  facilitate  and  encourage  food 
donations and to establish food waste monitoring. 

The  abovementioned  CEAP  for  2018–2020,  adopted  in 
December  2017,  is  still valid,  targeting  carbon  neutrality 
and resource efficiency. Portugal also introduced an eco-
design  work  plan  to  increase  the  reparability,  durability 
and recyclability of products. 

Implementing  Decision 

According  to  2021  data  reported  to  the  European 
in  accordance  with 
Environment  Agency 
(EEA) 
Commission 
(EU)  2021/19, 
Portugal reused: 
• 
• 
• 

915 t of textiles;  
6 378 t of electrical and electronic devices;  
8 474 t of furniture. 

It should be noted that these data have been reported for 
the  first  time,  and  hence  caution  is  advised  in  drawing 
insights from the dataset. 

(30)  Directive (EU) 2018/851, Directive (EU) 2018/852, Directive (EU) 
2018/850 and Directive (EU) 2018/849 amend the previous waste 

legislation and set more ambitious recycling targets for the period 
up to 2035. 

2025 Environmental Implementation Review – Portugal 

 
 
Policies to encourage separate collection and recycling 

Policies to discourage landfilling or incineration 

Portugal  12 

In Portugal, municipal waste collection primarily occurs via 
bring  points,  with  door-to-door  services  mainly  in  cities, 
and is supported by civic amenity sites. Municipal systems 
the  collection  methods.  Glass,  plastic, 
determine 
composite  and  metal  packaging  waste 
is  collected 
separately, while non-packaging items go to civic amenity 
sites.  The separate collection of food waste is limited  to 
some city neighbourhoods, and mainly targets restaurants 
and bigger waste producers, but recently is expanding in 
towns and suburbs, via both door-to-door collection and 
nearby bring points. In rural areas, community or domestic 
composting  is  most  common.  Finally,  textiles  and  wood 
waste are collected via civic amenity sites in Portugal. 

As  of  July  2021,  Portugal’s  Decree-Law  No 102-D/2020 
expands mandatory separate waste collection to include 
textiles,  biowaste  and  hazardous  municipal  waste, 
enhancing  coverage  and  altering  collection  methods. 
Nationwide schemes for biowaste, textiles, hazardous and 
bulky waste will be implemented by improving access to 
drop-off sites and expanding door-to-door collection. The 
law also sets goals for collection points and for the quality 
of the materials collected. 

The  most  recent  strategic  plan  for  municipal  waste,  the 
2030 PERSU, has established measures to promote pay-as-
you-throw or similar systems in Portugal, which currently 
apply only to a small share of the population. Additionally, 
the  2030  PERSU  has  a  specific  measure  to  improve  the 
accessibility  and  functionality  of  civic  amenity  sites, 
measures  to  promote  pay-as-you-throw  systems  and  to 
create tariff systems with benefits for home or community 
composting. 

In  Portugal,  there  is  a  tax  on  lightweight  plastic  bags  of 
EUR 0.10 per bag and there are firm plans for bringing in a 
levy of EUR 0.30 per item of  plastic or aluminium single-
use packaging purchased in ready-to-eat meals. 

like  paper,  cardboard, 

Portugal  has  extended  producer  responsibility  schemes 
for various types of packaging waste. These schemes cover 
ferrous  metals, 
materials 
aluminium, glass, plastics, wood and composite packaging, 
with  fee  modulation  based  on  recyclability,  recycled 
content  and,  for  some  materials,  sortability.  Audits  by 
producer responsibility organisations are mandated under 
Decree-Law No 152-D/2017 to ensure accurate reporting, 
and the law establishes harmonised criteria for fees. 

Portugal  has  a  voluntary  DRS  for  reusable  packaging  in 
place. A pilot project was developed to encourage the final 
consumer  to  return  non-reusable  plastic  beverage 
containers. The data obtained during this project helped 
to design the rules of and procedures for a DRS for non-
reusable plastic, ferrous metals and aluminium beverage 
containers. The DRS had its licence approved at the end of 
May 2024. 

Portugal  has  imposed  a  landfill  tax,  rather  than  bans  on 
landfilling, which has been progressively increasing since 
2007.  The  tax  rate  will  rise  to  EUR 5/t  in  2025,  which  is 
closely  aligned with the EU average for landfill taxes. To 
encourage  biowaste  separation  and  recycling,  new 
legislation stipulates that municipalities adhering to their 
approved  municipal  action  plans  will  pay  the  tax  at  the 
previous year’s rate. 

Portugal  has  an  incineration  tax,  which  depends  on 
whether  incineration  is  for  recovery  or  disposal  and 
amounts to 20 % and 85 % of the landfill tax, respectively. 

it  should  be  noted  that  Portugal 

In  conclusion, 
is 
considered to be at risk of not meeting the 2025 targets 
for preparing for reuse and recycling of municipal waste, 
for  the  recycling  of  glass,  plastics,  and  ferrous  and 
aluminium  packaging  waste  and  for  the  2035  target  to 
reduce  the  landfilling  of  municipal  waste.  The  reported 
recycling rate for total packaging waste was 63 % in 2021, 
just below the 2025 target of 65 %. 

that 

Progress on increasing recycling and reducing landfilling of 
municipal  waste  has  stagnated  since  2016,  and  thus 
Portugal  needs  to  speed  up  its  efforts  in  this  respect.  It 
seems 
introduced 
improvements,  such  as  the  extension  of  separate 
collection, treatment of biowaste at source and increase 
in the landfill tax, are not yet reflected in the most recently 
available data. 

the  effects  of 

recently 

In the abovementioned 2023 Waste Early Warning Report, 
the  European  Commission  issued  a  number  of  policy 
recommendations  to  improve  Portugal’s  performance  in 
waste management: 
• 

Support  preparing for reuse  of municipal  waste and 
reuse systems for packaging. 
Improve  separate  collection  of  recyclables  and 
different  packaging  waste  fractions  and  make  the 
separate collection of biowaste more convenient. 
Implement and strengthen economic instruments to 
encourage  good  waste  management,  such  as 
increasing  the 
implementing  a 
landfill  tax  and 
mandatory  pay-as-you-throw  system  and  a  deposit 
return scheme. 
Further  develop  waste  treatment 
associated  with  the  higher 
hierarchy. 

infrastructure 
levels  of  the  waste 

• 

• 

• 

It  is  also  important  to  note  that,  in  line  with  the  EIR 
assessment, Portugal has received in the framework of the 

2025 Environmental Implementation Review – Portugal 

 
Portugal  13 

2022 (31)  and  2023 (32)  European  Semester  a  country-
specific recommendation  (CSR)  on circular  economy and 
waste management: 
• 

‘Enhance  the  conditions  for  a  transition  towards  a 
circular  economy,  in  particular  by  increasing  waste 
prevention, recycling and reuse to divert waste away 
from landfills and incinerators.’ 

Moreover,  the  2022  EIR  also  included  several  priority 
actions  for  Portugal  on  waste  management,  concerning 
adequate  and  updated  planning,  cooperation  among 
competent authorities, optimisation of the use of existing 
infrastructure  and  closure  and 
waste 
rehabilitation of non-compliant landfills. 

treatment 

Some progress can be observed on the adoption of legal 
and  planning  instruments,  which  now  have  to  be  fully 
implemented.  Moreover,  several  reforms  included  in 
Portugal’s  RRP  should  improve  the  situation  in  the 
medium term. 

Furthermore,  in  November  2024,  Portugal  created  a 
Working Group on Waste Management engaging multiple 
institutions  to  identify  and  implement  new  solutions 
considering the infrastructure limitations (33). 

this  section,  many 
Nevertheless,  as  explained 
challenges  in  the  waste  sector  remain  and  the  current 
situation on the ground requires significant improvement. 
Therefore, the following priority actions are proposed. 

in 

2025 priority actions 

• 

• 
• 

• 

• 

Improve  municipal  waste  preparation  for  reuse  and 
recycling. 
Increase the recycling rates of packaging waste. 
Increase  the  collection  and  recycling  rate  of  waste 
electronic and electric equipment (WEEE). 
Invest  in  waste  prevention  measures  to  reduce  the 
total amount of waste generated. 
Ensure  the  achievement  of  the  2025  waste  targets, 
following 
the 
Commission  in  the  Early  Warning  Reports  where 
applicable. 

the  recommendations  made  by 

(31) 

(32) 

for  a  Council 
European  Commission,  Recommendation 
Recommendation  on  the  2022  national  reform  programme  of 
Portugal  and  delivering  a  Council  opinion  on  the  2022  stability 
programme of Portugal, COM(2022) 623 final of 25 March 2022, 
https://commission.europa.eu/document/download/a70e3197-
cb9a-4d54-a72a-d5e89b22acab_en?filename=2022-european-
semester-csr-portugal_en.pdf. See CSR-3 and Recital 25. 
European  Commission,  Recommendation 
for  a  Council 
Recommendation  on  the  2023  national  reform  programme  of 

Portugal  and  delivering  a  Council  opinion  on  the  2023  stability 
programme of Portugal, COM(2023) 622 final of 24 March 2023, 
https://commission.europa.eu/document/download/e4cdbdee-
7a79-4e13-80ea-
7bd4dc39857a_en?filename=COM_2023_622_1_EN.pdf. 
CSR-3 and Recital 32. 
n.º 

14013-A/2024, 

26.11.2024 

See 

(33)  Despacho 

https://diariodarepublica.pt/dr/detalhe/despacho/14013-a-
2024-897796612. 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Portugal  14 

2. Biodiversity and natural capital 

Global and EU biodiversity frameworks 

Biological  diversity  and  healthy  ecosystems  are  critical 
for our societies, underpin our economies and well-being 
and  are  essential  for  climate  change  adaptation  and 
mitigation.  The  Kunming–Montreal  Global  Biodiversity 
Framework  (GBF),  adopted  in  December  2022,  sets 
comprehensive  and  measurable  targets  to  tackle 
biodiversity  loss  by  2030.  To  implement  this  global 
framework and integrate biodiversity considerations into 
national  decision-making,  the  EU  and  all  EU  Member 
States had to submit national biodiversity strategies and 
action  plans  (NBSAPs),  or  to  communicate  national 
targets  aligned  with  the  global  targets,  by  the  end  of 
2024.  

The EU Biodiversity Strategy for 2030 (BDS) aims to put 
EU  biodiversity  on  a  path  to  recovery  by  2030.  It  sets 
quantified targets intended to protect and restore nature 
and manage ecosystems in a sustainable manner, as well 
as  measures 
and 
commitments  to  support  global  biodiversity.  A  BDS 
actions  tracker (34)  and  a  dashboard  of  indicators (35) 
provide information on implementation progress. 

implementation 

enable 

to 

recently 

adopted 

The 
EU  Nature  Restoration 
Regulation (36) is the first EU-wide, comprehensive law of 
its kind and a key instrument for the EU to deliver on the 
global  biodiversity  targets  for  2030.  It  lays  down  an 
overarching  objective  at  the  EU  level  to  put  in  place 
effective  restoration  measures  on  20 %  of  EU  land  and 
sea by 2030 and for all ecosystems in need of restoration 
by  2050.  To  achieve  this,  it  sets  binding  targets  for 
Member States to restore and maintain ecosystems, as 
well as an effective implementation framework based on 
national restoration plans. 

The BDS is the main instrument used by the EU to deliver 
on  its  obligation  under  the  GBF.  The  Commission  has 
submitted  to  the  Convention  on  Biological  Diversity 
(CBD)  its  report  on  GBF-aligned  EU  targets  that  stem 
from the BDS and from other policy instruments under 
the European Green Deal. 

EU  Member  States’  National  Biodiversity  Strategy  and 
Action  Plans  (NBSAPs)  need  to  provide  coherent 
frameworks  for  national  delivery  on  the  global  and  EU 
line  with  the  global 
2030  biodiversity  targets. 
obligations,  NBSAPs  should  also  include  a  biodiversity 
financing  plan  and  a  capacity-building  plan,  based  on 
needs  assessments,  as  well  as  an  overview  of  the 
national indicators used to measure progress. 

In 

2030  National 

Portugal’s 
Strategy  of  Nature 
Conservation and Biodiversity 2030 (Estratégia nacional 
de  conservação  da  natureza  e  biodiversidade) (37)  was 
approved by the government on 5 April 2018. It identifies 
goals for 2030 reflected in more than 100 measures, each 
with  corresponding 
indicators,  priorities,  deadlines, 
means of verification, tools and responsible entities. 

Furthermore,  on  1 August  2019, 
the  Portuguese 
government adopted Resolution 143/2019, containing a 
strategy and recommendations for the implementation 
of a network of marine protected areas. 

In line with this resolution, in October 2024 the Azores 
regional assembly passed legislation to protect 30 % of 
its  marine  territory  (almost  300 000 km2  of  sea).  This 
legislation  is  part  of  efforts  to  meet  the  UN  and  EU 
conservation  targets  and  to  fully  develop  a  functional 
Network of Protected Marine Areas (RAMPA) in Azores 
by  2030.  The  process 
involved  consultation  with 
stakeholders,  especially  the  local  fishing  industry,  to 
which the government plans to offer compensation and 
support  for  sustainable  practices.  The  creation  of  the 
Azores  Marine  Park 
is  a  significant  step  towards 
enhancing  Portugal’s  network  of  marine  conservation 
areas. 

However,  Portugal  has  not  yet  submitted  to  the 
Convention on Biological Diversity an updated NBSAP or 
national targets following the adoption of the GBF. 

Portugal  has  not  ratified  the  Nagoya–Kuala  Lumpur 
Supplementary  Protocol  to  the  Cartagena  Protocol  on 
Biosafety. 

The EU aims to allocate to biodiversity objectives at least 
7.5 % of annual spending under the EU budget in 2024, 

(34) 

(35) 

(36) 

Actions 

Tracker 

Strategy 

Strategy 

Biodiversity 

Biodiversity 

EU 
(https://dopa.jrc.ec.europa.eu/kcbd/actions-tracker/).  
EU 
(https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1).  
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
the 
http://data.europa.eu/eli/reg/2024/1991/oj; 

Dashboard 

see  also 

(37) 

on 

web 

page 

the 
Commission 
(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 
Estratégia nacional de conservação da natureza e biodiversidade 
2030, Resolução do Conselho de Ministros No 55/2018, Diário da 
maio, 
República 
https://www.cbd.int/doc/world/pt/pt-nbsap-v2-pt.pdf. 

Série I, 

No 87 

law 

de 

de 

7 

2025 Environmental Implementation Review – Portugal 

 
 
 
in  2026  and  2027.  For  details  on 
rising  to  10 % 
biodiversity  financing  and  investments  in  Portugal,  see 
‘Biodiversity and ecosystems’ in Chapter 5. 

2025 priority action 

• 

Submit  to  the  CBD  an  updated  NBSAP  or  national 
targets  following  the  adoption  of  the  Kunming-
Montreal Global Biodiversity Framework. 

Nature protection and restoration – Natura 
2000 

Natura  2000 (38),  the  largest  coordinated  network  of 
protected areas in the world, is key to the achievement 
of  the  objectives  set  out  in  the  Birds  and  Habitats 
Directives.  
These objectives are to ensure the long-term protection, 
conservation and survival of Europe’s most valuable and 
threatened species and habitats and the ecosystems they 
underpin.  
Key  milestones  towards  meeting  the  objectives  of  the 
Birds  and  Habitats  Directives  are  (i)  the  setting  up  of  a 
complete  and  coherent  Natura  2000  network;  (ii)  the 
designation of Sites of Community Importance (SCIs) as 
Special  Areas  of  Conservation  (SACs) (39);  and  (iii) 
effective  management  of all  Natura 2000  sites through 
the  setting  of  site-specific  conservation  objectives  and 
measures. 

Setting up a complete and coherent network of Natura 
2000 sites 

The  setting  up  of  a  complete  and  coherent  network  of 
Natura  2000  sites 
is  a  cornerstone  of  the  EU’s 
international commitments, under the BDS and GBF, to 
legally  protect  a  minimum  of  30 %  of  its  land  area  and 
30 % of its sea area. 

the 

these 

requires 

commitments 

Meeting 
full 
implementation of Article 3 of the Habitats Directive. The 
Natura 2000 network should represent a complete and 
coherent  ecological network composed of sites hosting 
natural habitat types and species of community interest. 
The  Natura  2000  network  enables  the  natural  habitat 
types  and  the  species’  habitats  concerned  to  be 
maintained  or,  where  appropriate,  restored  to  a 

(38)  Natura  2000  comprises  Sites  of  Community  Importance  (SCIs), 
designated pursuant to the Habitats Directive, as well as Special 
Protection  Areas  (SPAs),  classified  pursuant  to  the  Birds 
Directive. Numbers of protected areas in Figure 9 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. An SAC is an SCI designated by a Member State. 
SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 

(39) 

Portugal  15 

favourable conservation status in their natural range. 

As shown in Figure 9, in 2023, 21.2 % of the national land 
area  of  Portugal  was  covered  by  Natura  2000  (EU 
coverage  18.6 %),  with  Special  Protection  Areas  (SPAs) 
classified under the Birds Directive covering 10.6 % (EU 
coverage  12.8 %)  and  Sites  of  Community  Importance 
(SCIs) or Special Areas of Conservation (SACs) under the 
Habitats Directive covering 17 % (EU coverage 14.3 %) of 
the Portuguese territory. 

The latest assessment of the SCI/SAC part of the Natura 
2000  network  showed  that  some  species  and  habitats, 
in  the  marine  environment,  are  not 
particularly 
sufficiently protected. Therefore, Portugal should extend 
its  Natura  2000  network  with  additional  designations, 
particularly  for  marine  sites.  The  Commission  launched 
an  infringement  procedure  (2019/2148)  and  a  letter  of 
formal notice was sent to Portugal in July 2019. Although 
some shortcomings had been corrected, an assessment 
of  the  case  found  that  insufficiencies  persisted.  Hence, 
the Commission notified a reasoned opinion to Portugal 
in May 2022. This case is still open. 

Considering  both  Natura  2000  and  other  nationally 
designated  protected  areas,  Portugal  legally  protects 
22.4 %  of  its  terrestrial  areas  (EU-27  coverage  26.1 %) 
and  4.5 % (40)  of  its  marine  areas  (EU-27  coverage 
12.3 %) (41). This is below the EU 2030 target of 30%. 

Figure 9:  Natura  2000  terrestrial  protected  area 
coverage per Member State (%), 2023 

Source: European Environment Agency (EEA), ‘Natura 2000 Barometer’, 
2023  data,  accessed  March  2025,  https://www.eea.europa.eu/data-
and-maps/dashboards/natura-2000-barometer. 

(40) 

(41) 

This  percentage  will  increase  with  the  new  protected  areas  in 
Azores. 
Eurostat dataset env_bio4, protected area percentage for 2022, 
accessed 
2025, 
https://ec.europa.eu/eurostat/databrowser/view/env_bio4/def
ault/table?lang=en. 

March 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
Designating Special Areas of Conservation and setting 
site-specific conservation objectives and measures 

In order to ensure that SCIs contribute to the objectives 
of the Habitats Directive, Member States must designate 
them  as  SACs,  setting  site-specific  conservation 
objectives based on the ecological needs of the species 
and  habitats  present  on  the  sites.  The  site-specific 
conservation  objectives  must  be  defined  in  terms  of 
attributes  and  targets  that  cover  the  properties  of  the 
feature  of  interest  that  are  necessary  to  describe  its 
condition  as  either  favourable  or  unfavourable.  These 
objectives  must  address  the  key  pressures  and  threats 
present  on  the  site.  Article 6  of  the  Habitats  Directive 
requires  Member  States  to  establish  and  implement 
conservation  measures  for  the  realisation  of  the 
objectives of the site. 

Following a ruling by the Court of Justice of the European 
Union  on  5 September  2019,  Portugal  designated  as 
Special Areas of Conservation (SACs) all the existing Sites 
of  Community  Importance  (SCIs)  on  the  mainland 
(Atlantic  and  Mediterranean  biogeographical  regions). 
Most  of  the  sites  in  the  Macaronesian  biogeographical 
region had already been designated as SACs. There are, 
however, two pending designations, for the SCIs ‘Menez 
Gwen’ and ‘Lucky Strike’, for which the six-year deadline 
set by the Habitats Directive has already expired. 

The  decree  that  designated  the  SACs  on  the  mainland, 
Decreto  Regulamentar  1/2020,  does  not  identify  the 
habitat  types  and  the  species  protected  in  each  of  the 
sites and is therefore considered by the Commission not 
to  fulfil  Portugal’s  obligations  under  Article 4(4)  of  the 
Habitats Directive. 

Moreover,  Portugal  has  not  yet  adopted  management 
plans for a majority of the SACs on the mainland, and the 
in  the  past  for  the 
management  plans  adopted 
Macaronesian SACs are not sufficiently specific in terms 
of conservation objectives and measures. 

It is therefore urgent that adequate management plans, 
which  identify  site-specific  conservation  objectives  and 
measures  for  each  area,  are  put  in  place  and  that  the 
current management of the Natura 2000 sites is fully in 
line with those management plans. In this regard, several 
draft  management  plans  for  SACs  affected  by  the 
ongoing infringement procedure have been put through 
public  consultation.  However,  no  management  plans 
have yet been officially approved for the vast majority of 
SACs in mainland Portugal. 

The  Commission  therefore  considers  that  Portugal  has 
not yet complied with the ruling of 2019 and has taken 

(42) 

EEA State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
2020, 
European 

Luxembourg, 

Union, 

Portugal  16 

the decision to refer Portugal back to the Court of Justice 
under Article 260 of the Treaty on the Functioning of the 
European  Union  (TFEU),  asking  pecuniary  sanctions  to 
Portugal.  The  application  before  the  Court  has  been 
submitted in September 2024 (Case C-613/24). 

2025 priority actions 

• 
• 

• 

of 

the 

establishment 

Complete the Natura 2000 site designation process. 
Finalise 
site-specific 
conservation objectives and measures for all Natura 
2000 sites (including by adopting their management 
plans) and ensure their effective implementation. 
Ensure the effective implementation of Natura 2000 
management  plans  and  sufficient  administrative 
capacity and financing both for Natura 2000 and the 
the  Nature  Restoration 
implementation  of 
Regulation.  Ensure  implementation  of  Prioritised 
Actions Framework 2021-2027 (PAFs). 

Recovery of species 

One  objective  set  by  the  BDS  is  that,  by  2030,  there 
should be no further deterioration in conservation trends 
or  the  status  of  any  protected  species.  The  BDS  also 
states  that  Member  States  should  ensure  that  at  least 
30 % of species not currently in favourable conservation 
status  achieve  that  status  or  show  progress  towards 
doing so (e.g. by exhibiting positive population dynamics 
or stable or increasing range and habitat size), by 2030. 
According to the European Environmental Agency (EEA), 
based  on  reporting  required  under  Article 17  of  the 
Habitats Directive, a quarter of species in the EU were of 
good conservation status as of 2018 (42). 

One of the primary objectives of the Habitats Directive is 
the  maintenance  of  or  restoration  to  favourable 
conservation status of all species of community interest. 
Moreover, the Birds Directive also aims to ensure that all 
wild  birds  in  the  EU  enjoy  a  secure  status.  In  order  to 
achieve these objectives, it will be necessary to address 
key  pressures  and  threats.  The  Birds  Directive  and  the 
Habitats  Directive  lay  down  a  framework  of  species 
protection rules and rules on the conservation of habitats 
and species in order to combat these threats. 

To  measure  the  performance  of  Member  States, 
Article 17 of the Habitats Directive and Article 12 of the 
Birds  Directive  require  reporting  on  progress  towards 
maintaining or restoring favourable conservation status 
of  species  and  habitats.  According  to  the  report 
submitted  by  Portugal  on  the  conservation  status  of 
habitats  and  species  covered  by  the  Article 17  of  the 

https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 

2025 Environmental Implementation Review – Portugal 

 
 
 
for  2013–2018, 

the  share  of 
Habitats  Directive 
assessments  showing  habitats  with  good  conservation 
status  in  2018  was  23.7 %.  This  is  less  than  the  29.5 % 
reported  under  the  previous  reporting  period  (2007–
2012). As for protected species, the share of assessments 
showing species  with  good conservation status in 2018 
was  26.5 %,  more  than  the  19.7 %  reported  under  the 
previous reporting period (2007–2012). Only 4 % of the 
forest area had a favourable conservation status (43). As 
far as birds are concerned, 30 % of the breeding species 
showed 
stable 
increasing 
populations  (for  wintering  species  was  38.5 %).  At  the 
same time, the share of habitats assessed as having bad 
conservation  status  had  increased  to  28.8 %  and  the 
share  of  assessments  showing  species  with  bad 
conservation  status  had  also  increased  to  11.3 %.  The 
main pressures are from agriculture, urban development 
and alien and problematic species. 

trends  or 

short-term 

Under  Article 17  of  the  Habitats  Directive,  Member 
States are required to report on the conservation status 
of  habitats  and  species  every  six  years.  The  current 
reporting cycle, covering the years 2019–2024, is due for 
submission  in  July  2025.  Figures 10  and  11  show  the 
latest available conservation status data. 

Figure 10:  Assessments  of  conservation  status  of 
habitats  for  the  2007–2012  and  2013–2018  reporting 
periods 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in area conservation 
status in a Member State may result from changes to methods or use 
of better data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
2021, 
19 December 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived. 

December 

accessed 

2019, 

(43) 

EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
2020, 
European 

Luxembourg, 

Union, 

Portugal  17 

Figure 11:  Assessments  of  conservation  status  of 
species  for  the  2007–2012  and  2013–2018  reporting 
periods 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in area conservation 
status in a Member State may result from changes to methods or use 
of better data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
2021, 
19 December 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived. 

December 

accessed 

2019, 

It  is  difficult  to  assess  how  the  conservation  status  of 
habitats  and  species  is  evolving,  since  the  worsening 
trend may in part be due to improved knowledge rather 
than to actual degradation. It is clear, however, that a lot 
of  work  is  needed  to  reach  favourable  conservation 
status  and,  mainly  for  habitat  types,  even  to  fill  in  the 
knowledge gaps, which are still considerable. 

Among  numerous  other  actions  taken  by  Portugal  to 
improve  knowledge  of  habitats  and  species  is  the 
publication in 2023 of the Red Book of the Mammals of 
Continental Portugal (Livro Vermelho dos Mamíferos de 
Portugal  Continental)  and  several  projects  to  map 
habitats protected under the Habitats Directive. 

In 2023 the Commission decided to open an infringement 
case by sending a letter of formal notice to Portugal for 
failing  to  implement  the  measures  required  under  the 
Habitats  Directive  to  avoid  bycatch  of  cetaceans  by 
fishing vessels.44 

2025 priority actions 

• 

Strengthen  the  integration  of  biodiversity  actions 
into other policies, e.g. energy, agriculture, fisheries, 

https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020.. 
INFR(2020)4038. 

(44)  

2025 Environmental Implementation Review – Portugal 

 
 
 
 
 
forestry,  urban  and  infrastructure  planning  and 
sustainable  tourism,  and  promote  communication 
between stakeholders. 

Recovery of ecosystems 

Agricultural ecosystems 

The BDS works alongside the common agricultural policy 
(CAP) to support the transition to sustainable agriculture. 

The  strategy  has  set  five  common  agriculture-related 
targets for 2030, namely to: 
—  reduce by 50 % the overall use of – and risk from – 

chemical pesticides; 

—  reduce  by  50 %  the  use  of  more  hazardous 

pesticides; 

—  reduce  by  50 %  losses  of  nutrients  from  fertilisers 
(which  will result in a  20 % reduction in the use of 
fertilisers)  while  ensuring 
is  no 
deterioration of soil fertility; 

there 

that 

—  restore  at  least  10 %  of  agricultural  area  to  have 

— 

high-diversity landscape features; and 
increase the area under organic farming to at least 
25 %. 

The  “Vision  for  agriculture  and  food”,  adopted  by  the 
European Commission in February 2025, sets a roadmap 
to  an  agri-food  system  that  is  attractive,  competitive, 
sustainable and fair for current and future generations. 
To  ensure  a  sustainable  future  for  EU  agriculture,  it  is 
crucial  that  these  four  priority  areas  are  pursued 
together,  and  that  public  and  private  support  are 
adequately targeted toward this objective (45). 

The  CAP  and  national  CAP  strategic  plans  are  key 
instruments  to  facilitate  and  strengthen  the  efforts  of 
European  farmers  to  protect  biodiversity  and  the 
environment  at 
large.  The  Commission  approved 
Member  States’  CAP  strategic  plans  in  2022  for  the 
programming period 2023-2027. The CAP is the  largest 
source  of  funding  dedicated  to  supporting  biodiversity 
and  plays  a  significant  role 
implementing  EU 
environmental policy. Strategic plans should continue to 

in 

Portugal  18 

support  the  protection  of  soil,  water,  air  quality  and 
biodiversity. 

While certain CAP result indicators focus on the national 
measures  favouring  sustainable  agriculture  practices 
that  regenerate  ecosystems,  the 
impact  of  these 
measures  is  difficult  to  assess.  The  uptake  of  the  eco-
schemes is voluntary for farmers. 

The utilised agricultural area in Portugal decreased from 
3 664 700 ha  in  2012  to  3 638 040 ha  in  2016  and 
increased to 3 935 910 ha hectares in 2022 (46). 

Landscape  features  are  small  fragments  of  non-
productive  and  typically,  but  not  exclusively,  semi-
natural vegetation present in, or adjacent to, agricultural 
land.  They  provide  ecosystem  services  and  support  for 
biodiversity.  The  indicator  ‘share  of  agricultural  land 
covered  with  landscape  features’  is  the  ratio  between 
the  area  covered  by  landscape  features  and  the  area 
land.  Based  on  the  Land 
covered  by  agricultural 
feature 
landscape 
Use/Cover  Area  Frame  Survey 
estimates (47), the share of agricultural land  under non-
productive landscape features in Portugal is 8.9 %, above 
the EU average. At the EU level, landscape features cover 
5.6 % of agricultural land. 

In  2024,  the  CAP  basic  regulations  were  amended (48) 
regarding, 
inter  alia,  the  standards  for  the  good 
agricultural and environmental condition (GAEC) of land. 
These  changes  removed  the  obligation  for  farmers 
benefiting  from  CAP  area-related  support  to  have  a 
minimum  share  of  3–4  %  of  non-productive  areas  or 
landscape  features 
in  their  farms.  However,  the 
amended  regulation  does  not  remove  the  obligation 
under the GAEC 8 to maintain existing landscape features 
and sets out an obligation for Member States to establish 
and provide support for eco-schemes covering practices 
for  the  maintenance  of  non-productive  areas,  such  as 
land  lying  fallow,  and  for  the  establishment  of  new 
landscape features on arable land. 

The recently adopted Nature Restoration Regulation (49) 
focuses on the restoration of agricultural ecosystems and 
requires  Member  States  to  put  in  place  measures  that 
aim to achieve an increasing trend at the national level in 
at  least  two  out  of  three  indicators  for  agricultural 

(45) 

(46) 

https://agriculture.ec.europa.eu/overview-vision-agriculture-
food/vision-agriculture-and-food_en 
Eurostat,  ‘Utilised  agricultural  area  by  categories’,  tag00025, 
accessed 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/tag00025/de
fault/table?lang=en. 

5 December 

(49) 

is 

the 

(47)  European  Commission,  JRC,  Landscape  features  in  agricultural 
land:  what 
https://joint-research-
centre.ec.europa.eu/jrc-news-and-updates/landscape-features-
agricultural-land-what-extent-2024-09-30_en  
Regulation (EU) 2024/1468 of the European Parliament and of 
the  Council  of  14 May  2024  amending  Regulations  (EU) 
2021/2115 and (EU) 2021/2116 as regards good agricultural and 

extent? 

(48) 

environmental  condition  standards,  schemes  for  climate, 
environment  and  animal  welfare,  amendment  of  the  CAP 
strategic plans, review of the CAP strategic plans and exemptions 
from  controls  and  penalties  (OJ  L,  2024/1468,  24.5.2024), 
http://data.europa.eu/eli/reg/2024/1468/oj. 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
the 
http://data.europa.eu/eli/reg/2024/1991/oj; 
see  also 
law 
the 
on 
Commission 
(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 

page 

web 

2025 Environmental Implementation Review – Portugal 

 
 
 
ecosystems (50). One of these indicators is the ‘share of 
agricultural land with high-diversity landscape features’. 

is  the  fourth  highest  share 

Organic  farming  practices  are  highly  beneficial  to 
biodiversity. As shown in  Figure 12, it is estimated that 
19.31 % of Portugal’s land area is under organic farming. 
This 
in  the  EU  and 
substantially higher than the EU average of 10.50 % (51). 
Portugal is contributing above average to achieving the 
target  to have 25 % of the EU’s agricultural land under 
organic farming by 2030. 

Figure 12:  Share  of  total  utilised  agricultural  area 
occupied  by  organic  farming  per  Member  State  (%), 
2022 

Portugal  19 

mitigation. 

The EU soil strategy, adopted in November 2021, aims to 
support  soil  protection,  sustainable  soil  management 
and  the  restoration  of  degraded  soils  to  achieve  the 
Green  Deal  objectives  as  well  as  land  degradation 
neutrality by 2030. 

This entails: 
—  preventing further soil degradation; 
—  making  sustainable  soil  management  the  new 

normal; 

—  taking action for ecosystem restoration. 

The  proposed  Directive  on  Soil  Monitoring  and 
Resilience (52) aims to introduce the first comprehensive 
legislation on the protection of all soils in the EU. Should 
the  Directive  be  adopted,  Member  States  will  have  to 
transpose  it  into  national  legislation  and  implement  it, 
starting  with  putting  in  place  the  governance  systems 
and a sound monitoring framework building on existing 
national  soil  monitoring  frameworks.  The  objective  of 
the  proposed  Directive  is  to  provide  better  and  more 
comparable  soil  health  data  with  the  view  of  attaining 
healthy soils by 2050. 

Degradation  of  soil  ecosystems  encompasses  several 
aspects. The proposed Directive requires Member States 
to  assess  soil  health  according  to  a  set  of  common 
indicators  and  to  define  the  necessary  regeneration 
measures. The area of soil that is sealed is an important 
factor in monitoring land-use change and represents an 
important pressure on nature and biodiversity. Other soil 
issues  related  to  land degradation  are  soil  erosion,  soil 
soil 
compaction, 
contamination, soil salinisation and the presence in soil 
of  nitrogen  and  phosphorus  in  excess.  The  impact 
assessment accompanying the proposal, which builds on 
the data available in the EU Soil Observatory, points to 
the following soil degradation issues in Portugal (53). 

soil  organic 

loss  of 

carbon, 

The greatest contributor to Portugal’s unhealthy soils is 
unsustainable  soil  erosion  by  water,  wind,  tillage  and 
harvest, which  affects  9 % of the national territory and 
60 % of total cropland areas. 4 % of the land has a high or 
very high susceptibility to topsoil compaction, and other 
indicators of unhealthy soil are negligible. 

(53) 

of 

final 

5 July 

2023, 

COM(2023) 416 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex:52023PC0416. 
Commission  staff  working  document –  Impact  assessment 
report: Annexes – Accompanying the proposal for a Directive of 
the European Parliament and of the Council on Soil Monitoring 
and  Resilience  (Soil  Monitoring  Law),  SWD(2023) 417  final  of 
5 July 
2023, 
https://environment.ec.europa.eu/system/files/2023-
07/IMPACT 
REPORT_ANNEXES_SWD_2023_417_part4.pdf. 

ASSESSMENT 

Source:  Eurostat,  ‘Area  under  organic  farming’,  sdg_02_40,  accessed 
5 December 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en 

2025 priority action 

• 

Implement  eco-schemes  and  agri-environmental 
measures 
the 
to 
environmental needs of Portugal. 

practices 

address 

and 

Soil ecosystems 

Soil is an essential, finite and extremely fragile resource. 
Its  increasing  degradation  poses  a  threat  to  EU  food 
resilience,  adaptation  and 
security  and  climate 

(50) 

(51) 

(52) 

latest  available 

The  indicators are  ‘grassland butterfly  index’;  ‘stock  of  organic 
carbon in cropland mineral soils’ and ‘share of agricultural land 
with high-diversity landscape features’. 
information  from  Eurostat, 
Based  on  the 
currently  under  review;  European  Commission,  Agriculture 
biologique  au  sein  de  l’Union  européenne,  factsheet,  Brussels, 
2024, 
https://agriculture.ec.europa.eu/document/download/c67458e
d-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-
organic-farning_fr.pdf&prefLang=en. 
Proposal for a directive of the European Parliament and of the 
Council on soil monitoring and resilience (Soil Monitoring Law), 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
Grasslands 

Grasslands  are  among  the  most  diverse  ecosystems  in 
the EU; they can contain as many as 80 different  plant 
species per square metre and are home to a large variety 
of animals, ranging from small insects, birds and rodents 
to 
for 
large  herbivores.  Grasslands  are  essential 
agriculture and livestock herding. Natural grasslands also 
play  an  important  role  in  storing  carbon.  However, 
changes  in  agricultural  practices  and  land  uses  have 
caused  grasslands  to  disappear  at  an  alarming  rate, 
making  them  one  of  Europe’s  most  threatened 
ecosystems. 

In  Portugal,  there  are  large  tracts  of  natural  and  semi-
natural  grasslands,  which  include  areas  covered  by  11 
habitat types listed in Annex I of the Habitats Directive. 
Grasslands are among the most threatened habitat types 
in Portugal primarily due to  pressures from agricultural 
practices, 
and 
land 
important 
intensification  of  agriculture.  Additional 
pressures come from forestry and the impact of invasive 
alien species. According to reporting under Article 17 of 
the  Habitats  Directive  for  the  latest  reporting  period 
(2013–2018),  62 %  of  the  assessments  showed  an 
unfavourable conservation status. 

abandonment 

including 

Wetlands/peatlands 

Wetlands act as water sources and purifiers; they are the 
planet’s  greatest  natural  carbon  stores  and  they  are 
crucial  to  agriculture  and  fisheries.  Peatlands  are  a 
special  type  of  wetland  dominated  by  peat-forming 
plants such as Sphagnum mosses. Nearly all peatlands in 
the EU are habitat types listed in Annex I of the Habitats 
Directive. Drained peatlands under intensive agricultural 
use  constitute  only  3 %  of  the  EU’s  utilised  agricultural 
area. At the same time, they are responsible for 25 % of 
the  GHG  emissions  from  the  EU’s  agricultural  sector. 
Restoring  peatlands  brings  multiple  benefits,  as 
peatlands  improve  water  retention  and  quality,  store 
carbon, reduce GHG emissions and increase biodiversity. 

In  Portugal,  wetlands/peatlands  are  represented  by  13 
habitat  types listed in Annex I of the Habitats Directive 
(11 under the bogs, mires and fens group,  1 under the 
coastal  habitats  group  and  1  under  the  freshwater 
habitats  group).  These  habitat  types  are,  in  general, 

Portugal  20 

seriously threatened in Portugal. According to reporting 
under  Article 17  of  the  Habitats  Directive  for  the  latest 
reporting  period  (2013–2018),  83 %  of  assessments 
showed  an  unfavourable  conservation  status,  with  a 
wide range of important pressures and threats, including 
agriculture,  forestry,  human-induced  changes  in  water 
regimes,  development  and 
land  use,  tourism  and 
invasive alien species. 

Forest ecosystems 

Forests are important carbon sinks and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 
The EU forest strategy for 2030, adopted in July 2021, is 
a  plan  of  actions  to  promote  the  many  services  that 
forests  provide.  Its  key  objective  is  to  ensure  healthy, 
diverse  and  resilient  EU 
forests  that  contribute 
significantly to the achievement of the EU’s biodiversity 
and climate ambitions. About 27 % of the forest area in 
the EU is covered by habitat types listed in Annex I of the 
Habitats  Directive.  Moreover,  forests  host  several 
species  protected  under  the  Birds  and  Habitats 
Directives, 
is  a 
requirement  to  designate  Natura  2000  sites  and  to 
protect breeding sites and resting places. 

including  those  for  which  there 

Several  guidelines  on  forestry  management  were 
published in 2023 (54). They covered biodiversity-friendly 
afforestation, reforestation and tree planting; closer-to-
nature  forest  management;  and  defining,  mapping, 
monitoring  and  strictly  protecting  primary  and  old-
growth  forests.  Further  guidance  on  payment  schemes 
for ecosystems services has also been published. 

In  2023,  the  Commission  proposed  a  new  Forest 
Monitoring Law (55) that aims to create a comprehensive 
forest  knowledge  base,  address  information  gaps  and 
enable  a  better  response  to  growing  pressures  on 
forests. 

Assessments  show  that,  of  the  27 %  of  EU  forest  area 
protected under the Habitats Directive, less than 15 % is 
of  favourable  conservation  status (56).  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27 % in 2015 to 31 % in 2018. 

In  Portugal,  forests  covered  36.2 %  of  territory in 
2020 (57)  and  more  than  90 %  of  the  forest  habitat 
assessments under the Habitats Directive reveal a bad or 

(54) 

(55) 

the  European  Union, 

European  Commission:  Directorate-General  for  Environment, 
Guidelines on Closer to-nature Forest Management, Publications 
Office  of 
Luxembourg,  2023, 
https://op.europa.eu/en/publication-detail/-
/publication/2d1a6e8f-8cda-11ee-8aa6-01aa75ed71a1.  
European  Commission, 
Commission 
https://environment.ec.europa.eu/topics/forests/forest-
monitoring_en.  

‘Forest  monitoring’, 

European 
website, 

(56) 

(57) 

Union, 

EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
European 
2020, 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 
EEA,  forest  information  system  for  Europe,  ‘Countries –  FISE 
country  factsheets’,  forest  information  system  for  Europe 
website, https://forest.eea.europa.eu/countries. 

Luxembourg, 

2025 Environmental Implementation Review – Portugal 

 
 
 
poor  status (58)  (Figure 13).  Some  24 000 ha  in  Portugal 
are covered by primary forests (59). 

Wildfire  prevention 
resources for the bioeconomy. 

is  also  essential  to  preserve 

Portugal  21 

Figure 13:  Conservation  status  of  forests  protected 
under the Habitats Directive per Member State, 2013–
2018 (% of assessments) 

Source: Commission staff working document – New EU forest strategy 
for  2030,  SWD(2021) 652 
final  of  16 July  2021,  p. 24,  eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0652. 

. 

Among forest disturbances contributing to loss of forest 
integrity  and  related  biodiversity  loss,  wildfires  are  a 
particular  reason  for  concern.  In  2022,  the  EU  saw  a 
record number  (2 700) of wildfires affecting  more than 
30 ha,  which  led  to  the  destruction  of  785 605 ha  of 
forest,  the  second  highest  annual  figure  recorded. 
Recent  years  have  also  witnessed  the  occurrence  of 
widespread  uncontrollable  fires  (known  as  megafires), 
which are associated with loss of life and an enormous 
cost in terms of damage to the environment, businesses 
and  society  (over  EUR 2 billion  annually)  and  carbon 
dioxide  (CO2)  emissions.  Megafires  are  practically 
beyond fire suppression capacity and can be prevented 
only  by  an  integrated  risk  management  approach. 

(58) 

(59) 

(60) 

the 

base: 

Accompanying 

Commission staff working document – Stakeholder consultation 
and 
document 
evidence 
Communication 
from  the  Commission  to  the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – New EU forest 
strategy  for  2030,  SWD(2021) 652  final  of  16 July  2021, 
https://eur-lex.europa.eu/legal-
content/NL/TXT/?uri=CELEX:52021SC0652. 
European  Commission:  Joint  Research  Centre,  Mapping  and 
assessment  of  primary  and  old-growth  forests  in  Europe, 
Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
p. 13, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC124
671. 
Regulation (EU) No 995/2010 of the European Parliament and of 
the  Council  of  20 October  2010  laying  down the  obligations  of 
operators who place timber and timber products on the market 
(OJ  L 295,  12.11.2010,  p. 23),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010R0995. 

Under Component 8 “Forests” of the RRP Portugal, the 
“Programa MAIS Floresta” focuses on the difficulties of 
rural  areas.  The  decrease  in  population,  unfavourable 
economic conditions, lack of management/maintenance 
of  areas  and  fragmentation  of  rural  property,  factors 
that,  associated  with  the  exodus  of  the  population  to 
cities and the ageing of the rural population, contributed 
to  the  abandonment  of  spaces,  previously  treated;  for 
the uncontrolled growth of shrub and tree vegetation in 
these areas, increasing the potential risk of fire. 

The  measures  in  this  component  aim  to  transform  the 
landscape  of  vulnerable  and  unmanaged 
forest 
territories, with high fire risks, in order to prevent rural 
fires  and  increase  climate  and  economic  resilience, 
through programs to: Transformation of the landscape of 
vulnerable 
forest  territories;  Registration  of  rural 
property  and  land  occupation  monitoring  system;  Fuel 
management –  primary  network;  Means  of  preventing 
and fighting rural fires. 

The  EU  Timber  Regulation  (EUTR) (60)  prohibits  the 
placing on the EU market of illegally harvested timber. 

(EUDR) (61)  entered 

On  29 June  2023,  the  Regulation  on  Deforestation-free 
(62).  The 
Products 
regulation  seeks  to  guarantee  that  products  in  the  EU 
that are made using any of seven commodities have no 
links to deforestation. The EUDR repeals the EUTR. 

force 

into 

Marine ecosystems 

The  Marine  Strategy  Framework  Directive  (MSFD) (63) 
requires Member States to achieve good environmental 
status  (GES)  for  their  marine  waters.  To  that  end, 
Member States must draw up marine strategies for their 
marine waters and cooperate with other Member States 
sharing  the  same  marine  region  or  subregion.  These 

(61) 

Regulation (EU) 2023/1115 of the European Parliament and of 
the Council of 31 May 2023 on the making available on the Union 
market and the export  from the Union of certain commodities 
and  products  associated  with  deforestation  and 
forest 
degradation  and  repealing  Regulation  (EU)  No 995/2010  (OJ 
L 150,  9.6.2023,  p. 206),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461 

(62)   This  new  legislation  will  apply  to  large  and  medium-sized 
companies  starting  on  30  December  2025,  and  to  micro  and 
small enterprises starting on 30 June 2026. 

(63)  Directive  2008/56/EC  of  the  European  Parliament  and  of  the 
Council of 17 June 2008 establishing a framework for community 
action  in  the  field  of  marine  environmental  policy  (Marine 
Strategy  Framework  Directive)  (OJ  L 164,  25.6.2008,  p. 19), 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0056. 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
marine  strategies  comprise  different  steps  to  be 
developed and implemented over 6-year cycles. 

Since the 2022 EIR report, no additional data regarding 
Member  States’  set  of  GES  characteristics  for  each 
descriptor 
in  the  MSFD  have  become  available. 
Nevertheless, Member States have to report updates by 
October  2024,  and  these  will  be  assessed  by  the 
Commission.  In  the  context  of  this  next  round  of 
reporting, 
in  accordance  with  the  MSFD  and  the 
Commission  GES  Decision (64),  Member  States  must 
include  as  part  of  their  set  of  GES  characteristics  any 
threshold  values  for  the  descriptors  in  the  MSFD  that 
may  have  been  established  in  cooperation  with  other 
Member States at the EU or regional level (65). 

The  Commission  assessed  the  updated  monitoring 
programme reported by Member States in 2020 (66). At 
that  time  their  updates  on  the  elements,  features  and 
parameters identified monitoring gaps. The Commission 
recommended  that  Member  States  should  prioritise 
work 
levels  of 
implementation of the MSFD. 

those  gaps  at  all 

to  address 

Member States also reported their updated Programme 
of  Measures,  that  is  required  under  Article 13  of  the 
MSFD  and  that  must  be  updated  every  6  years.  The 
Commission has assessed Member States’ Programmes 
of Measures. 

Figure 14:  Level  of  adequacy  of  Portugal’s  updated 
programme of measures under  article 13 of the MSFD 
(2022 reporting exercise) 

Portugal  22 

While  moderate  progress  is  noted  in  some  areas, 
Portugal’s  updated  Programme  of  Measures  overall 
indicates  potential 
improvement  on  most 
descriptors. 

for 

Measures for sea-floor integrity (D6) for instance focus 
mostly on knowledge and monitoring activities of seabed 
habitats  rather  than  direct  actions  targeting  the  actual 
pressures such as dredging and trawler fishing. The same 
applies for measures addressing marine litter (D10) and 
underwater noise (D11). 

For  commercial  fish  and  shellfish  (D3),  eutrophication 
(D5) and contaminants in seafood (D9), no new measures 
specific  to  these  descriptors  were  reported,  leaving 
several important pressures insufficiently covered. 

Portugal received two priority actions in the 2022 EIR: i) 
Ensure regional cooperation with Member States sharing 
the  same  marine  (sub)region  to  address  predominant 
pressures;  and  ii)  Implement  the  recommendations 
made  by  the  Commission  in  the  2022  for  MSFD  legal 
reporting.  It  is  not  possible  to  evaluate  these  priority 
actions  currently  as  relevant  data  has  not  yet  been 
evaluated. 

2025 priority action: 

•  Report its updates on the assessment of the state of 
its marine waters, its targets, and its determinations 
of  GES (67)  which  are  expected  to  include  any 
threshold values for the descriptors in the MSFD that 
may  have  been  established  in  cooperation  with 
other Member States at the EU or regional level. 

Prevention and management of invasive alien 
species 

Invasive  alien  species  (IAS)  are  a  major  cause  of 
biodiversity  loss  in  the  EU.  Besides  inflicting  direct  and 
indirect damage on nature and the economy, some IAS 
also carry and spread infectious diseases, posing a threat 
to humans and wildlife. Regulation (EU) 1143/2014 (the 
IAS  regulation)  aims  to  prevent,  minimise  and  mitigate 
the  adverse  impacts  of  IAS  on  biodiversity.  It  focuses 
action  on  a  list  of  IAS  of  EU  concern  (the  ‘Union  list’), 

(64) 

(65) 

Commission  Decision  (EU)  2017/848  laying  down  criteria  and 
methodological  standards  on  good  environmental  status  of 
marine waters and specifications and standardised methods for 
repealing  Decision 
monitoring 
p. 43), 
(OJ 
2010/477/EU 
http://data.europa.eu/eli/C/2024/2078/oj. 
Communication from the Commission – Commission Notice on 
the threshold values set under the MSFD (Directive 2008/56/EC) 

assessment, 

18.5.2017, 

L 125, 

and 

and 

and  Commission  Decision  (EU)  2017/848  (OJ  C,  C/2024/2078, 
11.3.2024), http://data.europa.eu/eli/C/2024/2078/oj. 
Communication from the Commission – Commission Notice on 
recommendations on the 2020 updated reports for Article 11 of 
the  Marine  Strategy  Framework  Directive  (2008/56/EC)  (OJ 
C 165, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52023XC0510%2801%29. 
In accordance with Article 17 of Directive 2008/56/EC. 

10.5.2023, 

p.1), 

(66) 

(67) 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
which is regularly updated (68). 

The IAS Regulation (69) currently lists 88 species subject 
to  restrictions  on  keeping,  importing,  selling,  breeding, 
growing  and  releasing  into  the  environment.  Member 
States are required to take measures to (i) prevent the 
introduction of IAS, (ii) ensure early detection and rapid 
eradication  of  IAS  and  (iii)  manage  species  that  are 
already widespread on their territory. 

The  third  update  of  the  EU  list  entered  into  force  on 
2 August 2022. The fourth update is in preparation. The 
BDS further aims to decrease by 50 % the number of Red 
List species threatened by IAS. This aligns with target 6 of 
the GBF to reduce the introduction of IAS by at least 50 % 
by 2030 and minimise their impact. 

Preventing  the  introduction  and  spread  of  IAS,  and 
managing  them, 
including  through  eradication  and 
control,  can  result  in  a  substantial  cost  saving.  Studies 
estimate  that  the  total  cost  of  IAS  in  Europe  (damages 
and  management)  amounted  to  EUR 116.61 billion 
between  1960  and  2020 (70).  More  recent  studies  have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 
increasing  to  USD 148.2 billion  by  2040 (71),  and  at 
USD 423 billion annually at the global level (72). 

The total number of IAS of EU concern in the country is 
39. This includes 24 species recorded in the previous EIR 
(2021) and 15 new additions. Of these additions, 7 were 
already on the EU concern list in 2021, and 8 were added 
later  under  Commission  Implementing  Regulation  (EU) 
2022/1203. The spread of IAS in Portugal can be seen in 
Figure 15. 

(68) 

(69) 

Commission Implementing Regulation (EU) 2016/1141 of 13 July 
2016 adopting a list of  invasive alien species of Union concern 
pursuant  to  Regulation  (EU)  No 1143/2014  of  the  European 
Parliament  and  of  the  Council  (OJ  L 189,  14.7.2016,  p. 4),  as 
Implementing  Regulations  (EU) 
amended  by  Commission 
2017/1263,  (EU)  2019/1262  and  (EU)  2022/1203,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN. 
Regulation (EU) No 1143/2014 of the European Parliament and 
of  the  Council  of  22 October  2014  on  the  prevention  and 
management  of  the  introduction  and  spread  of  invasive  alien 

Portugal  23 

Figure 15:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Portugal, 2024 

As explained in the 2022 EIR, an infringement procedure 
was launched against Portugal for failing to establish and 
implement either a single action plan or a set of action 
plans fulfilling the requirements specified in Article 13 of 
the  IAS  Regulation  by  13 July  2019  and  to  transmit 
it/them to the Commission without  delay. Portugal has 
carried out the necessary actions and this case has been 
closed. 

2025 priority action 

• 

Step  up  implementation  of  the  IAS  Regulation, 
including  with  regard  to  enforcement  and  capacity 
of inspection authorities. 

Ecosystem assessment and accounting 

The  BDS  calls  on  Member  States  to  better  integrate 
biodiversity  considerations  into  public  and  business 
decision-making  at  all  levels  and  to  develop  natural 
capital accounting. 

(OJ 

L 317, 

4.11.2014, 

species 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R1143.  
(70)  Haubrock, P. J., Turbelin, A. J., Cuthbert, R. N. et al., ‘Economic 
costs of invasive alien species across Europe’, NeoBiota, Vol. 63, 
2021, pp. 153–190. 

p. 35), 

(72) 

(71)  Henry, M., Leung, B., Cuthbert, R. N. et al., ‘Unveiling the hidden 
economic  toll  of  biological  invasions  in  the  European  Union’, 
Environmental Sciences Europe, Vol. 35, No 1, 2023, p. 43. 
Platform 
IPBES 
on 
for 
Summary 
Biodiversity 
Policymakers –  Invasive  alien  species  assessment,  Bonn,  2023, 
https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 

Science-Policy 
Services), 

(Intergovernmental 

Ecosystem 

and 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
Portugal  24 

Back in 2007, the Portuguese Presidency of the Council 
of  the  European  Union  had  taken  the  initiative  to  hold 
the first EU Business and Biodiversity conference. 

In the 2022 EIR Portugal was given the following priority 
actions:  (i)  continue  to  support  the  mapping  and 
assessment  of  ecosystems  and  their  services  and  the 
development  of  ecosystem  accounting 
through 
appropriate  indicators  for  integrating  information  on 
ecosystem  extent,  ecosystem  condition  and  ecosystem 
services 
into  national  accounts;  and  (ii)  continue 
supporting  the  development  of  national  business  and 
capital 
biodiversity  platforms, 
accounting systems to monitor and value the impact of 
business on biodiversity. 

including  natural 

The  first  priority  action  cannot  be  assessed  due  to  the 
lack  of  data.  For  the  second,  some  progress  has  been 
made since Portugal now has an active network member 
of the EU Business & Biodiversity Platform. 

Similarly, target 14 of the GBF (73) aims to ensure the full 
integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 
accounting.  This  requires  effective  and  coherent 
biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (74) 

The  amended  Regulation  (EU)  691/2011  on  European 
introduces  new 
environmental  economic  accounts 
requirements  for  Member  States  to  report  on  the 
condition  of  ecosystems  including  urban  ecosystems, 
cropland,  grassland,  forest  and  woodland,  coastal 
beaches,  dunes  and  wetlands.  Data  reported  by  the 
Member  States  will  feed  into  the  second  European 
ecosystem assessment, due in 2027, and can also be used 
to support policy decisions. 

An ecosystem assessment is an analysis of the condition 
of ecosystems and the pressures acting on them, as well 
as  the  benefits  that  they  provide  to  people,  either 
directly or indirectly through the economy. 

An 
increasing  number  of  platforms,  networks  and 
communities of practice involve businesses in protecting 
biodiversity,  including  the  EU  Business  &  Biodiversity 
Platform (75). These platforms and communities are key 
tools  for  promoting  and  facilitating  natural  capital 
assessments  among  businesses  and  financial  services 
providers. 

Natural  capital  assessments  help  private  businesses  to 
better  understand  both  the  negative  and  positive 
impacts that they have on nature and to appreciate how 
nature contributes to their success. Such understanding 
contributes to the implementation of the EU’s BDS. 

Portugal  has  carried  out  a 
regional  ecosystem 
assessment in Alentejo, but upscaling it to national level 
is still lacking and a comprehensive approach is needed. 

Ecosystem  assessment  has  been  extended  to  5  of  the 
outermost EU regions (including Azores) and 10 overseas 
territories. 

(73)  Decision 15/4 adopted by the Conference of the Parties to the 
Convention  on  Biological  Diversity:  Kunming–Montreal  global 
biodiversity 
framework 
(https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-
en.pdf). 
European  Commission:  Joint  Research  Centre  and  EEA,  EU 
Ecosystem 
policymakers, 
Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
https://op.europa.eu/en/publication-detail/-

Assessment – 

Summary 

(74) 

for 

(75) 

/publication/81ff1498-b91d-11eb-8aca-
01aa75ed71a1/language-en. 
The  EU  Business  &  Biodiversity  Platform  (https://green-
business.ec.europa.eu/business-and-biodiversity_en)  aims  to 
promote  the  business  case  for  biodiversity  to  businesses  and 
financial institutions through workshops, seminars, reports and 
a cross-media communication strategy.  

2025 Environmental Implementation Review – Portugal 

 
 
 
 
 
 
 
 
 
 
 
 
 
Portugal  25 

3. Zero pollution 

Clean air

EU  clean  air  policies  and  legislation  have  successfully 
reduced  emissions  of  key  air  pollutants  and  significantly 
improved  air  quality,  which  is  now  moving  towards  the 
levels  recommended  by  the  World  Health  Organization 
(WHO).  This  has  resulted  in  clear  health  benefits  and 
reduced adverse impacts on ecosystems and biodiversity. 
However, to achieve the WHO-recommended levels, more 
efforts  are  needed,  including  full  compliance  with  EU 
legislation.  To  guide  these  efforts,  the  EU  zero  pollution 
action plan sets targets for 2030 relative to 2005. These 
are to reduce the health impacts of air pollution by 55 % 
and  to  reduce  the  EU  ecosystems  threatened  by  air 
pollution by 25 %. 

The EU has developed a comprehensive suite of air quality 
policies (76).  These  set  health-based  EU  air  quality 
standards (77)  and  stipulate  Member  States’  national 
emission  reduction  commitments (78)  for  several  air 
pollutants. 

On air pollution, Portugal presents a mixed picture. While 
emissions  of  several  air  pollutants  have  fallen  in  recent 
decades, air quality in Portugal continues to give cause for 
concern in some parts of its territory, mainly with regard 
to nitrogen dioxide (NO2). In particular, private transport 
exacerbates  problems  with  air  quality  and  traffic 
congestion  in  the  major  metropolitan  areas  in  Portugal 
(Lisbon,  Porto,  Braga),  leading  to  health  and  economic 
costs. 

The latest available annual estimates (for 2022) from the 
EEA (79) for Portugal attribute 3 600 deaths each year (or 
35 400 years  of  life  lost  (YLL))  to  fine  particulate  matter 
(PM2.5) (80);  710  deaths  each  year  (or  6 900  YLL)  to 
(NO2) (81); and 1 400 deaths each year (or  13 900 YLL) to 
ozone (82). 

Emissions  of  several  air  pollutants  have  decreased 
significantly in Portugal since 2005, while GDP growth has 
continued  (see  Figures 16  and  17).  According  to  the 
inventories submitted under Article 10(2) of the National 
Emission  reduction  Commitments  (NEC)  Directive (83)  in 
2024,  Portugal  met  its  emission  reduction  commitments 
for 2020–2029 for the air pollutants nitrogen oxides (NOx), 
non-methane  volatile  organic  compounds  (NMVOCs), 
sulphur dioxide (SO2) and PM2.5, and it did not meet them 
for  ammonia  (NH3).  According  to  the  latest  projections 
submitted  under  Article 10(2)  of  the  NEC  Directive, 
Portugal projects that it will meet its emission reduction 
commitments  for  2030  onwards  for  NOx,  NMVOCs,  SO2 
and NH3, but not for PM2.5. 

Figure 16: Emission trends of main pollutants / GDP in 
Portugal (%), 2005–2022 

200%

150%

100%

50%

0%

NH₃

PM2.5
PM2.5

NMVOC

SO₂

NOₓ

GDP

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

(76) 

(77) 

(78) 

(79) 

(80) 

European  Commission,  ‘Air’,  European  Commission  website, 
https://environment.ec.europa.eu/topics/air_en. 
European  Commission,  ‘EU  air  quality  standards’,  European 
website, 
Commission 
https://environment.ec.europa.eu/topics/air/air-quality/eu-air-
quality-standards_en.  
European  Commission,  ‘Reducing  emissions  of  air  pollutants’, 
European 
website, 
Commission 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants_en. 
EEA, Harm to human health from air pollution in Europe: Burden 
of  disease  2024,  briefing  No 21/2024,  Copenhagen,  2024, 
https://www.eea.europa.eu/en/analysis/publications/harm-to-
human-health-from-air-pollution-2024. 
Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) covering a wide range of sizes and chemical compositions. 
PM10 refers to particles with a diameter  of 10 µm  or less. PM2.5 

refers to particles with a diameter of 2.5 µm or less. PM is emitted 
from many human sources, including combustion. 

(82) 

(81)  NO2 pertains to a group of gases called NOx, which also includes 
nitrogen  monoxide.  NOx  is  emitted  during  fuel  combustion,  for 
example from industrial facilities and the road transport sector. 
Low-level  ozone 
is  produced  by  photochemical  action  on 
pollution.  This  year,  for  the  first  time,  the  impact  of  long-term 
exposure to ozone has also been taken into account. In previous 
analysis by the EEA, only the impact of short-term exposure was 
estimated. 

(83)  Directive (EU) 2016/2284 of the European Parliament and of the 
Council  of  14 December  2016  on  the  reduction  of  national 
emissions of  certain atmospheric pollutants, amending Directive 
2003/35/EC  and  repealing  Directive  2001/81/EC  (OJ  L 344, 
17.12.2016, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2016.344.01.0001.01.ENG. 

p. 1), 

2025 Environmental Implementation Review – Portugal 

 
 
 
Portugal  submitted  its  first  national  air  pollution  control 
programme (NAPCP) to the Commission on 1 April 2019. 
An update was due four years after that. Portugal also has 
to  update 
its  policies  and  measures  to  reduce  air 
emissions. 

Figure 17: PM2.5 and NOx emissions by sector in Portugal 
(%), 2022 

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5
PM2.5
4,23%

11,53%

NOₓ

0,59%

54,08%

41,30%

4,70%

38,22%

28,66%

2,72%

2,00%

5,46%

6,51%

Portugal  26 

The aim is that appropriate measures are put in place to 
bring all air quality zones into compliance. This case is still 
open,  and  the  Commission  is  assessing  the  measures 
adopted  by  Portugal  to  comply  with  the  ruling. 
Infringement  procedures  have  also  been  opened  for 
Member  States  not  meeting  the  emission  reduction 
commitments  for  2020–2029,  including  for  Portugal  for 
NH3. 

Portugal  has  not  yet  ratified  the  Persistent  Organic 
Pollutants  (POPs)  Protocol  under  the  United  Nations 
Economic Commission for Europe Air Convention. 

In the 2022 EIR, Portugal received three priority actions. 
The first was to further reduce emissions in the context of 
the  NAPCP.  Portugal  has  not  progressed  on  this,  as  the 
latest reported data show continued non-compliance with 
the  2020–2029  emission  reduction  commitment  for  NH3 
and also project non-compliance with emission reduction 
commitments  for  PM2.5  for  2030  onwards.  The  second 
priority action was to ensure full compliance with EU air 
quality  standards  and  maintain  downward  emission 
trends. Based on the latest data, Portugal has made some 
progress  in  this  regard.  However,  exceedances  of  limit 
values and target values remain for NO2 and ozone. Since 
2019, downward emission trends have been reported for 
all  main  air  pollutants,  except  for  NMVOCs,  which  have 
stayed constant. This situation requires further action. The 
third priority action received by Portugal was to ratify the 
POPs Protocol. Portugal has made some progress but still 
has not ratified protocol. 

2025 priority actions 

•  As  part  of  the  NAPCP,  take  action  towards  reducing 

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

• 

emissions of air pollutants. 
Ensure  full  compliance  with  the  current  AAQD 
standards, also in light of future stricter requirements 
under the revised AAQD. 

In  2023,  exceedances  above  the  limit  values  set  by  the 
Ambient Air Quality Directive (84) were registered for NO2 
in  two  air  quality  zones (85)  in  Portugal.  Furthermore,  in 
two  air  quality  zones,  the  target  values  for  ozone 
concentrations were also exceeded (86). 

Persistent  breaches  of  air  quality  requirements,  which 
have severe negative effects on health and environment, 
are  being  followed  up  by  the  European  Commission 
through  infringement  procedures  covering  all  Member 
States concerned, including Portugal. The Court of Justice 
of the EU delivered a judgment in 2023 over exceedances 
of  NO2  limit  values  (C-220/22;  Commission  v  Portugal) 
confirming  non-compliance  with  Directive  2008/50/EC. 

•  Accelerate  the  ratification  of  relevant  international 

conventions and protocols. 

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to: 
(i)  protect  air,  water  and  soil  and  to  prevent  harmful 

effects on human health and the environment; 

(ii)  prevent and manage waste; 
(iii) improve energy and resource efficiency; 
(iv) clean up contaminated sites. 
The  cornerstone  of  the  policy  is  the  Industrial  Emissions 

(84)  Directive  2008/50/EU  of  the  European  Parliament  and  of  the 
Council of 21 May 2008 on ambient air quality and cleaner air for 
Europe 
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0050. 

11.6.2008, 

L 152, 

p. 1), 

(OJ 

(85) 
(86) 

Entre Douro e Minho and Área Metropolitana de Lisboa Norte. 
Central 
Eionet 
EEA, 
(https://cdr.eionet.europa.eu/). 

Data 

Repository 

2025 Environmental Implementation Review – Portugal 

 
 
 
Portugal  27 

Directive (IED), which was revised in 2024 (87). The revision 
improves the directive’s contribution to the zero pollution 
objective. It has a strong focus on innovation, and builds 
solid  links  between  depollution,  decarbonisation  and 
circularity, making it a key regulatory tool to accompany 
the green transformation of EU industry by 2050. 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 (88). 

Portal, 
emissions-indicator. 

2024, 

https://industry.eea.europa.eu/analyse/industrial-

Overall,  industrial  emissions  to  water  in  the  EU  have 
decreased  over  time  for  all  the  main  pollutants.  On 
average  in  the  EU,  they  appear  to  be  decoupled  from 
industrial activity (expressed in GVA), which has increased 
over the same period, as shown in Figure 19. 

Figure 19: Industrial releases of pollutants to water and 
industrial activity in the EU-27 

In  Portugal,  around  800 
required to have a permit based on the IED. 

industrial 

installations  are 

The  industrial  sectors  in  Portugal  with  the  most  IED 
installations in 2018 were intensive rearing of poultry and 
pigs  (39 %),  waste  management  (14 %),  food  and  drink 
production (13 %), surface treatment of metals (11 %) and 
mineral production (5 %). 

Figure 18  shows  the  damage  to  health  and 
the 
environment due to the main industrial air pollutants. As 
this  depends,  among  other  factors,  on  the  size  of  the 
industrial  sector  in  each  Member  State,  the  figure  also 
shows  the  ratio  between  the  damage  and  the  industrial 
activity  (expressed  in  gross  value  added  (GVA)),  which 
gives an indication of the emissions  ‘intensity’. Although 
Portugal has the 15th highest level of damage in the EU, it 
ranks  11th  for  its  emissions  intensity,  above  the  EU 
average  of  EUR 27.5  per  EUR1 000  GVA.  The  main 
industrial  contributors  to  emissions  to  air  (89)  are  the 
energy sector and the mineral industry for NOX emissions, 
the waste management sector and chemical industry for 
dust emissions, and the energy sector, metals sector and 
mineral sector for SO2 and heavy metals. 

Figure 18:  Industrial  air  pollution  damage  and  intensity 
per Member State, 2021 

NB: Cd, cadmium; Hg, mercury; Ni, nickel; Pb, lead; total N, total nitrogen; 
total P, total phosphorus. 

Source:  EEA,  ‘Industrial  pollutant  releases to  water  in Europe’,  30 May 
https://www.eea.europa.eu/en/analysis/indicators/industrial-
2024, 
pollutant-releases-to-water. 

Concerning  Portugal  in  particular,  Figure 20  shows  the 
industrial emissions of heavy metals to water, taking into 
account  the  human  toxicity  of  each  metal,  as  well  as  its 
emissions 
intensity,  namely  the  ratio  of  toxicity  to 
industrial  activity  (expressed  in  GVA).  Portugal  has  the 
11th highest emissions of heavy metals to water in the EU 
and is in 6th position for emissions intensity (below the EU 
average intensity of 0.864 kg per EUR billion GVA). 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
air  pollution  damage  costs  intensity’,  European  Industrial  Emissions 

(87)  Directive  2010/75/EU  of  the  European  Parliament  and  of  the 
Council of 24 November 2010 on industrial and livestock rearing 
emissions (integrated pollution prevention and control) (OJ L 334, 
17.12.2010, p. 17),as amended by Directive (EU) 2024/1785 of the 
European  Parliament  and  of  the  Council  of  24 April  2024, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02010L0075-
20240804&qid=1725983863299.  

(88) 

(89) 

European 

Emissions 

EEA, 
Portal, 
Industrial 
https://industry.eea.europa.eu/, 2022 being the baseline year for 
all reports. 
European  Environment  Agency,  LRTAP,  Air  pollutant  emissions 
data viewer (Gothenburg Protocol, LRTAP Convention) 1990-2022, 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/air-pollutant-emissions-data-viewer-1990-2022. 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
Portugal  28 

infringements  of 

determine  effective,  proportionate  and  dissuasive 
penalties  applicable  to 
IED-based 
national provisions. In the revised directive, the provisions 
set that worst infringements can be sanctioned by fines of 
at least 3% of the annual EU turnover of the legal person. 
The revised IED will also introduce a right to compensation 
for  people  whose  health  has  been  harmed  by  such 
infringements. 

The development of best available techniques (BATs), BAT 
reference  documents  and  BAT  conclusions  ensures 
effective collaboration between stakeholders and enables 
better implementation of the IED. 

Since  the  2022  EIR,  the  Commission  has  adopted  BAT 
conclusions for (i) ferrous metal processing; (ii) the textiles 
industry;  (iii)  common  waste  gas  management  and 
treatment  systems  in  the  chemical  sector;  and  (iv) 
smitheries and foundries. 

The  Commission  relies  on  the  efforts  of  national 
competent  authorities  to  implement  the  legally  binding 
BAT  conclusions  and  associated  BAT  emission  levels  in 
environmental permits. This should result in considerable 
and continuous reductions in pollution. 

the 

In  Portugal,  considering 
IED 
legislation  and 
European 
Recommendation  2001/331/EC  of 
the 
Parliament and of the Council of 4 April 2001 providing for 
minimum  criteria  for  environmental  inspections  in  the 
Member States, there is a risk assessment system, and the 
data on IED environmental inspection work are published 
through  reports  and  information  on  the  website  of  the 
General Inspection of Agriculture, Sea, Environment  and 
Spatial  Planning  (Inspeção-Geral  da  Agricultura,  do  Mar, 
do Ambiente e do Ordenamento do Território (IGAMAOT), 
as well as annual activity inspections balance reports (90), 
which  include  enforcement  campaigns  or  environmental 
projects to support compliance in specific sectors. 

fulfils 

requirements  on 
the  mandatory 
Portugal 
environmental inspections, with a site visit taking place at 
least every 1–3 years, using risk-based criteria. During the 
inspection  activities  carried  out,  and  in  order  to  analyse 
and  verify  the  environmental  performance  of  the 
inspecting  operators,  the  implementation  of  the  BATs 
envisaged  in  the  sectoral  and  horizontal  BAT  reference 
documents is evaluated. 

When 
infringements  are  detected,  a  contravention 
procedure is instructed by IGMAOT, follow its legal terms, 
and is presented to court when applicable. Administrative 
issued,  when 
orders  to  correct 
necessary,  and  if  the  operator  does  not  comply  with  its 
terms, participation in disobedience, a criminal offence, is 
notified to the Public Prosecution Service. 

infringements  are 

Figure 20:  Industrial  releases  and  intensity  of  heavy 
metal emissions to water per Member State, 2022 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
water  pollution  intensity’,  European  Industrial  Emissions  Portal,  2024, 
https://industry.eea.europa.eu/analyse/industrial-emissions-indicator. 

As shown in Figure 21, the main industrial contributors to 
emissions  to  water  in  Portugal  are  the  pulp,  paper  and 
wood  industry  for  heavy  metals,  nitrogen,  total  organic 
carbon and total phosphorus and the waste management 
sector for heavy metals. 

Figure 21:  Relative  releases  to  water  from  industry  in 
Portugal (%), 2022 

100%

75%

50%

25%

0%

Heavy Metals
Ecotoxicity

Heavy Metals
Human Toxicity

Total nitrogen

Total organic
carbon (TOC)

Total phosphorus

Non-ferrous metal
Other waste management

Non-metallic minerals
Pulp, paper and wood

Other manufacturing
Refineries

Source: EEA, ‘Industrial reporting under the Industrial Emissions Directive 
2010/75/EU  and  European  Pollutant  Release  and  Transfer  Register 
Regulation (EC) No 166/2006 – ver. 12.0 Sep. 2024 (tabular data)’, EEA 
Geospatial 
2024, 
Catalogue, 
https://doi.org/10.2909/cf5e54c1-be99-4426-bcad-baa26c4f27a0. 

13 September 

Data 

IED  provisions  on  public  information  and  participation 
require Member States to adopt transposition legislation 
enabling members of the public to have access to relevant 
information  and  participate  in  the  approval  process  for 
potentially  polluting  installations.  Thus,  the  public  and 
(NGOs),  alongside 
non-governmental  organisations 
competent  authorities,  play  a  role 
in  ensuring  the 
compliance of these permits with EU legislation. The IED 
contains  mandatory  requirements  on  environmental 
inspections,  requiring  a  site  visit  to  take  place  at  least 
every 1–3 years, using risk-based criteria. In addition, IED 
enforcement  provisions  require  Member  States  to 

(90) 

These  reports  can  be  consulted  on  the  IGAMAOT  website 
(https://www.igamaot.gov.pt/pt/espaco-
publico/relatorios/inspecoes-ambientais-rei). 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
In  September  2022,  the  Commission  an  infringement 
procedure 
for  non-
(2022/2085)  against  Portugal 
conformity with the transposition of the IED; which led to 
a referral to the Court of Justice of the European Union in 
October 2024. The case is still pending before the Court. 

In  December  2024,  the  Commission  decided  to  open  an 
infringement procedure (2024/2224) against Portugal for 
non-conformity  with  the  transposition  of  the  Medium 
Combustion  Plants  Directive (91).  In  the  letter  of  formal 
notice, among other shortcomings, the Commission states 
that Portugal has not correctly transposed the Directive in 
relation  to  exemptions,  monitoring  of  emissions  and 
keeping obligations of the operator. 

In  the  2022  EIR,  Portugal  received  a  priority  action  to 
continue  addressing  emissions  from  the  energy  sector, 
especially from the Sines power plant, now closed. It is not 
possible to assess progress on this action because the last 
report  on  the  European  Industrial  Emissions  Portal  was 
submitted on 22 August 2022. 

2025 priority actions 

•  Reduce industrial air pollution damage and intensity. 
•  Reduce 
industrial  releases  to  water  and  their 

• 

• 

intensity. 
Engage  with  industry  and  environmental  NGOs  to 
ensure proper contribution to and implementation of 
BAT conclusions and ensure timely update of permits 
following publication of BAT conclusions. 
Ensure  effective  public  participation  and  access  to 
justice in relation with the IED. 

Major industrial accidents prevention – Seveso 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 
(i)  control  major-accident  hazards  involving  dangerous 

substances, especially chemicals; 

(ii)  limit  the  consequences  of  such  accidents  for  human 

health and the environment; 

(iii) continuously improve the prevention of, preparedness 

for and response to major accidents. 

The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive (92)). 

The overview below of industrial plants regulated by the 
Seveso III directive (‘Seveso establishments’) is based on 
data  reported  on  eSPIRS  (e-Seveso  Plants  Information 
Retrieval  System)  for  2022–2024 (93)  and  the  report  by 

(91)  Directive (EU) 2015/2193 of the European Parliament and of the 
Council  of  25 November  2025  on  the  limitation  of  emissions  of 
certain pollutants into the air from medium combustion plants (OJ 
https://eur-lex.europa.eu/legal-
L 313, 
content/EN/TXT/?uri=CELEX:32015L2193. 

28.11.2015, 

p. 1), 

Portugal  29 

Portugal on the implementation of the Seveso III Directive 
for 2019–2022 (94). 

in  2024,  among 

the  183  Seveso 
In  Portugal, 
establishments,  114  are  categorised  as 
lower-tier 
establishments  and  69  as  upper-tier  establishments 
(UTEs),  based  on  the  quantity  of  hazardous  substances 
likely  to  be  present.  UTEs  are  subject  to  more  stringent 
requirements.  The  number  of  Seveso  establishments  is 
presented in Figure 22. 

Figure 22: Number of Seveso establishments in Portugal, 
2018, 2022 and 2024 

NB: LTE, lower-tier establishment. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en 

Member  States  are  required  to  draw  up  external 
emergency  plans  (EEPs).  These  are  essential  to  allow 
proper  preparation  and  effective  implementation  of  the 
necessary  actions  to  protect  the  environment  and  the 
population should a major industrial accident occur. 

According to Portugal, in 2022, an EEP was required for all 
69 UTEs. In the same year, 49 UTEs had an EEP and 8 of 
those  had  been  tested  over  the  last  three  years.  A 
summary is shown in Figure 23. 

involving  dangerous  substances  (OJ  L 197,  24.7.2012,  p.1), 
https://eur-lex.europa.eu/eli/dir/2012/18/oj. 
https://espirs.jrc.ec.europa.eu/en/espirs/content; data extracted 
in September 2024.  
As provided for by Article 21(2) of the Seveso III Directive. 

(93) 

(94) 

(92)  Directive  2012/18/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2014  on  the  control  of  major-accident  hazards 

2025 Environmental Implementation Review – Portugal 

 
 
 
Figure 23: Situation regarding EEPs in Portugal, 2022 

NB: No data available for Greece. 

Portugal  30 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
https://op.europa.eu/en/publication-detail/-
Luxembourg, 
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en 

The information  for the public referred to in  Annex V to 
the Seveso III Directive – especially about how the public 
concerned will be warned in the event of a major accident; 
the  appropriate  action  to  take  in  the  event  of  a  major 
accident; and the date of the last site visit – is permanently 
available  for  77 %  of  the  Seveso  establishments 
in 
Portugal. 

The  shares  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  was  actively  made 
available  to  the  public  in  2022  in  all  Member  States  are 
presented  in  Figure 24.  Providing  this  knowledge  is  an 
important  provision  of  the  Seveso III  Directive,  as  the 
public’s awareness of this information may ameliorate the 
consequences of a major industrial accident. 

Figure 24: Share of UTEs for which information on safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public per Member State (%), 2022 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en 

It  should  be  noted  that  the  Commission  decided  in 
December  2024  to  open  an  infringement  procedure 
(2024/2225) against Portugal for non-conformity with the 
transposition  of  the  Seveso III  Directive.  In  the  letter  of 
formal  notice,  among  other 
the 
Commission  states  that  Portugal  has  not  correctly 
in  relation  to  provisions 
transposed  the  directive 
concerning  the  scope,  information  to  the  public  and 
emergency plans. 

shortcomings, 

In 2022, Portugal received priority actions to strengthen 
control and enforcement  to  ensure compliance  with  the 
Seveso III  Directive  provisions,  especially  on  EEPs.  Data 
reported on the implementation of the directive for 2019–
2022 in Portugal show that improvement is still needed in 
the number of EEPs established and tested over the last 
three years. 

2025 priority actions 

• 

• 

Strengthen  compliance  with  requirements  on safety 
measures  to  prevent  major  accidents  and  ensure 
appropriate preparedness and response for UTEs,  in 
particular  as  regards  review,  testing  and  update  of 
EEPs; at intervals of no longer than three years. 
Ensure  access  to  transparent  and  clear  information 
towards  citizens  on  risks  and  behaviour  in  case  of 
accidents. 

Mercury Regulation 

The  Mercury  Regulation  establishes  measures  and 
conditions concerning the use and storage of and trade in 
mercury,  mercury  compounds  and  mixtures  of  mercury, 
the manufacture and use of and trade in mercury-added 
products and the management of mercury waste, in order 
to ensure a high level of protection of human health and 
the  environment  from  anthropogenic  emissions  and 
releases of mercury and mercury compounds. The revision 
of the Mercury Regulation adopted in 2024 sets out rules 
to address the last intentional uses of mercury in the EU 
by  phasing  out  the  use  of  dental  amalgam  by  1 January 

2025 Environmental Implementation Review – Portugal 

 
 
 
Portugal  31 

2025 except when deemed strictly necessary by the dental 
practitioner  based  on  the  specific  medical  needs  of  the 
patient,  and  prohibiting  the  manufacture  and  export  of 
additional mercury-containing lamps from 1 January 2026 
or 1 January 2027 (depending on the lamp category). 

In 2019, 10 % of dental treatments were still using dental 
amalgam, which  represented a  challenge for Portugal to 
phase out its use by 1 January 2025. However, measures 
should  have  been  put  in  place  to  ensure  a  socially  and 
economically  sound  phasing  out,  including  adequate 
reimbursement for using alternatives to dental amalgam 
through  the  country’s  health  insurance  scheme  and  the 
training  of  dental  practitioners.  The  Commission 
is 
monitoring  whether  the  phasing  out  has  taken  place 
under the terms and conditions of the regulation. Portugal 
will also need to ensure that the manufacture and export 
lamps  are  prohibited  by  the 
of  mercury-containing 
deadlines set out in the Mercury Regulation. 

Noise 

The Environmental Noise Directive (95) requires a common 
approach to avoid, prevent and reduce the harmful effects 
of  noise.  The  designated  authorities  are  responsible  for 
making  and  approving  noise  maps  and  action  plans  for 
agglomerations,  major  roads,  major  railways  and  major 
airports.  Member  States  decide  on  noise  limits  that  are 
not  set  at  the  EU  level.  Nevertheless,  the  zero  pollution 
action  plan  sets  as  a  2030  target  a  30 %  reduction 
compared  with  2017  in  the  share  of  people  chronically 
disturbed by transport noise. 

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental health‐related issues in 
the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress (96). 

In Portugal, environmental noise is estimated to cause at 
least  around  90  cases  of 
ischaemic  heart  disease 
annually (97), some 40 000 people to suffer from disturbed 
sleep(98). 

Based on the latest set of information analysed, Portugal 
has completed its noise mapping of airports,  while noise 
mapping  of  agglomerations,  major  roads  and  major 
railways remains incomplete. 

Action  plans  for  noise  management  for  agglomerations, 
roads,  railways  and  airports  must  be  updated  and 
submitted  to  the  Commission  every  five  years.  The 
deadline for reporting noise action plans under the most 
recent  reporting  cycle  was  18 January  2025:  these  have 
not yet been assessed. 

There is an infringement procedure ongoing for Portugal 
related to a lack of reporting on the strategic noise maps 
and the adoption of noise action plans. 

Portugal received two priority actions in the 2022 EIR to 
complete noise mapping and noise action plans. There has 
been  no  progress  on  the  first  priority  action  on  noise 
mapping,  as  detailed  above.  Given  that  reporting  under 
the most recent reporting cycle for noise action plans was 
due 
in  early  2025,  these  have  not  been  assessed. 
Therefore,  these  priority  actions  are  maintained  for  the 
2025 EIR. 

2025 priority actions 

• 
• 

Complete noise mapping. 
Complete  and  implement  action  plans  on  noise 
management. 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional  waters,  coastal  waters  and 
freshwaters (including surface waters and groundwaters) 
be  significantly  reduced.  Achieving,  maintaining  or 
enhancing a good status of water bodies as defined by the 
Water  Framework  Directive  will  ensure  that  EU  citizens 
benefit  from  good-quality  and  safe  drinking  and  bathing 
water.  It  will  further  ensure  that  the  nutrient  cycle 
(nitrogen  and  phosphorus) 
in  a  more 
sustainable and resource-efficient way. 

is  managed 

(95)  Directive  2002/49/EC  of  the  European  Parliament  and  of  the 
Council  of  25 June  2002  relating  to  the  assessment  and 
management  of  environmental  noise –  Declaration  by  the 
Commission  in  the  Conciliation  Committee  on  the  directive 
relating  to  the  assessment  and  management  of  environmental 
noise (OJ L 189, 18.7.2002, p. 12), https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32002L0049.  

Copenhagen, 

(96)  WHO,  Environmental  Noise  Guidelines  for  the  European 
Region, 
2018, 
https://www.who.int/europe/publications/i/item/978928
9053563 
These figures are an estimation by the EEA based on (i) the data 
reported  by  Member  States  on  noise  exposure  covered  by 
Directive 2002/49/EC for the round of noise mapping of 2022; (ii) 

(97) 

European  Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Industrial  Pollution  (ETC/ATNI),  Noise 
Indicators  under  the 
Environmental Noise Directive 2021: Methodology for estimating 
missing data, Eionet report ETC/ATNI No 2021/06, Kjeller, 2021; 
and  (iii)  the  methodology  for  health  impact  calculations  in 
European  Topic  Centre  on  Air  Pollution  and  Climate  Change 
Mitigation  (ETC/ACM),  Implications  of  environmental  noise  on 
in  Europe,  Eionet  report  ETC/ACM 
health  and  wellbeing 
No 2018/10, 
2018, 
https://www.eionet.europa.eu/etcs/etc-atni/products/etc-atni-
reports/eionet_rep_etcacm_2018_10_healthimplicationsnoise.  

Bilthoven, 

(98)  More information on the adverse health effects of noise pollution 

is available at: 
https://www.eea.europa.eu/themes/human/noise/noise-2  

2025 Environmental Implementation Review – Portugal 

 
 
  
Water Framework Directive 

(WFD) (99) 

is  the 
The  Water  Framework  Directive 
cornerstone  of  the  EU  water  policy 
in  the  21st 
century (100).  The  WFD  and  other  water-related 
directives (101) form the basis of sustainable and integrated 
water management in the EU. They aim to achieve a high 
level  of  protection  of  water  resources,  prevention  of 
further  deterioration  and  restoration  to  good  status. 
These  objectives  are  very 
important  for  the  EU’s 
competitiveness,  strategic  autonomy  and  security,  yet 
have become even more challenging in the face of climate 
change affecting our precious water resources. 

The WFD establishes a procedural framework for reaching 
good  surface  water  ecological  and  chemical  status  and 
good groundwater quantitative and chemical status. This 
implies monitoring and classification of all water bodies, 
assessment of pressures and impacts and identification of 
the  most  cost-effective  measures  to  achieve  the 
objectives of the directive. The Directive dates from 2000 
and  set  an  initial  deadline  of  2015  for  achieving  its 
objectives, with the option to extend the deadline to the 
end of 2027. Every six years, Member States must report 
their  river  basin  management  plans  (RBMPs)  to  the 
Commission, they should cover river basin districts in their 
countries,  some  of  which  may  be  shared  with  other 
countries. The Commission has assessed the third cycle of 
RBMPs, which were to be submitted by March 2022, and 
has reported its findings to the European Parliament and 
to  the  Council  on  4  February  2025  for  most  of  Member 
States (102). 

Floods Directive 

Every six years, following the same reporting cycle as the 
RBMPs,  all  Member  States  also  report  their  flood  risk 

(99) 

https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32000L0060. 

(100)  https://environment.ec.europa.eu/topics/water_en. 
(101)  These  include  the  These  include  the  Groundwater  Directive 

the 

Floods 

Directive 

Standards 

(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex%3A32006L0118),  the  Environmental 
(https://eur-
Quality 
lex.europa.eu/eli/dir/2008/105/oj), 
Directive 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32007L0060), the Bathing Water 
(https://eur-lex.europa.eu/legal-
Directive 
content/EN/TXT/?uri=celex%3A32006L0007), 
Urban 
Wastewater 
(https://eur-
Directive 
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31991L0271), 
the 
(https://eur-
new 
lex.europa.eu/legal-
Nitrates 
content/EN/TXT/?uri=CELEX%3A32020L2184), 
Directive 
(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=celex%3A31991L0676), the Marine Strategy 
(https://eur-lex.europa.eu/legal-
Framework 
Directive 
IED 
content/en/TXT/?uri=CELEX%3A32008L0056) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075. 

Drinking  Water 

Treatment 

Directive 

and 

the 

the 

the 

Portugal  32 

management  plans  (FRMPs),  based  on  the  flood  risk 
hazard  maps  and  the  preliminary  flood  risk  assessments 
drawn up during the second cycle (2016–2021). 

Portugal  did  not  submit  the  third  RBMPs  and  second 
FRMPs  by  March  2022,  as  required  under  the  Water 
Framework  Directive  and  the  Floods  Directive.  The 
Commission  opened  an  infringement  procedure  for  late 
reporting  and  decided  to  refer  the  case  to  the  Court  of 
Justice of the EU. 

Portugal  finally  reported  its  third  RBMPs  and  its  second 
FRMPs by April 2024, and the infringement procedure was 
closed.  However,  as  a  result  of  this  late  reporting,  the 
Commission has not been in a position to assess the plans 
and include such an assessment for Portugal in its report 
to the European Parliament and to the Council issued on 4 
February 2025. 

As a consequence, the EIR cannot be updated for Portugal 
and reference is made to the 2022 EIR for the latest state 
of play (103). 

Drinking Water Directive 

The recast Drinking Water Directive is now applicable, and 
Member States were required to transpose its provisions 
into their national legal systems by 12 January 2023. Since 
into  force  of  the  recast  directive,  the 
the  entry 
Commission  has  adopted 
several  delegated  and 
list  of 
implementing  acts  establishing  (i)  a  watch 
substances  and  compounds  of  concern  for  drinking 
water (104); (ii) a methodology for measuring microplastics 
in  drinking  water (105);  and  (iii)  an  EU  system  for  testing 
and approving materials that are allowed to be in contact 
with drinking water (106). Member States will have to take 

(102)  European 

Commission, 

2025  

https://webgate.ec.europa.eu/circabc-ewpp/ui/group/c04f478b-
d4dc-44f9-a211-087c01165b2c/library/faada4be-9fc3-4a48-
b972-f71e356019d5?p=1&n=10&sort=modified_DESC. 

(103)  https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=comnat%3ASWD_2022_0270_FIN. 
(104)  https://environment.ec.europa.eu/publications/implementing-

decision-drinking-water-directive-watch-list_en. 

(105)  Commission Delegated Decision (EU) 2024/1441 of 11 March 2024 
supplementing  Directive  (EU)  2020/2184  of  the  European 
Parliament and of the Council by laying down a methodology to 
measure microplastics in water intended for human consumption 
(notified  under  document  C(2024) 1459)  (OJ  L,  2024/1441, 
21.5.2024), http://data.europa.eu/eli/dec_del/2024/1441/oj. 

(106)  OJ L, 

2024/365, 

23.4.2024, 
http://data.europa.eu/eli/dec_impl/2024/365/oj; OJ L, 2024/367, 
http://data.europa.eu/eli/dec_impl/2024/367/oj; 
23.4.2024, 
OJ L, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/369/oj;  OJ L,  2024/368, 
23.4.2024, http://data.europa.eu/eli/dec_impl/2024/368/oj; OJ L, 
23.4.2024, 
2024/370, 
http://data.europa.eu/eli/reg_del/2024/370/oj;  OJ L,  2024/371, 
23.4.2024,  http://data.europa.eu/eli/reg_del/2024/371/oj;  see 

2024/369, 

2025 Environmental Implementation Review – Portugal 

 
 
 
these  various  Commission  acts 
implementing the recast directive. 

into  account  when 

sources that can pollute groundwater and surface waters 
and by promoting the use of good farming practices. 

Portugal  33 

Finally,  the  Commission  has  now  received  data  from 
Member States on the quality of drinking water in 2017–
2019.  The  quality  of  drinking  water  (supplied  by  large 
water  suppliers) 
in  Portugal  does  not  give  rise  to 
concern (107). 

From  January  2026,  the  European  quality  standards  for 
per- and poly fluoroalkyl substances in drinking water will 
apply,  ensuring  harmonised  Member  State  reporting  of 
monitoring data on these substances in the future. 

Bathing Water Directive 

The  Bathing  Water  Directive  requires  Member  States  to 
monitor and assess bathing water. It requires that, during 
the  bathing  season,  Member  States  disseminate  to  the 
public information on bathing water quality actively and 
promptly. In particular, notices banning or advising against 
bathing should be rapidly and easily identifiable. 

In  2023,  out  of  the  667  Portuguese  bathing  waters,  575 
(86.2 %) were of excellent quality, 57 (8.5 %) were of good 
quality  and  11 
(1.6 %)  were  of  sufficient  quality 
(Figure 25).  Only  3  bathing  waters  (0.4 %)  were  of  poor 
quality and 21 were not qualified. 

Figure 25:  Bathing  water  quality  per  Member  State, 
Albania and Switzerland (%), 2023  

Source:  EEA,  European  Bathing  Water  Quality 
No 04/2024, 
https://www.eea.europa.eu/publications/european-bathing-water-
quality-in-2023/. 

in  2023,  briefing 
2024, 

Copenhagen, 

Nitrates Directive 

The  Nitrates  Directive (108)  aims  to  protect  water  quality 
across  Europe  by  preventing  nitrates  from  agricultural 

The  latest  Commission  report  on  the  implementation  of 
the  Nitrates  Directive,  dating  back  to  2021,  warns  that 
nitrates are still causing harmful pollution to water in the 
EU. Excessive nitrates in water are harmful to both human 
health  and  ecosystems,  causing  oxygen  depletion  and 
eutrophication. Cleaning of waters by national authorities 
or  farmers,  where  it  has  been  undertaken,  has  had  a 
positive  impact  on  the  drinking  water  supply  and  on 
biodiversity.  It  has  also  benefited  the  sectors –  such  as 
fisheries and tourism – that depend on biodiversity and on 
a good supply of drinking water. Nevertheless, excessive 
fertilisation remains a  problem in many parts of the EU. 
The  report  on  the 
implementation  of  the  Nitrates 
Directive covering 2020–2023 will be available in 2025. 

The analysis of Portugal’s RBMPs has identified nutrients 
important  pressure  on 
from  agriculture  as  an 
groundwater /  surface  water,  and  the 
impact  on 
waterbody status is one of the main factors in Portugal not 
meeting the Water Framework Directive objectives. 

2025 priority action 

• 

Tackle  nutrients  pollution,  especially  nitrates  from 
agriculture  through  the 
implementation  of  the 
Nitrates Directive. 

Urban Waste Water Treatment Directive 

The  Urban  Waste  Water  Treatment  Directive  (UWWTD) 
aims to protect human health and the environment from 
the  effects  of  untreated  urban  wastewater.  It  therefore 
requires Member States to collect and treat (secondary or 
biological  treatment)  waste  water  in  all  urban  areas  of 
more  than  2 000  people,  and  to  apply  a  more  stringent 
than  secondary,  with  nitrogen  and/or 
treatment 
phosphorus  removal,  to  the  wastewaters  generated  in 
urban areas, also known as agglomerations, of more than 
10 000 people, before they are discharged into waters and 
their  catchments  that  are  sensitive  to  nitrogen  and/or 
phosphorus 
(i.e.  eutrophic  or  tending  to  become 
eutrophic). 

Overall, in Portugal, the compliance rate was 82 % in 2020 
Some  56  agglomerations,  generating 
(Figure 26). 
2 367 950 population-equivalent of urban wastewater, did 
not comply with the requirements of the Directive. 

the  Commission  web  page  on  all  six  delegated  acts  for  more 
information 
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en). 

(107) 

In summary, the compliance for all parameter groups in Portugal 
was at least 99.49% in 2017, 99.68% in 2018 and 99.24% in 2019. 

(108)  https://eur-lex.europa.eu/legal-

content/EN/TXT/?qid=1561542776070&uri=CELEX:01991L0676-
20081211. 

2025 Environmental Implementation Review – Portugal 

 
 
 
Figure 26:  Proportion  of  urban  wastewater  that  fully 
complies with the UWWTD (%), 2020 

Source:  European  Commission,    12th technical  assessment  of  UWWTD 
implementation - Publications Office of the EU 

Portugal is the only EU Member State that has identified 
‘less  sensitive’  areas (109),  or  areas 
in  principle  not 
adversely affected by wastewater discharges due to their 
intrinsic features (110). 

Despite  the  improvement  in  compliance  over  the  years, 
for  which  the  availability  of  EU  funding  has  been 
fundamental,  Portugal  has  experienced  difficulties  in 
properly  implementing  the  UWWTD.  This  incomplete 
implementation has forced the Commission to take legal 
action  that  on  some  occasions  has  led  to  rulings  of  the 
Court of Justice of the EU, including Portugal having to pay 
a fine for one case that is already resolved. 

infringement 
The  Commission  has  currently  three 
procedures open against Portugal for poor application of 
the UWWTD. In one case, following a ruling of the Court 
of Justice, only the agglomeration of Funchal is pending, 
although compliance is likely to be achieved shortly. The 
other 
infringement 
procedures covering a certain number of agglomerations 
in breach of the UWWTD. 

two  cases  concern  horizontal 

Therefore, it is essential that Portugal takes the necessary 
measures  and  implement  projects  without  delay  to  fully 
comply  with  the  requirements  of  the  UWWTD,  taking 
advantage  of  the  available  EU  funding,  that  is,  the 
(ERDF),  the 
European  Regional  Development  Fund 
Cohesion  Fund  and  the  Recovery  and  Resilience  Facility 
(RRF). 

This  is  all  the  more  important  as  the  Directive  has  been 

Portugal  34 

for  micropollutants 

revised  and  strengthened  in  2024.  The  recast  Directive 
2024/3019  builds  on  the  current  acquis  strengthening 
existing  treatment  standards  and  establishing  a  new 
additional  treatment 
in  urban 
wastewater.  Other  new  requirements  relate  to  moving 
towards  energy  neutrality  in  the  sector,  establishing  an 
extended  producer  responsibility  scheme  to  ensure 
sustainable financing of micropollutant treatment by the 
most polluting industries and ensuring access to sanitation 
facilities,  especially  for  vulnerable  and  marginalised 
groups.  Portugal  has  until  31 July  2027  to  transpose  the 
new Directive into its national legal system. 

Portugal adopted in February 2024 the PENSAARP 2030, a 
national strategic plan for water supply, wastewater and 
pluvial water management. 

The  2022  EIR  included  as  a  priority  action  the  need  to 
complete  the  implementation  of  the  UWWTD  for  all 
agglomerations 
necessary 
building 
infrastructure  and by  developing the potential  for  water 
reuse.  Despite  some  progress,  Portugal  is  not  fully 
implementing  the  UWWTD,  and  further  efforts  are 
needed. 

the 

up 

by 

2025 priority action 

• 

the  necessary  measures 

Take 
full 
implementation  of  the  current  Urban  Wastewater 
Treatment  Directive,  taking  into  account  the  new 
requirements of the recast Directive. 

to  ensure 

Certain areas of Portugal suffer from water scarcity.  The 
water  exploitation  index  plus  (WEI+),  a  measure  of  how 
much  water  is  being  used  compared  with  the  total 
renewable  freshwater  resources  available  for  a  given 
territory  and  period,  shows  that,  especially  in  summer 
months,  the  country’s  total  water  consumption  exceeds 
its renewable freshwater resources (111). The highest WEI+ 
value (39)  was reached in the third quarter of 2022 and 
the  second  highest  value  (36)  in  the  third  quarter  of 
2019 (112). This seasonal index at  national  level does not 
reflect the situation at river basin level where more acute 
water stress can be recorded (113). 

The  challenges  faced  by  Portugal  because  of  climate 
change,  with  water  availability  falling  by  around  20 %  in 
the last 30 years and set to worsen in the future, and rising 
air  temperatures,  highlight  a  new  reality  for  which  it  is 
critical to find the best solutions for adaptation. 

(109)  For example, open bays, estuaries and other coastal waters with a 

good rate of water exchange. 

(110)  Portugal  reports  regularly  to  the  Commission  on  its  areas 
identified  as  less  sensitive  areas:  Cabo  da  Roca /  Estoril  and 
Madeira. 

(111)  Values above 20% are generally considered to be a sign of water 
scarcity,  while  values  equal  to  or  greater  than  40%  indicate 
situations of severe water scarcity. 

(112)  See  the  last  data from  the  European  Environment  Agency  (EEA) 
https://www.eea.europa.eu/en/analysis/indicators/use-of-
freshwater-resources-in-europe-1 

(113)  EEA, Seasonal water scarcity conditions for European sub-units for 
four  quarters  of  2022,  as  measured  by  WEI+. 

the 
https://www.eea.europa.eu/en/analysis/indicators/use-of-
freshwater-resources-in-europe-1/seasonal-water-scarcity-
conditions 

2025 Environmental Implementation Review – Portugal 

 
 
 
It is important to note that, in the framework of the 2024 
European Semester (114), Portugal has received a country-
specific recommendation (CSR-3) on water management 
and adaptation to climate change: 

• 

to 

strengthen 
Improve  water  management 
adaptation  to  the  effects  of  climate  change  and 
ensure 
long-term  economic  and  environmental 
resilience, by putting in place a strategy for integrated 
and  sustainable  water  management,  developing  its 
governance  structure,  promoting 
in 
wastewater collection and treatment, leaks reduction 
and water monitoring, while developing nature-based 
rehabilitation,  and 
solutions  and  water  body 
improving water efficiency and water reuse. 

investments 

Therefore, Portugal should take the necessary measures 
country-specific 
address 
to 
recommendation. 

comprehensive 

this 

In this sense, the Portuguese government has presented 
in  March  2025  a  new  far-reaching  national  strategy  on 
water  (“Water  that  Unites”)  that  aims  at  improving  the 
sustainable  management  of  water  resources  throughout 
the  country  by  promoting  integrated  water  governance, 
water efficiency and climate resilience. A long list of water 
investments is also envisaged. 

Several measures are under way to contribute to greater 
resilience. An example of this is the Algarve regional water 
efficiency  plan.  This  plan  was  presented  in  June  2024, 
during  an  EU  Green  Week  partner  event  dedicated  to 
water resilience in the Algarve region. 

(114)  European  Commission,  Recommendation 

for  a  Council 
recommendation on the economic, social, employment, structural 
and  budgetary  policies  of  Portugal,  COM(2024) 622  final  of 
19 June 
2024, 
https://commission.europa.eu/document/download/97267980-
f10e-4587-984f-
9d70e768b8bc_en?filename=com_2024_622_1_en.pdf. See CSR-
3 and Recital 26. 
(115)  Communication 

to 

from 

the  Commission 

the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Chemicals 
strategy  for  sustainability:  Towards  a  toxic-free  environment, 
COM(2020) 667 
final  of  14 October  2020,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A667%3AFIN;  Regulation 
(EC) No 1272/2008 of the European Parliament and of the Council 
of 16 December 2008 on classification, labelling and packaging of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
p. 1), 
L 353, 
https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2. 

31.12.2008, 

(OJ 

(116)  Namely,  Regulation 

(EC)  No 1907/2006  of  the  European 
Parliament  and  of  the  Council  of  18 December  2006  concerning 

Portugal  35 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects on human health and the environment. In October 
2020, the Commission published its chemicals strategy for 
sustainability  towards  a  toxic-free  environment (115), 
which  led  to  some  systemic  changes  in  EU  chemicals 
legislation. The strategy is part of the EU’s zero pollution 
ambition –  a  key  commitment  of  the  European  Green 
Deal. 

The  EU’s  chemicals  legislation (116)  provides  a  baseline 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating in the internal market. 

and 

enforcement 

Since 2007, the Commission has gathered information on 
the  enforcement  of 
the  Registration,  Evaluation, 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 
assessed  the  Member  States’  reports (117)  on  the 
implementation 
these 
regulations (118).  It  is  apparent  from  the  Commission’s 
in  the 
report  that  there  are  still  many  disparities 
implementation  of  the  REACH  and  CLP  Regulations, 
notably 
law  enforcement.  Recorded 
compliance  levels  in  Member  States,  generally  quite 
stable over time, appear to be getting slightly worse. This 
may be because (i) enforcement authorities are becoming 
detecting 
more 
non-compliant 
effective 
products/companies;  and 
(ii)  more  non-compliant 
products are being placed on the EU market. 

in  the  area  of 

of 

in 

p. 1), 

the  registration,  evaluation,  authorisation  and  restriction  of 
chemicals  (REACH),  establishing  a  European  Chemicals  Agency, 
amending Directive 1999/45/EC and repealing Council Regulation 
(EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as 
well as Council Directive 76/769/EEC and Commission Directives 
91/155/EEC,  93/67/EEC,  93/105/EC  and  2000/21/EC  (OJ  L 396, 
30/12/2006, 
https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32006R1907; and Regulation (EC) 
No 1272/2008 of the European Parliament and of the Council of 
16 December  2008  on  classification,  labelling  and  packaging  of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
L 353,  31.12.2008,  p. 1),  https://eur-
(OJ 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 
(117)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
2020, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 
In 
Article 46(2) of the CLP Regulation. 

line  with  Article 117(1)  of  the  REACH  Regulation  and 

Luxembourg, 

Union, 

(118) 

2025 Environmental Implementation Review – Portugal 

 
 
 
Portugal  36 

In  2020,  Portugal  participated  in  an  EU-coordinated 
enforcement  project  on  products  sold  online,  called  the 
REACH-EN-FORCE (REF)-8 project (123) (see Figure 27). The 
project  report  was  adopted  in  November  2021,  so  its 
findings could not be taken into account in the 2022 EIR. 

Figure 27: Compliance of imported products – results of 
the REF-8 project (%) 

In August 2021, the Commission published a measurable 
assessment  of the enforcement (119) of the two main EU 
regulations  on  chemicals  using  a  set  of  indicators  on 
different  aspects  of  enforcement.  Since  2021,  the  list  of 
chemicals  subject  to  restrictions  has  been  expanded  as 
new entries have been added to Annex XVII to the REACH 
Regulation (120). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (121).  The  new  hazard 
classes  cover  endocrine  disruptors  and  persistence-
related  hazards  while  the  revision  of  the  regulation 
encompasses  new  rules  on  online  sales  to  better  tackle 
non-compliances  observed  over  the  years.  Also  in  2023, 
the  Conference  of  the  Parties  of  the  Stockholm 
Convention (COP) decided to include, in its Annex A (which 
lists  banned  substances),  three  new  chemicals (122).  The 
Commission  is  working  on  the  delegated  acts  to  include 
these  substances  in  Annex I  to  the  POPs  Regulation  by 
2025 at the latest. 

Igamaot; 

Tax and Customs Authority; 

Portugal has various national enforcement authorities for 
the REACH and CLP Regulations, depending on the scope: 
• 
•  Authority for Economic and Food Safety; 
• 
•  Regional Inspectorate for Environment of Azores; 
•  Regional  Directorate  for  Environment  and  Climate 
Change,  Institute  of  Health  Administration,  and 
Regional  Authority 
for  Economic  Activities  of 
Madeira. 

A  Member  States  reporting  exercise  in  accordance  with 
Article 117 of the REACH Regulation and Article 46 of the 
CLP Regulation is conducted every five years. The results 
of the forthcoming exercise are expected in 2025, hence 
the  absence  of  new  nationally  specific  data  on 
enforcement since 2022. 

In  the  2022  EIR,  Portugal  had  devised  and  partially 
and  CLP  Regulation 
implemented  both  REACH 
enforcement  strategies.  Only  11  staff  members  were 
allocated  to  REACH  and  CLP  Regulation  enforcement, 
under IGAMAOT). 

(119)  European  Commission,  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  REACH  and  CLP 
Enforcement: EU-level enforcement indicators, Publications Office 
of 
2021, 
Union, 
https://op.europa.eu/en/publication-detail/-
/publication/e5c3e461-0f85-11ec-9151-01aa75ed71a1/. 

Luxembourg, 

European 

the 

(120)  For example, substances in tattoo inks and permanent make-up, 
N,N-dimethylformamide, 
formaldehyde 
releasers), lead in PVC (polyvinyl chloride), siloxanes (D4, D5, D6) 
and, finally, microplastics. 

formaldehyde 

(and 

(121)  Regulation (EU) 2024/2865 of the European Parliament and of the 
Council  of  23  October  2024  amending  Regulation  (EC)  No 
1272/2008 on classification, labelling and packaging of substances 

A risk assessment approach was used for the targeting of 
control  measures  in  order  to  maximise  the  chances  of 
finding  non-compliant  products.  Therefore,  the  non-
compliance  rates  presented 
in  Figure 27  cannot  be 
considered average for products in the EU. However, the 
proportion  of  non-compliance  cases  found  in  the  REF-8 
project are of concern. 

and mixtures, OJ L, 2024/2865, 20.11.2024, p.1 (Regulation - EU - 
2024/2865 - EN - EUR-Lex). 

(122)  For example. methoxychlor, dechlorane plus and UV-328. In the 
case of the pesticide methoxychlor, there are no exemptions from 
the ban. However, for the two plastic additives, dechlorane plus 
and  UV-328,  the  COP  decision  lists  some  time-limited  specific 
exemptions. 

(123)  European Chemical Agency, REF-8 project report on enforcement 
of the CLP, REACH and BPR duties related to substances, mixtures 
p. 20, 
and 
https://echa.europa.eu/documents/10162/17088/project_report
_ref-8_en.pdf/ccf2c453-da0e-c185-908e-
3a0343b25802?t=1638885422475. 

Helsinki, 

articles 

online, 

2021, 

sold 

2025 Environmental Implementation Review – Portugal 

 
 
 
Figure 28:  Number  of  REF-8  checks  performed  per 
100 000 inhabitants (EU average = 1.24) 

Portugal  37 

Portugal participated to a small extent in the REF-8 project 
(Figure 28). Online sales have been proven to correspond 
to  higher  non-compliance  rates  in  checks  performed 
across  the  EU,  in  particular  in  relation  to  imported 
products. 

In the 2022 EIR, Portugal received a priority action related 
to  the  upgrading  of  its  administrative  capacities  for 
implementing and enforcing a policy of zero tolerance of 
instances of non-compliance. In the absence of reporting 
since 2022, this priority action remains valid in 2025, partly 
because of the experience with the REF-8 project. 

2025 priority actions 

•  Upgrade 

the 

capacities 

in 
administrative 
implementation and enforcement to move towards a 
policy of zero tolerance of non-compliance. 
Increase involvement in the activities of the Forum for 
Exchange  of  Information  on  Enforcement  of  the 
European  Chemicals  Agency, 
the 
coordinated  enforcement  projects,  called  REF 
projects. 
Increase  customs  controls  and  controls  of  products 
sold online with regard to compliance with chemicals 
legislations. 

including 

in 

• 

• 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
 
 
 
Portugal  38 

4. Climate action

under  the  Effort  Sharing  Regulation;  and  (iii)  a  revised 
Regulation 
for  Land  Use,  Land  Use  Change  and 
Forestry (125). The package has been fully adopted, and the 
Member States have been implementing the legislation. 

The key strategic document at country level is the National 
Energy and Climate Plan (NECP) (126). Portugal submitted 
its  updated  plan  in  December  2024,  after  the  deadline 
set (127). The European Commission assessed the final plan 
and  the  extent  to  which  Portugal  has  followed  the 
recommendations for the draft version. 

The findings from the assessment are: 
• 

Emissions  under  the  Effort  Sharing  Regulation  will 
decrease  by  39%  in  2030  compared  to  2005,  and 
Portugal will o meet its target of 29%. 
Portugal is in line with its LULUCF target for the share 
of  renewable  energy  and  final  energy  consumption 
target. 

• 

To minimise the impacts of climate policies on vulnerable 
people  and  sectors,  Portugal  is  using  the  Just  Transition 
Fund,  the  Modernisation  Fund  and  will  use  the  Social 
Climate fund from 2026 (see Chapter 5). 

At the end of 2024, the Portuguese Government created 
the Agency for Climate to improve the coordination and 
efficiency of climate action, including the management of 
financial instruments (128). 

Figure 29:  Total  greenhouse  gas  emissions  (excluding 
international aviation) in Portugal, 1990–2022 

The impacts of climate change have continued to increase 
in recent years, inflicting damage and suffering in the EU 
and around the world. Globally, 2023 was the hottest year 
on  record,  while  Europe  has  been  warming  twice  as 
quickly  as  the  global  average  and  is  now  the  fastest-
warming  continent.  The  frequency  and  severity  of 
extreme  climate  events  are  also  increasing.  Against  this 
backdrop, the EU has demonstrated its determination to 
implement  the  European  Green  Deal  and  to  become 
climate neutral and resilient by 2050, ensuring sustainable 
competitiveness  and  supporting  EU  industry  in  the  net-
zero  transition.  The  European  Climate  Law  is  the  EU’s 
response  to  the  need  for  action.  It  sets  the  objective  of 
achieving climate neutrality by 2050 and a midterm target 
of a reduction in GHG emissions of at least 55 % by 2030 
and outlines the adaptation efforts necessary to adjust to 
climate  change’s  present  and  future  impacts.  Almost  all 
the  ‘Fit  for  55’  proposals  set  out  in  the  European  Green 
Deal  have  been  agreed 
law,  and  the  European 
in 
Commission  recommended  a  new  intermediate  climate 
target of a 90 % reduction in emissions by 2040. In 2024, 
the  Member  States  submitted  updated  national  energy 
and climate plans for 2021–2030, reflecting the increased 
ambition  of  the  revised  EU  legislation.  In  2024,  the 
European Commission also released, jointly with the EEA, 
the first-ever European climate risk assessment. 

Over  the  last  three  decades,  since  1990,  the  EU  has 
achieved  steady  decreases  in  its  emissions,  reaching  a 
running total in 2022 of –32.5 % (124). However, the EU and 
its Member States need to step up their implementation 
efforts and accelerate emissions reduction to stay on track 
to  reach  their  targets  of  a  55 %  reduction  in  net  GHG 
emissions  by  2030  and  climate  neutrality  by  2050. 
Between 1990 and 2022, net  GHG emissions of  Hungary 
decreased by 42 %, making it one of the countries with an 
above-average decrease. 

The  ‘Fit  for  55’  legislative  package  reflects  the  need  to 
speed up the green transition. It includes: (i) strengthening 
and expanding the EU emissions trading system (ETS), with 
the  creation  of  a  new,  second,  ETS  for  transport  and 
buildings together with a dedicated Social Climate Fund to 
help  citizens  during  the  transition;  (ii)  increasing  targets 

(124)  EU  net  domestic  emissions,  including  the  land  use,  land-use 
change and forestry (LULUCF) sector and excluding international 
aviation. 

(125)  A  full  overview  of  the  Fit  for  55  package  is  available  at 
https://commission.europa.eu/strategy-and-policy/priorities-
2019-2024/european-green-deal/delivering-european-green-
deal/fit-55-delivering-proposals_en. 

(126)  European  Commission,  ‘National  energy  and  climate  plans’, 

https://commission.europa.eu/energy-climate-change-

environment/implementation-eu-countries/energy-and-climate-
governance-and-reporting/national-energy-and-climate-
plans_en. 

(127)  Article  14  of  Regulation  2018/1999  on  the  Governance  of  the 

Energy Union and Climate Action. 

(128)  Decreto-Lei 

122/2024, 

31.12.24 

https://diariodarepublica.pt/dr/detalhe/decreto-lei/122-2024-
901661921. 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
Portugal  39 

The EU emissions trading system 

The  EU  ETS  is  the  key  tool  for  reducing  GHG  emissions 
cost-effectively across all Member States. It is the world’s 
biggest carbon market, covering around 40 % of the EU’s 
total GHG emissions from electricity and heat generation, 
the  manufacturing  industry,  aviation  within  Europe (129) 
and, from 2024, maritime transport also. 

The system sets a limit or cap on the total amount of GHGs 
that  can  be  emitted  at  the  EU  level.  Within  this  limit, 
companies buy emissions allowances (one allowance gives 
the  right  to  emit  1 tonne  of  CO2  eq.  (carbon  dioxide 
equivalent)),  in  auctions  or  through  trading  allowances 
with  others.  The  cap  is  reduced  annually  to  ensure  that 
overall  emissions  in  the  sectors  covered  decrease  over 
time. 

The emissions under the ETS decreased by 63 % from 2005 
to 2023. 

In  2023,  power  generation  was  responsible  for  32 %  of 
Portugal’s ETS emissions, a much lower share than in the 
EU  overall  (57 %) (130).  Of  the  total  emissions  from  all 
industry  sectors,  cement  and  lime  production  emitted 
43 %, refineries 27 %, and ‘other’ industries 27 %. In 2023, 
ETS emissions in Portugal were almost  half as high  as in 
2013.  The  reduction  of  ETS  emissions  has  largely  been 
driven  by  the  power  sector,  where  greenhouse  gas 
emissions  have  declined  by  69 %  since  2013.  Industrial 
emissions  from  cement,  lime  or  refineries  had  only 
modest emission reductions over the previous decade. 

From 2027, a new emissions trading system, called ETS2, 
for  buildings,  road  transport  and  additional  sectors, 
(mainly  industry  not  covered  by  the  current  ETS)  will 
become  fully  operational (131).  Member  States  should 
have  notified  full  transposition  the  provisions  of  the 
revised  EU  ETS  directive  related  to  the  new  ETS2  into 
national 
law  by  30 June  2024.  Portugal  did  not 
communicate  full  transposition  into  national  law  by  this 
deadline.  The  Commission 
therefore  opened  an 
infringement procedure against Portugal on 25 July 2024, 
by  sending  a  letter  of  formal  notice  for  failing  to  fully 
transpose the provisions into national law. In the absence 
of a satisfactory response, the Commission may decide to 
issue a reasoned opinion. 

The Commission also opened an infringement procedure 
against Portugal on 25 January 2024, by sending a letter of 
formal  notice  for  failing  to  fully  transpose  previous 
revisions of ETS Directives (132) into national law. Portugal 

(129)  Flights between the EU Member States including departing flights 
to Norway, Iceland, Switzerland, and the United Kingdom. 
(130)  EEA. EU Emissions Trading System (ETS) data viewer. EU Emissions 
Trading  System  (ETS)  data  viewer  |  European  Environment 
Agency's home page  

(131)  Directive 

(EU) 

2023/959 

(https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.ENG). 

has  since  notified  partial  transposition  of  either  one  or 
both  revisions  to  the  Commission.  In  the  absence  of  a 
complete  transposition,  the  Commission  may  decide  to 
issue a reasoned opinion. 

Effort sharing 

from  domestic  transport 

The  Effort  Sharing  Regulation  (ESR) (133)  covers  GHG 
(excluding  CO₂ 
emissions 
emissions  from  aviation),  buildings,  agriculture,  small 
industry and waste. Emissions from these sectors account 
for  around  60 %  of  the  EU’s  domestic  emissions.  The 
regulation  sets  the  EU-wide  target  to  reduce  emissions 
from the effort sharing sectors by 40 % by 2030 compared 
to 2005 levels. This overall target for the EU translates to 
binding  national  emission  reduction  targets  for  each 
Member State. Portugal‘s target is –28.7 %. 

In  addition  to  the  2030  targets,  Member  States  have 
annual GHG emissions limits (annual emission allocations), 
reducing every year until 2030. 

There  is  some  flexibility  to  take  account  of  annual 
fluctuations 
in  emissions,  by  trading  emissions  and 
transfers from the ETS and LULUCF. 

Based  on  historical  emissions  and  the  most  updated 
projections  Portugal  is  on  track  to  achieve  its  2030  ESR 
target.  Nevertheless,  excess  of  emissions  in  the  LULUCF 
sector automatically reduces ESR annual emission limits in 
2021–2025 (134).  Based  on  available  data,  Portugal  may 
struggle to stay within these limits each year in this period. 

Projected emissions are 13.3 percentage points above its 
2030 target. 

The largest  contributor is the domestic transport  sector, 
which accounted for 42 % of all effort sharing emissions in 
2022.  The  transition  to  sustainable  transport  is  slowly 
gaining  grounds  in  Portugal.  At  1.2 %  of  the  passenger 
vehicle fleet in 2022, the uptake of electric cars is close to 
the  EU  average.  The  country’s  7  200  publicly  accessible 
charging  points  provide  a  charging  point  for  every  18  e-
vehicles, far below the EU average of 1:10. 

The buildings sector is a significant concern for Portugal as 
well.  Even  though  emissions  decreased  by  41 %  from 
2005, Portuguese building stock’s energy performance is 
poor,  with  most  public  energy  efficiency  schemes  being 
one-off  measures,  not  always  taking  a  building’s  overall 
energy performance into account. Portugal needs to do a 

(132)  Directive - 2023/959 - EN - EUR-Lex and Directive - 2023/958 - EN 

- EUR-Lex. 
(133)  Regulation 

(EU) 

2018/842 

(https://eur-

lex.europa.eu/eli/reg/2018/842).  

(134)  See article 9(2) of Effort Sharing Regulation. 

2025 Environmental Implementation Review – Portugal 

 
 
Portugal  40 

Portugal is a hotspot of climate risks, including the regions 
most affected by climate change – Southern Europe, low-
lying  coastal  regions  and  outermost  regions  (Azores  and 
Madeira (135). 

Portugal  faces  water  management  challenges  due  to 
climate  change  and  has  a  wide  climate  protection  gap 
against  wildfires. Portugal remains vulnerable to climate 
change-related  extreme  events  such  as  floods,  coastal 
erosion,  droughts  and  heatwaves,  with  a  moderate 
climate  protection  gap  overall.  Water  management 
continues to be a major challenge, as Portugal is among 
the most drought-affected EU countries. 

Portugal adopted its climate adaptation law in 2021 and 
has national, regional and sectoral adaptation plans (136). 
It finalised a national roadmap for adaptation until 2100 
that assesses the impacts of global warming and outlines 
the  corresponding  adaptation  needs  and  will  inform  the 
review its adaptation strategy and spatial planning. 

Portugal  received  five  priority  actions  regarding  climate 
action in the 2022 EIR. 

There  is  still  little  visible  progress  in  decarbonisation  of 
transport  sector  and  in  renovation  of  buildings  stock. 
Progress  in  the  uptake  of  renewables  and  adaptation 
measures have been made, but more action is still needed, 
in particular as regards water management. 

In 2023, the application for classifying the 15 GWh lithium 
battery factory construction project in Sines as a Project of 
National  Interest  was  submitted  to  the  AICEP (137)  Two 
lithium  mining  projects  and  at  least  one  unit  for  lithium 
conversion are currently in progress. Stellantis Mangualde 
Plant  should produce fully  battery electric compact vans 
for Citroën, Fiat, Opel and Peugeot by 2025. 

2025 priority actions 

• 

Implement all polices and measures that are needed 
to  achieve  targets  laid  down  in  the  Effort  Sharing 
Regulation (ESR) and the Land Use, Land Use Change 
and  Forestry  (LULUCF)  Regulation.  More  detailed 
priority actions are set out in the assessment of the 
final National Energy and Climate Plan (NECP) (138). 

lot more to make a meaningful contribution to reaching its 
long-term renovation strategy target. 

Figure 30: Effort sharing emissions by sector, 2022 

Land use, land use change and forestry 

The LULUCF sector plays a significant role in achieving the 
EU’s climate neutrality goal. In the EU, this sector absorbs 
more GHGs than it emits, removing significant volumes of 
carbon  from  the  atmosphere.  Thus,  it  is  the  only  sector 
with negative emissions. 

Portugal’s forests are responsible for a major share of net 
carbon  removals  and  seem  to  have  partially  recovered 
from the decreased natural carbon sink  over 2009–2017 
caused by severe forest fires, among other phenomena. 

Portugal‘s target in 2030 is to enhance land removals by 
additional  –1.0  Mt  of  CO2  equivalent  compared  to  the 
yearly  average  of  the  period  2016–2018.  The  latest 
available projections show a surplus to target of −11.9 Mt 
of CO2 equivalent in 2030. Therefore, Portugal is on track 
to meet its 2030 target. 

Adaptation to climate change 

Halting  all  greenhouse  gas  emissions  would  still  not 
prevent  climate  impacts  that  are  already  occurring. 
Therefore,  adaptation  to  climate  change  is  also  a  key 
component of climate policy. 

(135)  EEA,  European  Climate  Risk  Assessment,  EEA  Report 01/2024, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
https://climate-adapt.eea.europa.eu/en/eu-adaptation-
policy/key-eu-actions/european-climate-risk-assessment.  

(136)    EEA, Climate-ADAPT country profiles. Country Profiles 
(137)  AICEP - Portuguese Trade & Investment Agency is the public body 
that promotes the attraction of productive inward investment and 

the  internationalization  of  the  Portuguese  economy,  fostering 
export  growth  and  the  international  expansion  of  Portuguese 
companies. 

(138)  European  Commission,  National  energy  and  climate  plans, 

https://commission.europa.eu/energy-climate-change-
environment/implementation-eu-countries/energy-and-climate-
governance-and-reporting/national-energy-and-climate-plans_en 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
 
 
 
Portugal  41 

Part II: Enabling framework – implementation tools 

5. Financing 

The  EU  budget  supports  climate  investment  in  Portugal 
with  significant  amounts  in  2021–2027,  with  revenues 
from  the  EU ETS  also  feeding  into  the  national  budget. 
During  2020–2022,  Portugal’s  revenues  from  auctioning 
reached  EUR 1 443 million  in  total,  with  almost  all  of  it 
spent on climate and energy. 

In  addition,  the  annual  investment  needed  to  meet  its 
environmental  objectives 
in  the  areas  of  pollution 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems is estimated to be around EUR 6.5 billion per 
year in Portugal. 

These  four  environmental  areas  currently  receive  total 
funding  of  nearly  EUR 5 billion  per  year;  thus,  there  is  a 
gap of EUR 1.6 billion per year. 

the 

annual 

Of 
gap, 
environmental 
EUR 0.8 billion  concerns  biodiversity  and  ecosystems, 
around  EUR 0.4 billion  concerns  water  and  around 
EUR 0.5 billion the circular economy objective. 

investment 

Climate finance landmarks 

EU funding for climate action 

The EU budget supports climate action in the EU-27 with 
EUR 657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy  provides  EUR 120 billion  (over  half  of  it  through 
CAP 
RRF 
the 
ERDF), 
EUR 145.9 billion (139). 

EUR 275.7 billion, 

and 

In  Portugal,  the  EU  cohesion  policy  (considering  EU 
contribution amounts) provides EUR 7.3 billion for climate 
action  in  2021–2027  (with  around  half  of  this  via  the 
ERDF), with a further EUR 160.4 million from the European 
Maritime, Fisheries and Aquaculture Fund (EMFAF) (140). 

(139)  European  Commission,  Statement  of  Estimates  of  the  European 
Commission –  For  the  financial  year  2025,  Publications  Office  of 
pp. 94–96, 
the 
https://commission.europa.eu/document/download/7a0420e1-
599e-4246-9131-ccb7d505d6d9_en?filename=DB2025-
Statement-of-Estimates_1.pdf. 

European  Union, 

Luxembourg, 

2024, 

(140)  See 

the 

Cohesion 

Open 

Data 

Platform 

(https://cohesiondata.ec.europa.eu/). 

(141)  EU  Commission  datasets,  and  the  Recovery  and  Resilience 
(https://ec.europa.eu/economy_finance/recovery-

Scoreboard 
and-resilience-scoreboard/index.html). 

The  RRF  contributes  to  climate  finance  in  Portugal  with 
EUR 9.2 billion  up  to  2026,  representing  41.2 %  of  the 
RRP (141). 

The  European 
(EIB)  provided 
Investment  Bank 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021 mid-2024 to support energy, transport and industry 
projects,  which  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 1.5 billion was assigned to 
Portugal in the reference period (142). 

National  financing, 
system revenues 

including  EU  emissions  trading 

to  EUR 256 million 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
in  2020, 
budgets,  amounted 
EUR 514 million  in  2021  and  EUR 673 million  in  2022,  in 
Portugal,  totalling  at  EUR 1 443 million  in  the  three-year 
period.  In  Portugal,  all  revenues  from  auctioning  are 
channelled  to  the  Environment  Fund  (alongside  other 
revenues),  which  finances  environmental  projects  that 
may or may not be directly related to climate objectives. 
The amounts reported as spent represent climate change 
and  energy  projects  paid  for  by  the  Environmental 
Fund (143). 

From the remaining part of the EU ETS revenues that feed 
into  the  Innovation  Fund  and  the  Modernisation  Fund, 
further  support  is  available  to  support  climate  action  at 
the EU level. 

the  environment 

It should be noted that investment in climate action also 
the 
supports 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (144). 

therefore, 

and, 

Environmental financing and investments 

investment  needs, 
This  section  describes  Portugal’s 
current  financing  and  gaps  as  they  relate  to  the  four 

(142)  A 

list  of 

financed  projects 

is  provided  by 

the  EIB 

(https://www.eib.org/en/projects/loans/index.htm). 

(143)  European  Commission:  Directorate-General  for  Climate  Action, 
Progress Report 2023 – Climate action, Publications Office of the 
European 
2023, 
https://climate.ec.europa.eu/news-your-voice/news/climate-
action-progress-report-2023-2023-10-24_en. 

Luxembourg, 

Union, 

(144)  NB:  Indirect  investments  (from  climate  and  other  policies)  in 

support of the environment are accounted for via the tracking. 

2025 Environmental Implementation Review – Portugal 

 
 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (145). 

The environment overall 

Investment needs 

The  overall  environmental 
investment  needs  to  be 
sufficient to enable Portugal to meet its objectives in the 
areas  of  pollution  prevention  and  control,  the  circular 
economy and waste, water protection and management, 
and biodiversity and ecosystems. The required investment 
is estimated to be EUR 6.5 billion per year (in 2022 prices). 

Of the estimated requirement, around EUR 1.5 billion per 
year, can be attributed to the need to support biodiversity 
and ecosystems. For pollution prevention and control, the 
annual 
to  be 
investment  needs  are  estimated 
EUR 1.1 billion, for water they are EUR 1.4 billion, and for 
the circular economy EUR 2.5 billion (in 2022 prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR 5 billion  in  Portugal  from  EU  and  national 
sources combined (in 2022 prices). 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 6.7 billion for Portugal in total, during 2021–2027 (or 
EUR 957 million per year) (see Table 1). 

Table 1: Key environmental allocations from EU funds to 
Portugal (million EUR), 2021–2027 

Instrument 

Cohesion policy 
ERDF 
Cohesion Fund 
Just Transition Fund 

CAP 
European Agricultural Guarantee Fund 
European  Agricultural  Fund  for  Rural 
Development 

EMFAF 

Other MFF sources 

RRF (d) (2021–2026) 

Allocations 

4 304.1 (a) 
3 118.0 
1 164.6 
21.5 
1 633.8 (b) 
754.5 
879.3 

58.8 

704.6 (c) 

 5 778 

Portugal  42 

European  Commission,  2021-2027  cohesion  policy  (planned) 
allocations  in  EU  amount  excluding  national  co-financing,  based 
on the tracking in the Common Provisions Regulation (CPR, 2021) 
Annex I. Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 
information: 
its  publication  date.  Source  and 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

further 

Regulation (EU) 2021/2115 of the European Parliament and of the 
Council  of  2 December  2021  establishing  rules  on  support  for 
strategic  plans  to  be  drawn  up  by  Member  States  under  the 
common agricultural policy (CAP strategic plans) and financed by 
the  European  Agricultural  Guarantee  Fund  (EAGF)  and  by  the 
European  Agricultural  Fund  for  Rural  Development  (EAFRD)  and 
repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013 
(OJ 
https://eur-
p. 1), 
lex.europa.eu/eli/reg/2021/2115. 

6.12.2021, 

Annex XI, 

L 435 

Note that 2021-2027 combines factual data for 2021 and 2022 and 
expenditure  under  the  relevant  specific  objectives  (SOs)  of  the 
CAP strategic plans from 2023, using the EU biodiversity tracking 
methodology. 
Commission. 
Source: 
https://commission.europa.eu/system/files/2023-
06/Biodiversity%20tracking%20methodology%20for%20each%20
programme%202023.pdf 

European 

Space  Fund,  Horizon  Europe,  financial 
environment and the Connecting Europe Facility. 

instrument  for  the 

Outside  the  MFF.  Note  that  the  RRF  applies  a  similar 
environmental tracking scheme (set in the RRF Regulation, Annex 
VI)  as  the  EU’s  cohesion  policy.  RRF  dataset  version  used:  July 
2024, prior to 2025 revisions. Source: European Commission. 

(a) 

(b) 

(c) 

(d) 

in  Portugal  by 

In 2021–2027, EU cohesion policy will support long-term 
investing 
development  objectives 
EUR 22.75 billion,  including  EUR 223.8 million  from  the 
new  Just  Transition  Fund  directed  to  alleviate  the 
socioeconomic impacts of the green transition in the most 
vulnerable  regions.  A  relevant  part  of  the  ERDF  and  the 
Cohesion Fund is devoted to environmental investments. 

It is worth recalling that the implementation of the ERDF 
for 2021–2027 is linked to the fulfilment of the enabling 
conditions, 
including  the  three  environmental  ones. 
Portugal  has  already  met  the  nature  enabling  condition, 
although  further  efforts  are  needed  to  comply  with  the 
waste and water enabling conditions. 

Portugal  also  participates  in  various  programmes  of 
territorial  cooperation  (transnational  and  cross-border 
cooperation) under the ERDF in which the environmental 
investments  carry  considerable  weight,  and  outstanding 
projects and good practices can be found (146). 

Environmental 
in  the 
Partnership  Agreement  for  2021–2027  and  the  different 

integration  has  been  ensured 

(145)  Research,  development  and  innovation  is  accounted  for  under 
each environmental objective. The financing needs, baselines and 
gap  estimates  are  based  on  the  Directorate-General  for 
Environment’s internal analysis (of 2024). Throughout this finance 
chapter,  specific  references are  provided to  the  most  important 
data sources used. 

(146)  Like the RISC_PLUS Interreg project, under the POCTEP 2021-2027, 
which  is  based  on  prevention,  preparedness  and  digitisation, 
aiming to strengthen resilience to the risks of floods and droughts 
derived  from  the  impact  of  climate  change  in  the  International 
Basins of the Miño and Limia Rivers, in Spain and Portugal. It aims 
to extend and improve the RISC_ML initiative supported under the 
POCTEP 2014-2020. https://risc-plus.eu/en/  

2025 Environmental Implementation Review – Portugal 

 
 
 
 
Portugal  43 

protection  investment  reached  EUR 731 billion  in  2020, 
rising  to  EUR 775 billion  in  2021,  representing  around 
0.4 % of GDP. 

protection 

investment 

Split  by  institutional  sector,  26 %  of  Portugal’s  national 
environmental 
(capital 
expenditure) comes from the general government budget, 
with 55 % coming from specialist private-sector producers 
(of environmental protection services  such as waste and 
water  companies)  and  19 %  from  the  business  sector, 
whose environmental activities are usually ancillary to its 
main  activities.  At  the  EU  level,  38 %  of  environmental 
protection  investment  comes  from  governments,  40 % 
from  specialist  private-sector  producers  and  22 %  from 
the general business sector (152). 

Portugal’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 5 billion  per  year  (in  2022 
prices), including EU funding, national public and national 
private expenditure. Of the total, the share of EU funding 
(including  EIB)  reaches  36 %,  with  around  64 %  national 
financing.  The  total  public  financing  (EU  plus  national 
public) represents 53 % of the total. 

The gap 

To meet its four environmental objectives beyond climate 
change, the additional investment need over the current 
levels  (i.e.  the  gap)  reaches  an  estimated  EUR 1.6 billion 
per  year  in  Portugal,  representing  around  0.65 %  of  the 
national GDP, which is lower than the EU average (0.77 %) 
(Figure 31). 

Programmes  for  the  ERDF,  Cohesion  Fund  and  Just 
Transition  Fund  through  the  application  of  the  Strategic 
Environmental  Assessment  (SEA)  Directive  and  by  other 
means. 

Portugal,  in  addition  to  receiving  EU  funds  earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
the  LIFE  programme (147) 
(EUR 5.4 billion),  Horizon 
Europe (148)  (EUR 95.5 billion),  the  Connecting  Europe 
Facility (149) 
InvestEU 
programme (150). 

(EUR 33.7 billion) 

and 

the 

Under  NextGenerationEU,  Portugal  is  set  to  receive 
EUR 22.2 billion (EUR 16.3 in grants and EUR 5.9 in loans) 
from  the  RRF.  Portugal’s  Recovery  and  Resilience  Plan 
(RRP) (151)  is  based  on  three  pillars:  resilience,  climate 
transition  and  digital  transition.  Portugal’s  revised  RRP 
(September  2024)  is  structured  in  21  components.  It 
includes 44 Reforms and 144 Investments. 

Portugal’s  RRP  supports  climate  objectives  through 
funding  of  EUR 9.2 billion  (41 %  of  total)  with  a  2.5 % 
additional amount for the environment (EUR 0.55 billion). 
The components more relevant for environmental topics 
are:  8  on  forests,  9  on  water  management,  12  on 
bioeconomy, and 10 on the sea. 

The  EIB  provided  around  EUR 842 million 
in  an 
environment-related  financial  contribution  to  Portugal 
from 2021 to mid-2024, most of which, EUR 578.2 million 
(69 %), is in the areas of sustainable energy, transport and 
industrial projects, which provides significant co-benefits 
such  as  reducing  air  pollution,  environmental  noise  and 
other pollution. 

The  EU’s  total  national  expenditure  on  environmental 
protection  (operating  plus  capital  expenditure)  was 
EUR 298 billion  in  2020  and  EUR 321 billion  in  2021, 
representing around 2.2 % of EU-27 GDP. In Portugal, total 
national  environmental  protection  expenditure  was 
EUR 3.3 billion 
in  2021, 
representing 1.6 % and 1.8 % of GDP, respectively. 

in  2020  and  EUR 3.9 billion 

Of  the  total  environmental  expenditure,  the  national 
capital  expenditure 
(investment)  on  environmental 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
0.4 % of the EU’s GDP. In Portugal, national environmental 

(147)  https://cinea.ec.europa.eu/programmes/life_en. 
(148)  European  Commission,  Horizon  Europe,  https://research-and-
innovation.ec.europa.eu/funding/funding-opportunities/funding-
programmes-and-open-calls/horizon-europe_en. 

(149)  The  Connecting  Europe  Facility  Transport  part  also  includes 
EUR 11.3 billion  transferred  from  the  Cohesion  Fund,  of  which 
30 % will be made available, on a competitive basis, to all Member 
States  eligible  for  the  Cohesion  Fund.  The  remaining  70 %  will 
respect the national envelopes until 31 December 2023. 

(150)  The  InvestEU  Fund  is  set  to  mobilise  over  EUR 372 billion  of 
investment through an EU budget guarantee of EUR 26.2 billion to 
back  the  investment  of  financial  partners such as  the  EIB  group 
and others. 

(151)  https://commission.europa.eu/business-economy-
euro/economic-recovery/recovery-and-resilience-
facility/country-pages/portugals-recovery-and-resilience-
plan_en. 
(152)  Eurostat, 

’Environmental  protection  expenditure  accounts’, 

env_ac_epea. 

2025 Environmental Implementation Review – Portugal 

 
 
Figure 31: Environmental financing, needs and gaps  per 
Member State (% of GDP) 

Total 

 1 554 

100.0 

0.65 

Source: Directorate-General for Environment analysis. 

Portugal  44 

Pollution prevention and control 

Investment needs 

In pollution prevention and control, Portugal’s investment 
needs  are  estimated  to  reach  EUR 1.2 billion  per  year 
(including  baseline  investments)  in  2021–2027.  Most  of 
this,  EUR 1 billion,  relates  to  air  pollution  control  to 
comply with the clean air requirements for the five main 
air  pollutants  under  the  NEC  Directive  by  2030.  The 
estimated  needs  to  reduce  environmental  noise  reach 
EUR 0.4 billion per year, most of which is delivered by the 
(same) sustainable energy and transport investments that 
also  benefit  clean  air (153).  Industrial  site  remediation 
requires  an  estimated  EUR 44 million  per 
year. 
Microplastics pollution and the chemicals strategy require 
around EUR 30 million per year (each) (154). 

Source: Analysis of Directorate-General for Environment. 

Current investments 

shows 

Table 2 
Portugal’s 
environmental  investment  gap  (expressed  in  various 
forms) by environmental objective. 

distribution 

the 

of 

Table 2: Summary of environmental investment gaps in 
Portugal per year, 2021–2027  

Environmental 
objective 

Investment gap per year  

%  
of total 

%  
of GDP 

Million 
EUR  
(2022 
prices) 

investment 

The  current 
levels  supporting  pollution 
prevention and control reach an estimated EUR 1.2 billion 
per year in Portugal in 2021–2027. Most of the financing 
concerns  clean  air  (EUR 1.1 billion  per  year).  Protection 
from environmental noise receives around EUR 1.4 billion 
per year, with a further 46 million for radiation protection 
and 27 million for site remediation a year. 

In Portugal, the EU MFF provides an estimated 24 % of the 
clean  air  financing  (mostly  via  cohesion  policy),  with  a 
further 52 % from the RRF, adding up to 76 % of the total. 
EIB financing contributes 6 % and national sources reach 
17 % (155). 

Pollution prevention 
and control 

Circular economy and 
waste 

Water management 
and water industries 

Biodiversity and 
ecosystems 

— 

— 

— 

The gap 

472 

30.4 

0.2 

 371 

23.9 

0.2 

805 

51.8 

0.3 

To meet its environmental objectives concerning pollution 
prevention and control (towards zero pollution), Portugal 
needs to provide some additional tens of millions of euros, 
in  the  areas  of  site  remediation,  chemicals  and 
microplastics, 
adequate 
The 
implementation  of  the  NECP  with  the 
investments 
included  for  sustainable  energy  and  transport  would 

together. 

taken 

(153)  2021 

assessment 

Phenomena 

project 
(https://op.europa.eu/en/publication-detail/-
/publication/f4cd7465-a95d-11eb-9585-01aa75ed71a1)  and  the 
Directive 
Commission’s 
implementation 
report 
(https://environment.ec.europa.eu/system/files/2023-
03/COM_2023_139_1_EN_ACT_part1_v3.pdf). 

Environmental 

Noise 

2023 

(154)  European  Commission,  Third  Clean  Air  Outlook,  Brussels,  2022, 

https://environment.ec.europa.eu/topics/air/clean-air-
outlook_en. See also the impact assessment for the revision of the 
AAQD, available from the Commission web page on the proposed 
revision 

(https://environment.ec.europa.eu/publications/revision-eu-
ambient-air-quality-legislation_en). 

(155)  Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure (EPEA accounts, Eurostat). Note that the bulk of clean 
air  financing  is  provided  as  a  contribution  from  climate  (energy 
and  transport)  measures,  as  per  the  tracking  schemes  in  the 
Common  Provisions  Regulation  Annex  I  and  the  RRF  Regulation 
Annex  VI.  Further 
tracking: 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 

information  on  clean  air 

2025 Environmental Implementation Review – Portugal 

 
 
 
largely deliver the necessary investments for clean air and 
noise. 

According to the latest (2023) NAPCP review report (156), 
Portugal did not comply with NH3 reduction requirements 
in 2020 and 2021, while it is not at risk of non-compliance 
for  NH3  and  other  air  pollutants  concerning  the  NEC 
Directive  2030  emission  reduction  commitments,  based 
on the policies and measures in its NAPCP that takes into 
account  climate,  energy  and  CAP  plans  and  financing 
baselines. 

Circular economy and waste 

Investment needs 

Portugal’s  investment  needs  in  circular  economy  and 
waste  reach  EUR 2.5 billion  per  year  (including  baseline 
investments).  Most  of  this,  around  EUR 2.1 billion  per 
year, relates to circular economy measures in the mobility, 
food  and  built  environment  systems,  with  a  further 
for  waste  management 
EUR 0.4 billion  necessary 
(municipal  and  packaging  waste),  covering  waste 
collection,  biowaste  treatment;  recycling  reprocessors; 
waste-sorting  facilities;  and  digitalisation  of  the  waste 
registry. The amount for waste excludes the investments 
needed for the uptake of circularity and waste prevention 
across the economy (157). 

Current investments 

Circular economy investments across the economy reach 
around EUR 1.7 billion per year in Portugal in 2021-2027, 
with  a 
for  waste 
further  EUR 0.3 billion  provided 
management that does not constitute circular economy. 

Around 4 % of this combined financing for circularity and 
waste  comes  from  the  EU  MFF,  with  a  further  0.1 % 
contribution from the RRF, coming to 4.1 % combined. EIB 
loans  identified  in  support  of  circularity  and  waste 
represent 1.3 % of the total. The share of national sources 
is  absolutely  overwhelming,  reaching  95 %  of  the  total 
financing (158). 

(156)  European Commission, ‘National air pollution control programmes 
website, 
European 

projections’, 

and 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants/national-air-pollution-control-
programmes-and-projections_en. 

Commission 

(157)  See Systemiq and Ellen MacArthur Foundation, Achieving ‘Growth 
Within’, 2017; and European Commission: Directorate-General for 
Environment, Study on investment needs in the waste sector and 
on  the  financing  of  municipal  waste  management  in  Member 
States,  Publications  Office  of  the  European  Union,  Luxembourg, 
https://op.europa.eu/en/publication-detail/-
2019, 
/publication/4d5f8355-bcad-11e9-9d01-01aa75ed71a1. 

(158)  Waste management and circular economy expenditure tracking in 
the  EU  funds,  EIB  projects  and  in  the  national  expenditure 

Portugal  45 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  Portugal  needs  to  increase 
investments  by  an  estimated 
circular  economy 
EUR 356 million 
additional 
EUR 116 million  concerning  waste  management  action, 
not  belonging  to  circular  economy.  Combined,  this 
amounts to EUR 472 million per year, representing 0.20 % 
of Portugal’s GDP. 

year,  with 

per 

an 

Of  the  circular  economy  gap,  EUR 93 million  relates  to 
recent  initiatives,  such  as  the  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 
digital  tools,  CRM  recycling,  and  measures  proposed 
under the amendment of the Waste Framework Directive, 
and EUR 263 million constitutes further investment need 
to unlock Portugal’s circular economy potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 1426 million  (in  2022  prices) 
in  Portugal.  This 
comprises investment needs both for the water industry 
and for the protection and management of water. Of the 
total  annual  need,  EUR 627 million  relates  to  the 
management  of  wastewater  (also  including  additional 
costs  associated  with  the  revised  UWWTD),  a  further 
EUR 706 million  is  necessary  for  drinking  water-related 
investments and around EUR 85 million for the protection 
and management of water (159). 

Current investments 

this, 

EUR 311 million 

Water investments in Portugal are estimated to be around 
EUR 1 054 million per year (in 2022 prices) in 2021–2027. 
Of 
supports  wastewater 
management, EUR 595 million drinking water and around 
the  Water 
EUR 144 million 
Framework  Directive 
and 
protection). 

the  other  aspects  of 

(water  management 

Of the total financing,  13.9 % is provided by the EU MFF 
(mostly  through  cohesion  policy),  with  a  further  5.8 % 
support  from  the  RRF,  reaching  19.7 %  combined.  EIB 

(Eurostat).  Datasets:  EPEA  accounts  (env_epi)  and  circular 
economy private investments (cei_cie012). 

(159)  See  European  Commission,  ‘Estimating  investment  needs  and 
financing capacities for water-related investment in EU Member 
States’, 
2020, 
28 May 
https://commission.europa.eu/news/estimating-investment-
needs-and-financing-capacities-water-related-investment-eu-
member-states-2020-05-28_en;  and  OECD,  Financing  Water 
Supply, Sanitation and flood Protection: Challenges in EU Member 
States  and  policy  options,  OECD  Publishing,  Paris,  2020, 
https://www.oecd-ilibrary.org/environment/financing-water-
supply-sanitation-and-flood-protection_6893cdac-en. 

2025 Environmental Implementation Review – Portugal 

 
 
financing  is  around  0.8 %  of  the  total,  while  the  bulk  of 
financing comes from national sources (79.5 %) (160). 

The gap 

To  meet  the  various  environmental  targets  under  the 
Water  Framework  Directive  and  the  Floods  Directive, 
Portugal’s water investment gap reaches EUR 371 million 
per year (0.16 % of GDP),  with  EUR 316 million linked to 
wastewater  measures.  Drinking  water  measures  require 
an additional EUR 110 million per year. 

It should be noted that Portugal adopted in February 2024 
the  PENSAARP  2030,  the  new  national strategic  plan  for 
water supply, wastewater and pluvial water management, 
envisaging  an 
for 
wastewater  management  and  EUR 400 million  for  urban 
run-off (ideal scenario). 

investment  of  EUR 3 159 million 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 1.5 billion per year (in 2022 prices) in 
Portugal 
includes  the  following 
financing needs: 

in  2021–2027.  This 

•  Portugal’s  Prioritised  Action  Framework (161)  (PAF), 
concerning  the  Natura  2000  areas:  EUR 207 million 
per year, mostly running costs; 

•  Additional  Biodiversity  Strategy  to  2030 (162)  costs: 
EUR 896 million per year on top of the PAF, and, 
Sustainable 
EUR 367.2 million per year. 

management (163) 

costs: 

soil 

• 

Current investments 

The current level of biodiversity financing is estimated to 
be EUR 665 million per year (in 2022 prices) in 2021–2027. 
72.5 %  of  the  financing  is  considered  direct  financing  to 
biodiversity  and  ecosystems,  with  a  100 %  coefficient  in 
the tracking schemes. 

10.7 % of the total financing is estimated to come from EU 
cohesion  policy,  32.9 %  from  the  CAP,  7 %  from  Horizon 
Europe,  and  around  2.7 %  from  LIFE  and  1.1 %  from 
EMFAF. The EU MFF altogether accounts for 55.3 % of the 
financing and the RRF for 10.1 %, adding up to a total of 
65.4 % from the EU budget. The rest, 34.6 %, comes from 
national sources. 

(160)  Water investment levels are estimated through tracking EU funds, 
EIB projects and national expenditure (EPEA accounts, Eurostat). 
(161)  European Commission, ‘Financing Natura 2000 – Prioritised action 
website, 

European 

frameworks’, 
https://environment.ec.europa.eu/topics/nature-and-
biodiversity/natura-2000/financing-natura-2000_en.. 

Commission 

(162)  European  Commission:  Directorate-General  for  Environment, 
Biodiversity  Financing  and  Tracking –  Final  report,  Publications 
2022, 
Office 

European  Union, 

Luxembourg, 

the 

of 

Portugal  46 

Portugal has programmed a relatively high share (20.3 %) 
of  its  CAP  funds  for  2021–2027  for  biodiversity  support 
measures. On the other hand, 4.5 % (below EU average) of 
its cohesion policy EU contribution amount is dedicated to 
biodiversity  (disregarding  ESF+),  as  well  as  2.3 %  of  RRF 
funding (see Figure 32). 

Figure 32: 2021–2027 contributions to biodiversity from 
the main EU instruments per Member State ( % of policy 
total) 

NB: ESF+, European Social Fund Plus. 

The gap 

To  meet  the  environmental  objectives  concerning  the 
protection and restoration of biodiversity and ecosystems 
and  other  relevant  horizontal  measures,  Portugal’s 
investment gap is estimated to be around EUR 805 million 
per year, corresponding to 0.34 % of its GDP. 

Public financial management 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools to 
achieve climate and environmental goals. Some Member 
States,  including  Portugal,  already  use  green  budgeting 
tools  for  identifying  and  tracking  green  expenditures 

https://op.europa.eu/en/publication-detail/-
/publication/793eb6ec-dbd6-11ec-a534-
01aa75ed71a1/language-en. 

(163)  Proposal  for  a  directive  of  the  European  Parliament  and  of  the 
Council  on  soil  monitoring  and  resilience  (Soil  Monitoring  Law) 
2023, 
COM(2023) 416 
https://environment.ec.europa.eu/publications/proposal-
directive-soil-monitoring-and-resilience_en. 

5 July 

final 

of 

2025 Environmental Implementation Review – Portugal 

 
 
 
and/or  revenues (164).  Green  budgeting  practices (165) 
provide  increased  transparency  on  the  environmental 
implications of budgetary policies. 

The  Commission  has  developed  a  non-mandatory  green 
budgeting  reference  framework  that  brings  together 
methodologies  for  assessing  the  impacts  of  budgets  on 
climate and environmental goals (166). 

To help Member States develop national green budgeting 
and  thereby  improve  policy  coherence  and  support  the 
green  transition,  the  Commission  facilitated  a  Technical 
Support Instrument (TSI) project on green budgeting from 
2021 to  2024 (167).  Portugal  participated,  taking  steps 
towards its own green budgeting tagging methodology. 

Beyond green budgeting, to improve policy outcomes, the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (168)  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

Total environmental taxes amounted to EUR 4.7 billion in 
Portugal  in  2022,  representing  1.9 %  of  its  GDP  (EU 
average  2.0 %)  (Figure 33).  Energy  taxes  formed  the 
largest component of environmental taxes, accounting for 
1.4 % of GDP, which is lower than the EU average of 1.6 %. 
Transport  taxes,  at  0.5 %  of  GDP,  were  above  the  EU 
average (0.4 %), while taxes on pollution and resources, at 
0.03 %,  were  under  the  EU  middle  value  (EU  average 
0.08 %). 
in  Portugal 
accounted  for  5.3 %  of  total  revenues  from  taxes  and 
social security contributions (slightly under the EU average 
of 5.0 %) (169). 

In  2022,  environmental  taxes 

(164)  European  Commission,  Green  Budgeting  in  the  EU.  Key  Insights 
from the 2023 European Commission Survey of Green Budgeting 
Practices, 
https://economy-
finance.ec.europa.eu/economic-and-fiscal-governance/national-
fiscal-frameworks-eu-member-states/green-budgeting-
eu_en#:~:text=European%20Commission%20Green%20Budgetin
g%20Survey%C2%A0. 

2023, 

(165)  https://economy-finance.ec.europa.eu/economic-and-fiscal-
governance/national-fiscal-frameworks-eu-member-
states/green-budgeting-eu_en. 

(166)  European  Commission, 

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

reference 
finance.ec.europa.eu/economic-and-fiscal-governance/green-
budgeting-eu_en. 

(167)  https://reform-support.ec.europa.eu/what-we-
do/revenue-administration-and-public-financial-
management/supporting-implementation-green-
budgeting-practices-eu_en. 

Portugal  47 

Figure 33: Environmental taxes per Member State, 2022 

The EU Green Deal emphasises the role of well-designed 
tax  reforms  (e.g.  shifts  from  taxing  labour  to  taxing 
pollution) to boost economic growth and resilience, and to 
foster  a  fairer  society  and  a  just  transition  through  the 
right price signals. The Green Deal promotes the ‘polluter-
pays  principle’,  which  makes  polluters  bear  the  costs  to 
prevent, control and remedy pollution. 

According to a 2024 study (170) Portugal applies a levy on 
low-density  plastic  bags  to  discourage  environmentally 
harmful activities and behaviours in the fields of packaging 
and plastic bags. Moreover, it applies emission charges for 
aircraft noise and emissions and for solid waste disposal 
and  landfilling,  product  charges  for  the  disposal  of 
batteries  and  electronic  articles,  levies  on  plastics  and 
tyres and a hunting and fishing tax (171). 

(168)  Commission notice – Technical guidance on the climate proofing 
of infrastructure in the period 2021–2027 (OJ C 373, 16.09.2021, 
p. 1), 
https://op.europa.eu/en/publication-detail/-
/publication/23a24b21-16d0-11ec-b4fe-
01aa75ed71a1/language-en. 

(169)  Eurostat, ‘Environmental taxes accounts’, env_eta.  
(170)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
https://op.europa.eu/en/publication-detail/-
Annex 2, 
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

(171)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
Annex 1, 
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

2025 Environmental Implementation Review – Portugal 

 
 
 
Green bonds and sustainable bonds 

Figure 34: Value of green bonds issued per Member State 
(billion EUR) in 2021, 2022 and 2023 

Portugal  48 

In  2023,  the  total  value  of  green  bonds  issued  by  the 
Member States  was USD 245 billion (EUR 227 billion), up 
from USD 234 billion (EUR 198 billion) in 2021. 

During 2021–2023 combined, Portugal issued green bonds 
worth USD 6.4 billion (EUR 5.5 billion) (Figure 34). Of this, 
in  2023  amounted  to  USD 2.4 billion 
issuance 
the 
(EUR 2.2 billion) (172). 

During  2014–2023,  83 %  of  the  green  bonds  issued  by 
European  countries  (excluding  supranational  entities) 
served objectives in energy, buildings or transport, while 
5 % supported objectives in water, 5.1 % related to land 
use  (with  links  to  nature  and  ecosystems)  and  3.8 %  to 
waste  management.  By  2023,  the  combined  share  of 
energy,  buildings  and  transport  had  decreased  to  73 %, 
the  share  of  waste  management  and  land  use  had 
increased  (to  5.9 %  and  8.4 %,  respectively),  while  the 
share of water had remained around 5 %. 

In  2021–2023,  31.7 %  of  the  European  green  bonds 
(excluding  those  issued  by  supranational  entities)  was 
issued  by  financial  corporates,  29.1 %  by  sovereign 
governments  and  23.1 %  by  non-financial  corporates. 
8.3 % of the issuances was linked to government-backed 
entities, 6.4 % to developments banks and 1.4 % to local 
governments. 

Data source: Climatebonds.net, with some additional data from national 
sources (e.g. Croatia, Slovenia). 

Environmentally harmful subsidies 

Addressing  and  phasing  out  environmentally  harmful 
subsidies (EHSs), in particular fossil fuel subsidies (FFS), is 
a  further  step  towards  achieving  the  8th  Environment 
Action Programme objectives and the enabling conditions 
(173). FFS are costly for public budgets and make it difficult 
to achieve European Green Deal objectives. 

The overall downward trend in FFS mentioned in past EIRs 
has  been  disrupted  since  2022,  due  to  the  European 
response  to  the  2021  energy  crisis  and  subsequent 
increase in energy prices. 

As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 109 billion in 2023 from EUR 57 billion in 
2020. From 2021 to 2023, there was a marked increase in 
annual fossil fuel subsidies of 72 % in the EU (174). 

For the majority of the Member States (16) the year 2022 
saw  a  peak  in  the  amount  of  overall  FFS.  A  decline  was 
then  observed  in  in  2023 (175).  In  particular,  FFS  for  coal 
and  lignite,  natural  gas  and  oil  increased  in  2022,  and  a 
strong increase was observed for natural gas subsidies. 

In Portugal, the energy subsidies were relatively stable in 
2015–2020, followed by a drop in 2021 and a significant 
increase  in  2022  (an  EU-wide  phenomenon)  (Figure 35). 
FFS between 2015 and 2021 were stable, between EUR 0.7 
and  EUR 1.0 billion  per  year,  with  an  outstanding 

(172)  Climate  bonds  initiative  (https://www.climatebonds.net/).  NB. 
Additionally (and not included in this), national sources indicated 
EUR 544.8 million issuance for Croatia, in 2022-2023, and a slightly 
higher  amount  for  Slovenia  (+0.27  billion)  during  2021-2023  in 
total. 

(173)  Article 3(h) of the eighth environment action programme. 

(174)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 

European Union, COM(2025). 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en 

(175)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, 

AT, PT, RO and SE. 

2025 Environmental Implementation Review – Portugal 

 
 
 
Portugal  49 

EUR 3.9 billion  in  2022,  partly  recovering  in  2023  (FFS 
decreasing to EUR 2.2 billion). 

As a share of GDP, fossil fuel subsidies in 2022 ranged from 
1.8 %  in  Croatia  to  less  than  0.1 %  in  Denmark  and 
Sweden.  Portugal’s  value  reached  1.6 %,  above  the  EU 
average (0.8 %) (176). 

Figure 35:  Energy  subsidies  by  energy  carrier  (billion 
EUR), 2015–2023 

NB: RES, renewable energy source. 
Source: analysis of Directorate-General Energy 

to  maximise  opportunities 

Chapter 5 of the 2022 EIR included the following priority 
actions for Portugal: (i) devise an environmental financing 
strategy 
closing 
environmental implementation gaps, bringing together all 
relevant administrative levels, and (ii) ensure an increased 
level  of  financing,  compared  with  past  levels,  for  the 
environment,  including  from  private  sources  (currently 
accounting  for  a  third  of  the  total),  to  cover  significant 
investment needs across the environmental objectives. 

for 

The  overall  environmental  investment  gap  has  been 
decreasing in Portugal compared with the EIR 2022, and 
(at 0.65 % of GDP) has become lower than the EU average. 

Portugal  should  take  advantage  of  the  available  EU 
funding to improve its environmental compliance and to 
develop  the  potential  of  the green  economy  to  improve 
the country’s competitiveness and create jobs. 

2025 priority action 

•  Use more national funding (for instance by increasing 
taxes  in  favour  of  the  environment  and  reducing 
environmentally  harmful  subsidies),  EU  funding  and 
private funding to help close the investment gap. 

(176)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 

European Union, COM(2025). 

https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Portugal  50 

6. Environmental governance 

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they rely on the three ‘pillars’ of the Aarhus Convention: 
(i)  access  to  information,  (ii)  public  participation  in 
decision-making and (iii) access to justice in environmental 
matters.  It  is  of  crucial  importance  to  public  authorities, 
the public and businesses that environmental information 
shared  efficiently  and  effectively (177).  Public 
is 
participation  allows  authorities  to  make  decisions  that 
take public concerns into account. Access to justice is a set 
of  guarantees  that  allows  citizens  and  NGOs  to  use 
national courts to protect the environment, safeguard the 
citizens  and  ensure  accountability  of 
rights  of 
authorities (178).  It 
legal 
includes  the  right  to  bring 
challenges (‘legal standing’) (179). 

Environmental information 

This  section  focuses  on  the  implementation  of  the 
Infrastructure  for  Spatial  Information  in  the  European 
Community  (INSPIRE)  Directive.  The  INSPIRE  Directive 
aims to set up a European spatial-data infrastructure for 
sharing environmental spatial information between public 
authorities across Europe. It is expected that this will help 
policymaking  across  boundaries  and  facilitate  public 
access  to  this  information.  Geographic  information  is 
needed  for  good  governance  at  all  levels  and  should  be 
readily and transparently available. 

Portugal’s  performance  in  implementing  the  INSPIRE 
Directive is substantial and has been reviewed based on its 
2023 country fiches (180) (see Table 3). 

(177)  The  Aarhus 

Convention 

(https://unece.org/environment-
policy/public-participation/aarhus-convention/text),  the  Access 
to  Environmental  Information  Directive  (Directive  2003/4/EC) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32003L0004) 
Directive 
(Directive 
lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32007L0002)  together  create  a 
legal  foundation  for  the  sharing  of  environmental  information 
between public authorities and with the public. 

INSPIRE 
the 
(https://eur-

2007/2/EC) 

and 

Table 3:  Portugal  dashboard  on  the  implementation  of 
the INSPIRE Directive, 2016–2023 

2016 

2023 

Legend 

sharing 

Effective  coordination  and  data 
sharing 
Ensure  effective 
coordination  
Data 

■  
■ 
■ 
without obstacles   ■ 
INSPIRE performance indicators 
(i)  Conformity  of 
■ 
metadata  
(ii)  Conformity  of 
■ 

■ 
spatial datasets    ■ 

(iii)  Accessibility 
of spatial datasets 
through view and 
download 
services 
(iv) Conformity of 
network services 

■ 

■ 

■ 

■ 

■ 
Implementation 
of  this  provision  is 
well  advanced  or 
(nearly)  completed. 
issues 
Outstanding 
are  minor  and  can 
be addressed easily. 
Percentage: > 89 % 
■ 
Implementation 
of this provision has 
started  and  made 
some  or  substantial 
progress  but  is  still 
not  close  to  being 
completed. 
Percentage: 
89 % 
■ 
Implementation 
of  this  provision  is 
falling  significantly 
Serious 
behind. 
efforts 
are 
necessary  to  close 
the implementation 
gap. 
Percentage: 
< 31 %  

31–

Source:  European  Commission,  ‘Portugal’,  Inspire  Knowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/portugal_en. 

Portugal received a priority action in the 2022 EIR for its 
implementation  of  the  INSPIRE  Directive.  It  has  made 
progress  on  the  accessibility  of  spatial  data,  but  more 
efforts  are  needed  to  make  spatial  data  more  widely 

content/EN/ALL/?uri=CELEX:52017XC0818(02) and a related 2018 
citizen's 
(https://op.europa.eu/en/publication-detail/-
/publication/2b362f0a-bfe4-11e8-99ee-01aa75ed71a1/language-
en/format-PDF). 

guide 

(179)  This  EIR  focuses  on  the  means  used  by  Member  States  to 
guarantee  rights  of  access  to  justice  and  legal  standing  and  to 
overcome other major barriers to bringing cases on environmental 
protection. 

(180)  European  Commission, 

‘Portugal’, 

Inspire  Knowledge  Base, 

https://knowledge-base.inspire.ec.europa.eu/portugal_en. 

(178)  These  guarantees  are  explained  in  the  European  Commission’s 
2017  notice  on  access  to  justice  in  environmental  matters 
(https://eur-lex.europa.eu/legal-

2025 Environmental Implementation Review – Portugal 

 
 
 
 
 
 
 
 
accessible and prioritise the environmental datasets (181). 
Therefore, the 2022 priority action is repeated in 2025. 

Public participation 

Public involvement  at both the planning and the project 
phase  maximises  transparency  and  social  acceptance  of 
programmes  and  projects.  Consultation  with  the  public 
(including  NGOs)  and  environmental,  local  and  regional 
authorities  is  a  key  feature  of  an  effective  impact 
assessment procedure. Such consultation also provides an 
opportunity for public authorities and project promoters 
to  engage  with  the  public  actively  and  meaningfully  by 
making information on the likely significant effects widely 
available. If carried out with due diligence and taking into 
consideration  useful  public  input,  this  process  leads  to 
better-informed decision-making and can promote public 
acceptance.  Making 
increases 
stakeholder  involvement,  thus  lessening  resistance  and 
preventing (or minimising) litigation. On the other hand, it 
is paramount that the procedure is effective. 

information  available 

This  section  examines  how  public 
involvement  and 
transparency are ensured under two instruments, namely 
the Environmental Impact Assessment (EIA) Directive (182) 
(SEA) 
and  the  Strategic  Environmental  Assessment 
Directive (183). 

safeguards,  while  enabling 

EU  law  provides  for  a  flexible  framework  concerning 
environmental  impact  assessments.  The  aim  of  this 
framework  is  to  ensure  the  application  of  the  necessary 
environmental 
speedy 
approval of projects. The Commission has contributed to 
simplifying  and  accelerating  permitting  for  renewable 
energy  projects  and  continues  to  support  the  Member 
States in this regard (184). Portugal has already taken steps 
aiming  to  accelerate  permitting  procedures  taking 
advantage of the broad flexibilities offered by the EU legal 
framework, such as the establishment of one-stop shops 
and  accelerated  short  deadlines  for  issuing  permits  for 
renewable energy projects. 

The average speed in the EU for issuing permits involving 
an EIA procedure is 20.6 months with a minimum duration 

(181)  https://github.com/INSPIRE-MIF/need-driven-data-

prioritisation/blob/main/documents/eReporting_PriorityDataList
_V2.1_final_20201008.xlsx.  

(182)  Directive  2014/52/EU  of  the  European  Parliament  and  of  the 
Council  of  16 April  2014  amending  Directive  2011/92/EU  on the 
assessment of the effects of certain public and private projects on 
the  environment  (OJ  L 124,  25.4.2014,  p.  1),  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32014L0052. 
(183)  Directive  2001/42/EC  of  the  European  Parliament  and  of  the 
Council of 27 June 2001 on the on the assessment of the effects of 
certain  plans  and  programmes  on  the  environment  (OJ  L 197, 
21.7.2001, 
https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32001L0042. 

p. 30), 

(184)  Commission Staff Working Document  (SWD/2022/0149 final), 18 
https://eur-lex.europa.eu/legal-

2022, 

May 

( 

Portugal  51 

and 

(screening, 

scoping,  EIA 

a  maximum  duration  of 
of 11.4  months 
75.7 months (185).  The  duration  of  each  step  in  an  EIA 
process 
report,  public 
consultation, reasoned conclusion, development consent) 
varies considerably between Member States and projects. 
There are no data available for Portugal. A priority action 
is included for 2025 to provide more detailed information 
on the different stages of the EIA process. Effective use of 
EU procedures can positively influence the timely approval 
of  activities  underpinning  the  decarbonisation  of  the 
economy on the way to net zero by 2050. 

A new report  is not  yet  available on the application and 
effectiveness of the SEA Directive in the EU. Nevertheless, 
a  support  study has been published with information by 
Member State (186). 

Portugal  has,  since  2015,  made  available  an  integrated 
online  service (187)  allowing  citizens,  NGOs  or  businesses 
to  participate  in  EIA  and  SEA  processes:  the  Participa 
website makes available a full list of cases, with access to 
relevant  documentation,  and  facilitates  submission  of 
evidence by the public.  This channel is also available  for 
participating  in  the  preparation  of  other  environmental 
plans, for example in the nature, waste and water sectors. 
However,  there  are  other  plans  with  an  environmental 
is  channelled 
dimension  where  public  participation 
through other tools, for example on noise and transport. 
Moreover, information is not yet available on the extent 
to  which  the  public  makes  use  of  the  opportunity  to 
participate in SEA and EIA processes, and it is therefore not 
possible  to  identify  whether  further  action  is  needed  by 
public authorities to encourage participation. Hence, as in 
the 2022 EIR, a priority action is proposed on this matter. 
In  addition,  access  to  environmental  information  and 
associated administrative documents is guaranteed in law. 

Access to justice 

Access to justice, guaranteed by Article 19(1) of the Treaty 
on  European  Union  and  Article 47  of  the  Charter  of 
Fundamental  Rights  of  the  European  Union, 
is  a 
fundamental right and part of the democratic process. It is 
vital to ensure the full application of EU law in all Member 

content/EN/TXT/?uri=CELEX%3A52022SC0149&qid=1653034229
953). 

Union, 

European 

Impact  Assessment 

(185)  European  Commission:  Directorate-General  for  Environment, 
Collection of information and data on the implementation of the 
revised  Environmental 
(EIA)  Directive 
(2011/92/EU) as amended by 2014/52/EU), Publications Office of 
the 
2024, 
https://op.europa.eu/en/publication-detail/-
/publication/8349a857-2936-11ef-9290-01aa75ed71a1/. 
(186)  European  Commission:  Directorate-General  for  Environment, 
Lundberg, P., McNeill, A., McGuinn, J., Cantarelli, A. et al., Study 
supporting  the  preparation  of  the  report  on  the  application  and 
effectiveness  of  the  SEA  Directive  (Directive  2001/42/EC)  –  Final 
study,  Publications  Office  of  the  European  Union,  2025, 
https://data.europa.eu/doi/10.2779/1615072 

Luxembourg, 

(187)  https://participa.pt. 

2025 Environmental Implementation Review – Portugal 

 
 
States and the legal protection of the rights of individuals, 
including  in  environmental  matters.  Access  to  justice  is 
essential  to  enable  judicial  review  of  the  decisions  of 
public  authorities  and  to  allow  the  correction  of  any 
wrongdoing committed by these authorities. 

This  section  provides  a  snapshot  of  the  state  of  play  of 
access to courts by the public, particularly when it comes 
to challenging plans, or the non-adoption of plans, under 
EU law, in the areas of water, waste, air quality and noise, 
irrespective of the form of the legal act (i.e. regulatory act 
or administrative decision). 

As  mentioned  in  the  2022  EIR,  Portugal  allows  both 
individuals and environmental associations to bring legal 
actions on environmental matters. NGOs may intervene in 
administrative and judicial proceedings provided that they 
also  have  an  environmental  scope  in  their  statutory 
regulations  when  challenging  SEA  decisions  (either  the 
plan/programme  or  the  environmental  report  or  both) 
and  also  other  plans  and  programmes.  There  is  also  a 
system  of  regular  and  substantive  supervision  of 
regulatory legally binding acts, and it is accessible for the 
members of the public and NGOs. 

In 2022, there were priority actions addressed to Portugal 
on access to justice, namely to (i) better inform the public 
about  their  rights  on  access  to  justice  (ii)  and  to  ensure 
that costs are not a hindrance to effective access to justice 
in environmental matters. It is concluded that no progress 
has been made.  

2025 priority actions 

• 

for 

spatial  datasets 

•  Make  spatial  data  more  widely  accessible  and 
prioritise  environmental  datasets  in  implementing 
the  INSPIRE  Directive,  especially  those  identified  as 
high-value 
implementing 
environmental legislation. 
Ensure  that  relevant  information  on  EIA  and  SEA 
procedures 
(including  on  public  participation 
opportunities and on publication of final decisions) is 
electronically accessible in a timely manner, through 
at least a central portal or easily accessible points of 
access, at the appropriate administrative level. 
Provide  information  on  the  average  duration  of  all 
steps in the EIA process. 
Improve  access  to  courts  in  national  environmental 
cases by the public concerned and eliminate practical 
barriers, such as length of proceedings and excessive 
costs. 

• 

• 

(188)  The concept is explained in detail in 2018 communication on EU 
actions  to  improve  environmental  compliance  and  governance 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52018DC0010)  and  the  related 
(https://eur-
Commission 

document 

working 

staff 

Portugal  52 

Compliance assurance 

Environmental  compliance  assurance  covers  all  work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air and nature, to manage waste (188) and to remedy any 
environmental  damage.  It  includes  measures  such  as  (i) 
compliance  promotion;  (ii)  compliance  monitoring  (i.e. 
inspections  and  other  checks);  (iii)  enforcement,  that  is, 
steps taken to stop breaches and impose sanctions; and 
(iv)  ensuring  damage  prevention  and  remediation in  line 
with the polluter-pays principle. 

Compliance promotion, monitoring and enforcement 

Non-compliance  with  environmental  obligations  may 
occur for different reasons, including poor understanding 
or  lack  of  acceptance  of  the  rules,  opportunism  or  even 
criminality.  Compliance  promotion  activities  help  duty-
holders to comply by providing information, guidance and 
other  support.  This  is  particularly  important  in  areas 
where new and complex legislation is put in place. 

When  inspections  and  other  control  activities  identify 
problems,  a  range  of  responses  may  be  appropriate, 
the  use  of  administrative  and  criminal 
including 
enforcement tools. 

Portugal  is  very  active  within  the  EU  Network  for  the 
Implementation  and  Enforcement  of  Environmental  Law 
(IMPEL)  and  has  made  efforts  to  enhance  specialisation 
and  cooperation.  Useful  work  has  been  done  on 
establishing  tools  for  the  assessment  of  substantial 
damage  to  water  for  the  purposes  of  inspections  and 
sanctioning  of  non-compliance.  Thus,  technical  guidance 
has been produced by a working group under the IMPEL 
National  Network,  and  it  has  been  used  since  2022  in 
concrete  cases  of  investigation  of  criminal  offences  in 
environmental  matters,  when  there  is  potential  damage 
to water resources (189). 

The  2022  EIR  extensively  covered  the  compliance 
promotion  and  monitoring  activities  carried  out  by  the 
General  Inspectorate  for  Agriculture,  Sea,  Environment 
and Spatial Planning (IGAMAOT), which plays a key role in 
this domain. 

The  IMPEL  National  Network  involves  18  authorities, 
including 
IGAMAOT,  as  coordinator,  and  authorities 
(including  from  Azores  and  Madeira),  namely  agencies, 
police  authorities,  the  Public  Prosecution  Service  (PGR), 
and,  since  December  2024  as  an  observer,  the  Supreme 
Judicial Council (SCM), that cooperate on IMPEL activities 

lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010). 

(189)  APA, Technical scientific index for the clarification of illicit actions 
Portuguese),  APA  website, 
(in 

resources’ 

on  water 
https://apambiente.pt/agua/indice-tecnico-cientifico-
esclarecimento-do-ilicito-sobre-os-recursos-hidricos. 

2025 Environmental Implementation Review – Portugal 

 
 
and at national level. An annual balance report of the work 
done 
IGAMAOT 
website (190). 

is  available  to  the  public  on  the 

Concerning  more  effective  enforcement,  since  2017, 
Portugal has a national plan for environmental inspection 
and  enforcement  (Plano  nacional  de  fiscalização  e 
inspeção ambiental (PNFIA)), an annual plan with national 
coverage,  based  on  a  digital  platform  coordinated  by 
IGAMAOT,  with  the  purpose  of  developing  synergies 
arising from the articulation of the attributions of each of 
the entities with permitting, enforcement and inspection 
in  the  area  of  governance  of  the 
responsibilities 
the 
allows 
platform 
PNFIA 
The 
environment. 
accommodation  and  planning  of  enforcement 
in  a 
coordinated manner, as well as maximising resources and 
avoiding  unjustified  duplication  of  effort,  with  resulting 
gains  in  efficiency  in  the  administration’s  monitoring  of 
compliance  with  environmental  legislation.  The  entities 
that 
IGAMAOT,  the  five 
Commissions for Coordination and Regional Development 
(CCDR)  of  the  North,  Centre,  Lisbon  and  Tagus  Valley, 
Alentejo  and  Algarve,  the  Portuguese  Environment 
Agency (APA) and, since 2020, the Directorate-General for 
Energy and Geology (DGEG). An annual balance report is 
available to the public on the PNFIA website (191). 

implement  the  PNFIA  are 

in 

Regarding  complaints  at  the  national  level,  Portugal  has 
developed  an  IT  portal  and  a  platform  to  manage 
complaints 
the  areas  of  agriculture,  sea  and 
environment, as a part of the project iFAMA (192) – Single 
Inspection and Monitoring platform. This is a single point 
of entry, management and centralisation of complaints, in 
electronic  form,  by  the  17  competent  authorities  in  the 
areas  of  agriculture,  sea  and  environment.  When 
submitted,  complaints  will  be  automatically  directed  to 
one authority and citizens will have access to information 
on the management of their complaints. 

The 2022 EIR recommended that Portugal provides more 
targeted  information  online  to  help  farmers  understand 
how to comply with their obligations on nature protection. 
Concerning  compliance  promotion,  monitoring  and 
criminal  and  administrative  enforcement,  the  2022 
priority  actions  are  not  assessed  here  due  to  lack  of 
systematic  information.  Similarly,  the  Commission  is  not 
aware of whether information is easily available online at 
the national level for farmers regarding compliance with 
the  Nitrates  Directive  and  Nature  Directives,  and  hence 
the 2022 priority action is not assessed. 

(190)  https://www.igamaot.gov.pt/pt/espaco-

publico/relatorios/relacoes-internacionais.  

(191)

https://www.igamaot.gov.pt/contents/pagecollapselist/extr

atorelatoriopnfia2023.pdf. 

(192)  https://ifama.igamaot.gov.pt/Portal/LandingPage. 
(193)  Directive (EU) 2024/1203 of the European Parliament and of the 
Council  of  11 April  2024  on  the  protection  of  the  environment 

Portugal  53 

The new EU Environmental Crime Directive 

legislation  with 

The EU has recently strengthened its legal framework on 
tackling  the  most  serious  breaches  of  environmental 
obligations,  notably  by  the  adoption  of  the  new 
Environmental  Crime  Directive  (ECD) (193)  and  new 
sectorial 
stronger  provisions  on 
compliance  monitoring,  enforcement  and  penalties. 
the 
the 
Issues 
implementation  of  the  relevant  new  instruments  are 
highlighted below; a detailed assessment of these topics 
will be included in the next EIR once more implementation 
in  place  and  more  systematic 
measures  are  put 
information is available. 

transposition  and 

important 

for 

The  new  ECD  replaces  the  2008  ECD  and  introduces 
several  new  offence  categories,  such  as  unlawful  ship 
recycling,  unlawful  water  abstraction,  and  serious 
breaches  of  EU 
legislation  on  chemicals,  mercury, 
fluorinated GHGs and  IAS of EU concern.  It also covered 
the establishment  of qualified  offences, subject  to more 
severe penalties where one of the offences defined in the 
directive  leads  to  serious  widespread  and  substantial 
damage  or  destruction  of  the  environment.  Concrete 
provisions on the types and levels of penalties that can be 
imposed  for  natural  and  legal  persons  who  commit  an 
offence  were also introduced. Other provisions will help 
considerably  to  improve  the  effectiveness  in  combating 
environmental crime of all actors along the enforcement 
chain.  These  include  obligations  to  ensure  adequate 
resources  and  investigative  tools,  specialised  regular 
training 
cooperation 
the  establishment  of 
mechanisms within and between Member States as well 
as national strategies on combating environmental crime. 

and 

Member  States  are  required  to  transpose  the  new  ECD 
into national law by 21 May 2026 and to take additional 
measures 
to  combat  environmental  crime  more 
effectively,  in  particular  through  training,  coordination, 
cooperation  and  strategic  approaches.  The  Commission 
will  provide  support, 
facilitating  the 
identification  and  sharing  of  good  practices.  Member 
States are expected to ensure the necessary resources and 
specialised  skills  required  and  they  are 
invited  to 
encourage their authorities to support and cooperate with 
the  recognised  EU-level  networks  of  environmental 
IMPEL (194), 
enforcement 
EnviCrimeNet (195), the European Network of Prosecutors 

including  by 

practitioners, 

such 

as 

through  criminal  law  and  replacing  Directives  2008/99/EC  and 
2009/123/EC 
L  2024/1203,  30.4.2024),  https://eur-
lex.europa.eu/eli/dir/2024/1203/oj/eng. 

(OJ 

(194)  https://www.impel.eu/en. 
(195) 

LIFE+SATEC 
(https://webgate.ec.europa.eu/life/publicWebsite/project/LIFE2

project 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
for the Environment (196) and the EU Forum of Judges for 
the  Environment (197).  The  European  Union  Agency  for 
Law  Enforcement  Cooperation  and  European  Union 
Agency for  Criminal Justice Cooperation mechanisms for 
cooperation on cross-border cases should be used more 
systematically for environmental offences. 

In  Portugal,  IGAMAOT  is  a  criminal  police  body  with 
specific  competence  on  environmental  crime  and  has 
worked  on  more  than  200  inquiries  on  environmental 
crimes,  delegated  by  the  Public  Prosecution  Service. 
Directive  1/2021,  now  replaced  by  Directive  1/2023 
underlines the importance, in investigating environmental 
crimes,  of  having  specialised  teams  of  prosecutors; 
recognising the competence and expertise of IGAMAOT in 
supporting  investigations;  creating  investigation  teams 
involving  various  police  authorities,  including  finance 
authorities;  ensuring  close  cooperation  among  different 
jurisdictions  within  the  Public  Prosecution  Service;  and 
ensuring close cooperation between police authorities. 

A formal agreement between IGAMAOT and the judiciary 
police  was  signed  in  2021,  providing  for  collaboration  in 
the prevention, detection and investigation of crimes; for 
exchange  of  information  and  knowledge;  and  for  joint 
training activities undertaken through the Judiciary Police 
School. 

In 2024, IGAMAOT signed a  partnership agreement  with 
CEPOL, the European Union Agency for Law Enforcement 
Training  on  training  on  environmental  crime,  and  joined 
EnviCrimeNet,  the  network  of  police  authorities  with 
competences in environmental crime. 

Coordination  with  national  units  of  the  European  Union 
Agency  for  Law  Enforcement  Cooperation  and  the 
International  Criminal  Police  Organization  was  also 
strengthened,  in  order  to  improve  access  to  relevant 
information on the environment, as was cooperation with 
the European Multidisciplinary Platform against  Criminal 
Threats. 

Environmental Liability Directive 

The  Environmental  Liability  Directive  (ELD) (198)  aims  to 
ensure that environmental damage is remediated in kind 
at the expense of those who have caused it, in line with 
the polluter-pays principle. It helps to halt the net loss in 
biodiversity,  as  well  as  reducing  the  number  of 

0-PRE-ES-000001/fight-against-environmental-crime-at-a-
strategic-level-through-the-strengthening-of-envicrimenet-
network-of-experts-in-environmental-criminal-investigations). 

(196)  https://www.environmentalprosecutors.eu. 
(197)  https://www.eufje.org/index.php?lang=en. 
(198)  Directive  2004/35/EC  of  the  European  Parliament  and  of  the 
Council on environmental liability with regard to the prevention 
and remedying of environmental damage (OJ L 143, 30.4.2004, p. 
56), 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02004L0035-
20190626&qid=1568193390794&from=EN. 

Portugal  54 

contaminated  sites  and  protecting  the  environmental 
quality of groundwaters and surface waters. The ELD is a 
cross-cutting 
for  better 
tool  and  a  key  enabler 
implementation of EU environmental law. 

The  ELD  addresses  cases  of  significant  environmental 
damage  to  protected  species  and  natural  habitats  and, 
when caused by operators carrying out certain potentially 
hazardous  activities, also damage  to  water  and  soil.  The 
Commission has a legal obligation to periodically evaluate 
the ELD. The ELD has undergone a second evaluation (199), 
which will be finalised in 2025 and which was supported 
by an external study (200), containing, among other things, 
evidence,  views,  reports  and  other  relevant  information 
gathered  from  different  stakeholder  groups,  including 
Member States. 

One  of  the  most  relevant  indicators  in  assessing  the 
implementation  and  enforcement  of  the  ELD  is  the 
number  of  environmental  damage  cases  handled  under 
the  directive,  especially  when  this  number  is  compared 
with the previous reporting period. Fewer ELD cases were 
reported in the second reporting period (2013–2022) than 
in  the  first  one  (2007–2013).  However,  the  downward 
trend  in  the  number  of  ELD occurrences  and  the  overall 
low number does not necessarily mean that the ELD has 
achieved its objectives, as it  needs to be compared with 
the overall number of environmental damage cases  that 
may have been handled under other liability instruments. 

The ELD has not always been effective in ensuring that the 
polluter pays, because the liable operators often lack the 
financial  capacity  to  carry  out  remediation  measures. 
While the ELD does not provide for a mandatory financial 
security  system,  it  explicitly  calls  for  Member  States  to 
encourage 
financial  security 
instruments  and  markets,  with  the  aim  of  enabling 
operators  to  use  financial  guarantees  to  cover  their 
responsibilities under this Directive. 

the  development  of 

From  30 April  2013  to  31 December  2021,  Portugal 
reported 23 occurrences of an imminent threat and two 
occurrences  of  environmental  damage  under  the  ELD. 
to  31 December  2021,  184 
From  1 August  2008 
occurrences of  environmental damage  were reported to 
the  APA,  of  which  134  were  not  considered  to  be  ELD 
occurrences,  and  consequently  23  were  considered 
imminent threats, and 2 were considered environmental 
damage under the ELD. In the previous reporting period, 

(199)  Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025. 

(200)  European Commission: Directorate-General for Environment and 
Fogleman,  V.,  Study 
in  support  of  the  evaluation  of  the 
Environmental  Liability  Directive  and  its  implementation –  Final 
report,  Publications  Office  of  the  European  Union,  Luxembourg, 
2024, 
https://op.europa.eu/en/publication-detail/-
/publication/006d90e5-980a-11ef-a130-
01aa75ed71a1/language-en. 

2025 Environmental Implementation Review – Portugal 

 
 
there were six occurrences of an imminent threat and two 
occurrences  of  environmental  damage  under  the  ELD. 
Portugal is among the few EU Member States that have an 
increase  in  occurrences  between  two  reporting  periods, 
and that have invested most heavily in developing training 
and  methodologies  to  assist  the  ELD’s  implementation. 
Currently, Portugal is focusing on continuing to promote 
information and to raise awareness  of  obligations under 
the ELD, especially regarding financial guarantees. 

Portugal  has  introduced  mandatory  financial  security 
systems  for  ELD  liabilities.  In  Portugal,  operators  of 
activities listed in  Annex III to  the ELD must have one or 
more financial security instruments to ensure their ability 
to carry out such activities, and there are no exceptions to 
the  mandatory  financial  security  requirement.  The  only 
type  of 
insurance  that  satisfies  mandatory  financial 
security  requirements  for  ELD  liabilities  in  Portugal  is  an 
environmental insurance policy. Environmental insurance 
policies  that  provide  cover  for  on-site  and  off-site  ELD 
liabilities  including  complementary  and  compensatory 
remediation are widely available, but some policies limit 
cover for the costs of remediating on-site environmental 
damage to damage that begins and ends during a specified 
period  of  hours  or  days,  that  is,  sudden  and  accidental 
pollution.  Some  policies  have  sub-limits  for  the  costs  of 
remediating  pollution.  Cover  for  ELD  liabilities  must  be 
ring-fenced  against  other  liabilities  or  responsibilities 
including  any  charges  or  other  instruments  that  have  a 
higher priority than them. 

The  APA  has  made  available  on  its  website  a  frequently 
asked  questions  document  with  guidance  related  to 
environmental  liability, 
including  mandatory  financial 
security systems (201). 

2025 priority action 

• 

Encourage the use of training programmes provided 
by  the  Commission  (or  developed  at  the  national 
level)  covering  the  ELD  and  its  interaction  with  the 
other national liability-related instruments, to ensure 
more  efficient  ELD  implementation,  improve  the 
expertise  of  the  competent  authorities  and  raise 
awareness among all stakeholder groups. 

EU-supported environmental capacity building 

The Commission’s 2023 Compact (202) initiative to enhance 

(201)  APA,  ‘Environmental  liability –  Answers  to  frequently  asked 
Portuguese), 

questions’ 
(in 
https://apambiente.pt/sites/default/files/_Avaliacao_Gestao_A
mbiental/Responsabilidade_ambiental/FAQ_RA_Versao_2022_0
2.pdf. 

(202)  See 

the  European  Commission  web  page  on  Compact 
(https://reform-support.ec.europa.eu/public-administration-and-
governance-coordination/enhancing-european-administrative-
space-compact_en). 

Portugal  55 

the administrative space identifies the capacity to lead the 
green transition as one of three key pillars, along with the 
public  administration  skills  agenda  and  the  capacity  for 
Europe’s Digital Decade. Compact also recognises the role 
of  the  EIR  reporting  tool  in  improving  environmental 
governance. The two main capacity-building opportunities 
for 
the  European 
Commission  are  the  TSI (203)  and  the  TAIEX-EIR  PEER  2 
PEER tool (204). The technical assistance available through 
the cohesion policy is subject to shared management and 
is not dealt with in this subsection. 

the  environment  provided  by 

The Commission’s technical support instrument 

The  TSI  provides  Member  States  with  tailor-made 
technical expertise on the design and implementation of 
reforms.  The  support  is  demand  driven  and  does  not 
require national co-financing. 

The  TSI  had  annual  calls  in  2021,  2022,  2023,  2024  and 
2025.  The  following  environment-related  projects  have 
been selected for Portugal: 

• 

• 

fisheries 

•  Development of a strategic plan for decarbonisation, 
digitization,  and  sustainable  blue  economy  for  the 
maritime  and 
sectors  and  marine 
environment  planning  and  sustainability  from  the 
Directorate-General for Natural Resources, Safety and 
Maritime Services (DGRM) (2022). 
Industrial ecosystems Government of Central Region 
and Government of Alentejo (2023). 
EU  Taxonomy  guidance  for  the  tourism  sector: 
directing  tourism  investments  towards  sustainable 
projects and activities, from Turismo de Portugal, I.P 
(2023). 
Strengthening the centre of government’s capacity to 
deliver  on  climate  change  and  other  high-level 
priorities  through  enhanced  strategic  planning, 
coordination  and  policy  development,  from  the 
Competence Centre for Planning, Policy and Foresight 
in Public Administration (2023). 
sustainable 
coherence 
policy 
development across national and local government in 
Portugal, 
the 
Presidency of the Council of Ministers (2023). 

the  Secretariat-General  of 

•  Building 

from 

for 

• 

•  Climate  adaptation  from  the  Agency  for  Integrated 

• 

Rural Fire Management. (AGIF, I.P.) (2023). 
Implementing  Effective  Green  Budgeting  Practices 
from  GPEARI  (Gabinete  de  Planeamento,  Estratégia, 

(203)  See 

the  European  Commission  web  page  on 

the  TSI 

(https://commission.europa.eu/funding-tenders/find-
funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en).  

(204)  See the European Commission web page on the TAIEX-EIR PEER 2 
(https://environment.ec.europa.eu/law-and-

PEER 
governance/environmental-implementation-review/peer-2-
peer_en). TAIEX: Technical Assistance and Information Exchange. 

tool 

2025 Environmental Implementation Review – Portugal 

 
 
Avaliação e Relações Internacionais) – Ministério das 
Finanças (2025) 

made  limited  progress  in  that  respect,  and  the  priority 
action is reiterated. 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

2025 priority action 

Portugal  56 

• 

Improve overall national environmental governance, 
in  particular  administrative  capacity  to  support  the 
green transition and coordination at the regional and 
local levels. 

States’ 

among  Member 

In 2017, the Commission launched the TAIEX-EIR PEER 2 
PEER  tool (205)  in  2017.  It  aims  to  facilitate  peer-to-peer 
learning 
environmental 
authorities through workshops (single- or multi-country), 
expert missions (where a delegation of experts travels to 
the  requesting  institution)  and  study  visits  (where a 
delegation from the requesting institution travels to a host 
country).  Flagship  multi-country  are  those  requested  by 
to  present  new  and  upcoming 
the  Commission 
environmental 
in  all  Member 
States (206). 

legislation  and  policy 

Workshops involving Portugal are as follows: 

• 

Future  challenges  for  air  protection  (24 November 
2022) with the Czech Presidency. 

•  Making  space  for  biodiversity:  regional  action  to 
mainstream  biodiversity  and  empower  stakeholders 
(21–23 March 2023) 

•  Decentralised  biowaste  recycling 

in  Austria  (9–

10 October 2023). 

•  Green budgeting at regional level (9 April 2024). 
•  Online  platforms:  EU  Batteries,  Packaging  and 
Packaging Waste Regulations (28–29 October 2024). 
•  New  aspects  of  cross-border  cooperation  against 
environmental crime (19–20 November 2024). 
Freight  transport  by  rail  (in  relation  to  waste 
transport) (17-18 March 2025). 

• 

Portugal hosted a study visit on smart solutions for urban 
sustainability,  environmental  management  and  citizen 
engagement  (9–10 January  2024)  in  Lisbon.  Portuguese 
experts also participated in an expert mission in Latvia on 
nature-based  solutions  and  climate  action  initiatives  for 
Liepāja’s smart city roadmap (24–26 July 2024). 

In  the  2022  EIR,  Portugal  received  a  priority  action  to 
in 
improve 
particular,  its  administrative  capacity  and  coordination 
between the different levels of government. Portugal has 

its  national  environmental  governance, 

(206) 

(205)  European  Commission,  ‘TAIEX-EIR  PEER  2  PEER  tool’,  European 
Commission  website,  https://environment.ec.europa.eu/law-
and-governance/environmental-implementation-review/peer-2-
peer_en. 
 Flagship  multi-country  workshops  in  the  reporting  period  are: 
Recast  Drinking    Water  Directive  (3  April  2025);  Environmental 
compliance  and  governance  (18  March  2025);  Planning  of 
Renewable  Energy  Projects  (20  February  2025);  Air  Quality: 
Implementation  of  the  revised  Air  Quality  Directive  (16  January 
2025); Industrial safety: awareness raising of emerging risks linked 
with climate change and decarbonation (12 December 2024); Air 
further 
implementation  of  the  NEC  Directive  to 
quality: 
mainstream  air  and  broader  pollution  reduction  in  agricultural 
policy  (25 September  2024);  Industrial  emissions  transposition 
and implementation of the revised directive (12 September 2024); 

Noise:  progress  towards  meeting  Member  States’  noise  limit 
values and EU reduction targets (5 June 2024); Best practice use 
of  environmental  footprint  methods  on  the  EU  market  (30 May 
2024);  Sustainable  finance  (9 November  2023);  Textile  waste 
separate collection, treatment and markets (3 October 2023); EU 
environmental  funding  and  support  (13 June  2023);  Advisory 
service for businesses to go circular (24 April 2023); Digital product 
passport implementation (6 December 2022); Public involvement 
in  planning  and  approval  of  renewable  energy  projects 
(17 November 2022); Environmental compliance and governance 
(14 November  2022);  Biowaste  management  (19–20 September 
2022); and  Renewable energy projects: permit granting processes 
(13 June 2022). NB: The first flagship workshop on zero pollution 
for air, water and soil took place 9 February 2022. 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
 
 
 
Portugal  57 

Annex 

2025 priority actions 

Circular economy 

•  Adopt measures to increase the circular material use rate. 
• 

Speed up the transition to a circular economy by implementing an updated national strategy and the EU 
framework and recommendations, in particular to complement it with upstream circularity measures. 

• 
• 
• 
• 
• 

• 

• 
• 

• 

• 

• 

Waste management 

Improve municipal waste preparation for reuse and recycling. 
Increase the recycling rates of packaging waste. 
Increase the collection and recycling rate of waste electronic and electric equipment (WEEE). 
Invest in waste prevention measures to reduce the total amount of waste generated. 
Ensure  the  achievement  of  the  2025  waste  targets,  following  the  recommendations  made  by  the 
Commission in the Early Warning Reports where applicable. 

Biodiversity and natural capital 
Global and EU biodiversity frameworks  

Submit  to  the  CBD  an  updated  NBSAP  or  national  targets  following  the  adoption  of  the  Kunming-
Montreal Global Biodiversity Framework. 

Nature protection and restoration – Natura 2000 

Complete the Natura 2000 site designation process. 
Finalise the establishment of site-specific conservation objectives and measures for all Natura 2000 sites 
(including by adopting their management plans) and ensure their effective implementation. 
Ensure the effective implementation of Natura 2000 management plans and sufficient administrative 
capacity  and  financing  both  for  Natura  2000  and  the  implementation  of  the  Nature  Restoration 
Regulation. Ensure implementation of Prioritised Actions Framework 2021-2027 (PAFs). 

Recovery of species  

Strengthen the integration of biodiversity actions into other policies, e.g. energy, agriculture, fisheries, 
forestry,  urban  and  infrastructure  planning  and  sustainable  tourism,  and  promote  communication 
between stakeholders. 

Recovery of ecosystems 

Implement eco-schemes and agri-environmental measures and practices to address the environmental 
needs of Portugal. 

Marine ecosystems  
•  Report its updates on the assessment of the state of its marine waters, its targets, and its determinations 
of GES, which are expected to include any threshold values for the descriptors in the MSFD that may 
have been established in cooperation with other Member States at the EU or regional level. 

Prevention and management of invasive alien species  

2025 Environmental Implementation Review – Portugal 

 
 
 
 
 
 
  
 
 
 
 
 
Portugal  58 

• 

Step up implementation of the IAS Regulation, including with regard to enforcement  and capacity of 
inspection authorities. 

Zero pollution 
Clean air 

•  As part of the NAPCP, take action towards reducing emissions of air pollutants. 
• 

Ensure full compliance with the current AAQD standards, also in light of future stricter requirements 
under the revised AAQD. 

•  Accelerate the ratification of relevant international conventions and protocols. 

Industrial emissions 

•  Reduce industrial air pollution damage and intensity. 
•  Reduce industrial releases to water, and their intensity. 
• 

Engage with industry and environmental NGOs to ensure proper contribution to and implementation of 
BAT conclusions; and ensure timely update of permits following publication of BAT conclusions. 
Ensure effective public participation and access to justice in relation with the IED. 

Major industrial accidents prevention – Seveso 

Strenthen compliance  with requirements on safety measures to prevent  major  accidents and ensure 
appropriate preparedness and response for UTEs, in particular as regards review, testing and upddate 
of EEPs, at intervals of no longer than three years. 
Ensure access to transparent and clear information towards citizens on risks and  behaviour in case of 
accidents. 

Complete noise mapping. 
Complete and implement action plans on noise management. 

Noise 

Water quality and management 

Tackle  nutrients  pollution,  especially  nitrates  from  agriculture  through  the  implementation  of  the 
Nitrates Directive. 
Take the necessary measures to ensure full implementation of the current Urban Wastewater Treatment 
Directive, taking into account the new requirements of the recast Directive. 

• 

• 

• 

• 
• 

• 

• 

Chemicals 
•  Upgrade the administrative capacities in implementation and enforcement to move towards a policy of 

• 

• 

• 

zero tolerance of non-compliance. 
Increase involvement in the activities of the Forum for Exchange of Information on Enforcement of the 
European Chemicals Agency, including in the coordinated enforcement projects, called REF projects. 
Increase customs controls and controls of products sold online with regard to compliance with chemicals 
legislations. 

Climate action 

Implement all polices and measures that are needed to achieve targets laid down in the Effort Sharing 
Regulation (ESR) and the Land Use, Land Use Change and Forestry (LULUCF) Regulation. More detailed 
priority actions are set up in the assessment of the final National Energy and Climate Plan (NECP). 

Financing 

2025 Environmental Implementation Review – Portugal 

 
 
 
 
 
•  Use more national funding (for instance, by increasing taxes in favour of the environment and reducing 

environmentally harmful subsidies), EU funding and private funding to help close the investment gap. 

Portugal  59 

• 

• 
• 

• 

• 

Environmental governance 
Information, public participation and access to justice 
•  Make spatial data  more widely accessible and prioritise environmental datasets in implementing the 
implementing 

INSPIRE  Directive,  especially  those  identified  as  high-value  spatial  datasets  for 
environmental legislation. 
Ensure  that  relevant  information  on  EIA  and  SEA  procedures  (including  on  public  participation 
opportunities  and  on  publication  of  final  decisions)  is  electronically  accessible  in  a  timely  manner, 
through at least a central portal or easily accessible points of access, at the appropriate administrative 
level. 
Provide information on the average duration of all steps in the EIA process. 
Improve  access  to  courts  in  national  environmental  cases  by  the  public  concerned  and  eliminate 
practical barriers, such as length of proceedings and excessive costs. 

Compliance assurance 
Encourage the use of training programmes provided by the Commission (or developed at the national 
level) covering the ELD and its interaction with the other national liability-related instruments, to ensure 
more  efficient  ELD  implementation,  improve  the  expertise  of  the  competent  authorities  and  raise 
awareness among all stakeholder groups. 

EU-supported environmental capacity-building 
Improve overall national environmental governance, in particular administrative capacity to support the 
green transition and coordination at the regional and local levels. 

2025 Environmental Implementation Review – Portugal