When importing waste to Portugal, EU Regulation 1013/2006 must be complied along with the Portuguese Ministry Order dated 03/01/2020 and now Portuguese Decree Law 22/2020 dated 16th May 2020, according to Nick Dimokidis, Claims Director and Maitane Tarrio, Claims Assistant.

Meanwhile, Article 11 of the EU Regulation 1013/2006 establishes that a member state may reject waste from entering the country, when  same affects the self-sufficiency of local and national waste disposal facilities.

Based on the above, the Ministry order dated 03/01/2020 denies authorisation to shipments of waste for disposal on which the permission is applied from 1st February 2020 onwards.

In the following scenarios, shipowners, charterers and cargo interests might be fined from the pertinent Portuguese authority and shall be under the duty to take back the cargo, if:

  • The waste for disposal permission was requested after 1st February 2020.
  • Even if the waste for disposal authorization was granted before 1st February 2020, if it is a:
    a)  Shipment of non-dangerous waste for landfill disposal – Code D 1; and/or
    b)  Shipment of inert waste for landfill disposal - Code D 1.


Before commencing a waste cargo voyage to Portugal, ship operators are highly recommended to:

  1. Confirm whether the waste is for disposal or recovery. Waste for recovery is not affected by the new regulations and therefore is subject to the general rules.
  2. Make sure the date when the permission to carry waste for disposal was authorized following the Ministry Order dated 03/01/2020.
  3. Consider the type of waste. The following types are not subject to any restrictions under the Decree Law 22/2020:
    a) Shipments of waste for temporary warehousing – Code D15.
    b) Shipments of dangerous waste for disposal.
    c) Shipments of hospital waste, either for chemical treatment or for incineration.