Waste Production in Portugal: Do I Need to Submit the MIRR Report?

MIRR — the Integrated Waste Registration Map — is the annual reporting mechanism provided for in the General Waste Management Regime, through which companies declare to the Portuguese Environment Agency (APA) the waste they produced, quantities, classification, destination, and involved transporters. It is submitted via the SILiAmb platform within the Integrated Electronic Waste Registration System (SIRER).

When is it mandatory?

As a waste producer, you are required to register in SIRER and submit MIRR if you fall under any of the following categories:

Organizations with more than 10 workers producing non-urban waste;

Organizations with more than 10 workers producing urban waste, with an average daily production of 1,100 liters or more per establishment;

Establishments producing hazardous non-urban waste, regardless of the number of workers;

Establishments producing hazardous urban waste, with an average daily production of 1,100 liters or more per establishment, regardless of the number of workers.

Pay special attention to the third point: producing just one type of hazardous waste triggers this obligation, even if the company only has two or three employees. This is the case, for instance, for workshops with used oil, farms using plant protection product packaging, or any facility generating contaminated absorbents.

For this purpose, an organization is considered to be the set of establishments under the same VAT/NIF number. If the organization is covered, all of its establishments that produced waste during that year must fill out MIRR — reporting is always conducted per establishment.

Note that the obligation to submit MIRR does not stem from issuing e-GARs. They are distinct requirements: you may need to register in SILiAmb to issue a transport guide without that automatically obligating you to annual reporting — and vice versa.

Deadlines

MIRR is completed and submitted between January 1 and March 31 of the year following the reported period. For forms to even become available, entity and establishment data must be fully updated, MIRR framework defined, and the SIRER fee settled — which is why leaving the process to the last week of March usually causes issues.

Failure to submit MIRR constitutes a serious environmental infraction.

You Don't Have to Handle This Internally

If you need to complete registration on the SILiAmb platform, have questions about your obligations, or simply prefer to save your team time, MJD provides this service.

We handle entity and establishment registration, emission and validation of electronic waste transport guides (e-GARs), completion and submission of annual maps, and all related matters. We work with these platforms daily and understand their specifics.

Contact us via email at ambiente@mjd.pt or phone at +351 229 820 742.