The ban will come into force on 1 January 2027. In the interim, a transitional period has been established to allow for the orderly clearance of existing stock, the renegotiation and adjustment of supply and logistics arrangements, the consolidation of viable alternatives within the market, and the gradual adaptation of consumers to new patterns of consumption.
Consumers and economic operators will have this transitional period to adjust, the central objective being the replacement of disposable solutions with reusable alternatives.
The legal framework for this measure is primarily set out in Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment, as well as in Law no. 76/2019, which partially transposed the Directive into Portuguese law.
It is also important to recall the national regime introduced in two thousand and fifteen to reduce the consumption of lightweight plastic carrier bags, which led to a very significant decrease in per capita consumption in Portugal. The next step now focuses on ultralight bags, commonly used for fruit and vegetables.
Despite their small size, these bags have a significant environmental impact.
They are less than fifteen microns thick, easily dispersed into the environment, take decades to degrade and contribute substantially to landfill waste and marine pollution.
Their widespread use generates a considerable cumulative impact, both environmentally and economically.
Although the definitive replacement model has not yet been announced, the market already offers and tests several alternatives, including reusable cotton or recycled cotton bags, lightweight washable mesh bags for fruit and vegetables, thicker recycled plastic bags designed for multiple uses and certain biodegradable solutions, although public policy is clearly focused on reuse. The logic is straightforward: use repeatedly rather than dispose of after a single use.
It is foreseeable that these new alternatives will involve a unit cost, albeit one that is offset over time given their reusable nature.
For economic operators, the issue extends beyond price and includes contractual revisions with suppliers, appropriate consumer communication, stock management and strict compliance with new legal obligations.
For retailers and distributors, this change entails reviewing internal sustainability policies, adapting contractual arrangements, assessing regulatory risks, monitoring environmental obligations and, where necessary, adjusting labelling and consumer information.
Non-compliance may result in administrative sanctions.
The elimination of ultralight plastic bags represents a further step in consolidating Portugal’s policy of reducing single-use plastics. For consumers, it means a change in habits; for businesses, it raises issues of environmental compliance and strategic adaptation to the new regulatory framework. Anticipation and planning will be essential to mitigate risks and avoid additional costs.
Belzuz Abogados, S.L.P. is an international law firm headquartered in Madrid, with offices in Lisbon and Oporto, with an established practice in regulatory and environmental law, and is able to assist clients in adapting to this new legal framework and in mitigating associated legal risks.