MIRR and e-GAR: Obligations, Deadlines and Importance

Waste management in Portugal relies on two central digital instruments: the Integrated Waste Register (MIRR) and the Electronic Waste Transport Document (e-GAR). Both are managed in SILiAmb (Integrated Environmental Licensing System) under the Portuguese Environment Agency (APA) and are designed to ensure traceability, transparency and compliance with national and European environmental goals. Soon P7CO® EcoResupply will introduce new features in this area, including integration with SINLAB and automatic deadline alerts.

What is MIRR

MIRR is a mandatory annual declaration where waste producers, carriers and operators report the quantity and type of waste generated, transported or treated. It includes hazardous and non-hazardous waste, depending on the company’s activity and size. This register is essential for APA and the European Commission to monitor waste management in Portugal and assess progress towards circular economy goals.

Entities obliged to submit MIRR include hazardous waste producers and non-hazardous waste producers above certain thresholds. Licensed operators, carriers and intermediaries are also required.

What is e-GAR

The e-GAR is the electronic document that accompanies waste from its origin to its final destination. It is completed in SILiAmb and contains information about the producer, the carrier, the vehicle, the recipient, and the type and quantity of waste. This system replaced old paper forms, making the transport process faster, traceable and auditable.

All parties — producer, carrier and recipient — share responsibilities in filling out and validating the e-GAR. The document must accompany the waste during the entire transport, even digitally, and remains available in the system for five years.

Deadlines and Obligations

MIRR must be submitted each year by 31 March, covering the previous calendar year. For example, the MIRR for 2025 must be submitted by 31 March 2026. This deadline is legally binding, and failure to comply constitutes an environmental offence.

e-GAR has no fixed annual deadline: it must be issued whenever waste subject to mandatory tracking is transported. Each journey involving hazardous waste, or specific types of non-hazardous waste, must be accompanied by a valid and confirmed e-GAR.

Importance of Compliance

Complying with MIRR and e-GAR is essential to remain legally compliant and avoid fines. But their importance goes beyond legality: these systems ensure transparency in waste management, provide traceability of producer, carrier and recipient, and help reduce environmental, social and reputational risks.

Strategically, MIRR and e-GAR data feed into national and EU reports, guide public policy, and allow Portugal to report circular economy indicators to the European Union. Without this reliable data, achieving targets such as reducing landfill disposal or increasing recycling would be impossible.

Consequences of Non-Compliance

Non-compliance can lead to significant fines, classified as serious or very serious environmental offences depending on the type of waste and severity. Beyond financial impacts, risks include reputational damage and difficulties securing contracts that require proof of compliance.

Upcoming Features

P7CO® EcoResupply is preparing integrations with SINLAB and automatic deadline management for MIRR and e-GAR. These features will simplify compliance, ensure deadlines are met, and keep records secure and auditable. Soon we will share how users can benefit from smart alerts and integrated reports directly in the platform.

Want to know more or receive updates on these features? Contact us.