Within the scope of Line of Action 8 of Biomethane Action Plan (PAB 2024–2040) – “Clarifying the regulatory framework and streamlining licensing procedures” – several legislative amendments have been published and are currently underway, alongside the implementation of other joint instruments by various public entities with legal responsibilities in the new waste-to-biomethane value chains.
This section will progressively make public the various initiatives and regulatory changes designed to streamline the licensing processes for the conversion of waste into biomethane.
Licensing Guide
A technical note (available only in Portuguese), prepared by the Portuguese Environment Agency (APA) and with contributions from DGEG, DGADR and DGAV, aims to clarify the legislation in force relating to the production of biogas/biomethane via anaerobic digestion, with regard to environmental regulations and the licensing regimes under which this economic activity may fall. In this context, no analysis has been conducted on the regulatory framework for gasification and power-to-methane (synthetic methane) processes.
DGEG as coordinating body for CAE 35210
Joint APA–DGEG Order on the “Licensing procedure for biomethane production units” (9 January 2026, only available in Portuguese).
This order clarifies the licensing procedure applicable to biomethane production units under the current version of Decree Law No. 62/2020 of 28 August, particularly on the categorisation under the economic activity classification code (CAE) 35210 and on the relationship between prior registration and mandatory sectoral licenses.
This Order does not preclude the application of other licensing regimes where required, particularly depending on the type of waste used, the specific configuration of the facility or the main CAE code for the promoter’s activity.
