102 active EU infringement files on Portugal: What does this number mean, what delays affect the consumer?

Delays in Portugal's process of translating and implementing European Union law into national legislation are on the agenda again.

According to the compilation announced by the environmental organization Quercus on October 2, there are 102 active violation procedures against Portugal before the European Commission.

Of these, 21 are related to the environment, 12 to energy and three to the field of climate action.

However, it is necessary to read the meaning of the number 102 correctly.

This figure does not mean that Portugal lost 102 cases or that the country was issued 102 separate fines.

“Violation procedure” is not a direct conviction

When the European Commission thinks that a member state does not implement EU law correctly or in a timely manner, it can initiate a process known as an infringement procedure.

One of the first stages is the letter of formal notice.

The country is given time to respond and fix the problem.

If the problem is not resolved, the process can progress to the reasoned opinion stage.

However, at a later stage, the file can be transferred to the Court of Justice of the European Union.

For this reason, it is necessary to distinguish between the active file and the fine imposed by the court.

New files were opened for Portugal on September 25

One of the current developments behind Quercus' statement today is the European Commission's September 25 decisions.

The Commission, on the grounds that they did not fully transpose the Hydrogen and Decarbonised Gas Directive (EU) 2024/1788 into national law. It sent official notification to 26 countries, including Portugal.

Countries were required to transpose the directive by August 5, 2026.

According to the Commission, only Italy had reported full transposition by the deadline.

Portugal was given two months to correct the deficiencies and report them to the Commission.

“Right to Repair” also delayed in Portugal

One of the most concrete files for consumers is the Right to Repair directive.

Directive (EU) 2024/1799 aims to make it easier for consumers to repair, rather than replace, the product for certain products.

It includes new rights for manufacturers to offer repairs on smartphones, washing machines, refrigerators and certain other products under reasonable time and price conditions.

On September 25, the European Commission initiated a violation process against a group of countries, including Portugal, on the grounds that the directive was not fully conveyed.

So the problem is not just an administrative procedure between Brussels and Lisboa; It may also affect the timely implementation of some EU consumer rights in Portugal.

There are also gaps in energy and industrial emissions

Within the scope of the same package, in addition to the directive on the hydrogen and decarbonized gas market, there is also a transaction for Portugal regarding the transfer of the Industrial and Livestock Emissions Directive.

These regulations cover areas such as energy conversion, reduction of industrial emissions and environmental protection.

Quercus also It draws attention to the fact that European regulations on combating greenwashing have not been implemented in Portugal in a timely manner.

Not all 102 files are at the same stage

This point is particularly important.

The 102 active files provided by Quercus bring together files opened on different dates and at different legal stages.

Therefore, it is not possible for all of these to automatically go to court or turn into a fine after two months.

Each file has its own legal process.

Portugal has also received fines before

A concrete example of the difference between active procedure and definitive sanction can be seen in the nature protection file.

As Quercus reminds, the Court of Justice of the European Union imposed a collective penalty of 10 million euros on Portugal in March for not fulfilling a previous decision regarding protected areas and a daily sanction of 41,250 euros until the decision is fully implemented.

This dossier does not mean that all 102 active procedures announced today are at the same stage; On the contrary, it shows how different stages the processes can be in.

Resources

European Commission — Commission takes action to ensure complete and timely transposition of EU directives, 25 September 2026

https://energy.ec.europa.eu/news/commission-takes-action-ensure-complete-and-timely-transposition-eu-directives-key-decisions-energy-2026-09-25_en

Observador / Lusa — Portugal Jul 102 diretivas europeias, 2 October 2026

https://observador.pt/2026/10/02/portugal-tem-102-processos-por-infracao-na-transposicao-de-diretivas-europeias/

Dinheiro Vivo / Lusa — Quercus diz que Portugal jul 102 processos por infração, 2 October 2026

https://dinheirovivo.dn.pt/economia/quercus-diz-que-portugal-tem-102-processos-por-infrao-na-transposio-de-diretivas-europeias