For several years, the framing of investments in the processing and marketing of agricultural products was marked by excessive complexity that brought little benefit to the promoters and, in many cases, ended up stalling economically sound projects. The “boundary” between ERDF (Portugal 2020) and EAFRD (PDR2020) was based on a set of criteria that were difficult to apply in an objective and predictable way, giving rise to ambiguous situations related to the origin of the raw material, the location of the industrial unit or the nature of the promoter. Furthermore, with the successive amendments that occurred in the regulations of Portugal 2020 and PDR2020, it created a negative discrimination for Producer Organisations (POs) e promoters with their own raw materials. The result was a scenario of uncertainty that penalised decision-making and delayed relevant investments in the agro-industrial sector.
O new Partnership Agreement and the regulatory changes approved at the end of 2025 finally resolved this “it”and very clearly simplified this “border”. The deliberation of the Interministerial Coordination Commission for Portugal 2030, approved on 24 November 2025, and its subsequent regulation through the Order No. 429/2025, of 4 December, came unequivocally clarify the demarcation of intervention between ERDF (now Portugal 2030) and EAFRD (now PEPAC) in supporting the processing and marketing of agricultural products.
The definition of a single, clear threshold of 2 million euros of total investment for these operations, when classified under Annex I of the Treaty on European Union, represents a significant step forward in terms of simplicity, transparency and predictability. The rule is now easily understood and applied, drastically reducing the scope for divergent interpretations and for decisions based on criteria that have little to say about the actual merit of the investment.
This simplification has very relevant practical effects. First of all, it eliminates the need to analyse, on a case-by-case basis, whether the raw material is mostly own or purchased, or whether the processing unit is located inside or outside the agricultural holding. The focus finally shifts to what truly matters: the scale, ambition and impact of the project. And more importantly, Producer Organisations are no longer excluded from the measure.
One of the most positive aspects of this new framework is creation of clear opportunities for mid-scale projects, in particular in the bracket between 1 and 4 million euros. These investments, which correspond to a very significant part of the modernisation of the national agro-industry, found themselves frequently in a grey area: too large for EAFRD and, at the same time, too small for ERDF. With the new demarcation, Projects exceeding the €2 million threshold are now eligible to apply to the Portugal 2030 Productive Innovation Incentive System, creating a financing route that until now had practically been closed to many developers in the sector.
It is important, however, to emphasise that this opportunity comes with a high level of demand. A Productive Innovation of Portugal 2030 is not an agricultural sectoral measure; is a transverse instrument, where agro-industrial projects compete directly with projects from all sectors of the economy. The merits analysis criteria are complex and multidimensional, evaluating the degree of innovation, the contribution to competitiveness, the creation of added value, the orientation towards external markets, the economic sustainability and the structural impact of the investment on the region. It is not enough to have a good project from a technical or productive standpoint; it is necessary to clearly demonstrate its strategic relevance in a highly competitive context.
Furthermore, the project maturity requirements are of particular importance. According to the regulations currently in force, whenever investments involving works subject to prior control are concerned, it is required that the architectural design is approved by the competent authorities, or that there is a favourable request for prior information, duly instructed with all legally required opinions.
Conversely, for a project to be eligible, there must be no firm commitment to start the investment prior to the submission of the application. Contracts, awards, orders or equivalent acts may irremediably jeopardise access to funding. Managing this balance (between sufficient maturity and the absence of onset) is frequently one of the most critical and sensitive aspects of the entire process.
In a context where opportunities exist, but competition is high and criteria are demanding, the ability to correctly read the regulatory framework, anticipate risks and structure solid applications becomes a critical success factor. More than ever, access to finance depends not only on the quality of the investment, but also in the way this investment is conceived, prepared and presented.
It is now up to prosecutors to know how to seize this window of opportunity with strategy, preparation and an informed reading of the “rules of the game”.
To help you learn the “rules of the game”, you can always count on the experience of the Industrial Projects team at CONSULAI.