Savannah Resources Plc (AIM: SAV), the developer of the Barroso Lithium Project in northern Portugal, has submitted its Environmental Compliance Report of the Execution Project — known as the RECAPE — to Agência Portuguesa do Ambiente (APA), Portugal's environmental regulator. The submission, announced on 5 November 2026, initiates the final stage of the environmental licencing process required before construction can begin. A regulatory decision, known as the DCAPE, is expected before the end of January 2027, a milestone investors in Europe's critical raw materials sector are likely to monitor closely.

Key Points

  • Savannah Resources Plc (AIM: SAV) develops the Barroso Lithium Project, Europe's largest spodumene lithium deposit, in northern Portugal
  • The company has submitted its RECAPE to APA, initiating the final stage of environmental licencing ahead of construction
  • APA's Evaluation Committee has a maximum of 50 working days to issue its decision once the submission is accepted; a 15 working day public consultation is also expected during this period
  • Investors should watch for APA's formal acceptance of the submission, payment of the RECAPE review fee, and the DCAPE decision expected before end of January 2027

What the RECAPE Submission Means for the Barroso Lithium Project's Licencing Process

The RECAPE is a formal verification document submitted to APA so that the regulator can confirm whether Savannah's detailed execution project has complied with the conditions set out in the conditionally approved Environmental Impact Assessment — known as the DIA — which was granted in May 2023. Once APA accepts the submission and Savannah pays the RECAPE review fee, the Evaluation Committee appointed by APA will have a maximum of 50 working days under Portuguese legislation to conduct its review and issue a final opinion, upon which APA will then base its DCAPE decision. The precise deadline will be set once payment is made, which the company states is expected in the coming days.

Barroso Project's Strategic Status and Scale Under Europe's Critical Raw Materials Act

The Barroso Lithium Project holds a significant position in European critical minerals policy. It was classified as a Strategic Project by the European Commission under the Critical Raw Materials Act in March 2025 and was approved for a Portuguese State development grant of up to €110 million in January 2026. When operational, the project is expected to produce approximately 183,000 tonnes per annum of spodumene concentrate — sufficient to supply lithium for around half a million electric vehicle battery packs annually, supporting the European Commission's goal of at least 10% endogenous lithium production from 2030.

CEO Emanuel Proença Outlines Path to Construction Financing Following DCAPE

Chief Executive Officer Emanuel Proença stated that the team has worked to submit a comprehensive RECAPE and has engaged regularly with APA and key stakeholders since the 2023 DIA award. He noted that a favourable DCAPE in early 2027 would allow the company to finalise its construction financing package, secure remaining operational licences, and begin the project build. The announcement also notes that a separate environmental licencing process will be required for the future development of the C-190 Aldeia Mining Concession, indicating further regulatory steps beyond the current process.

Regulatory Risk Remains if DCAPE Decision Is Conditional or Non-Compliant

Whilst the company states it expects a favourable DCAPE based on the submission and the prior positive DIA decision, Portuguese regulations provide for scenarios in which the decision could be conditionally compliant or non-compliant. In such cases, the managing authority would notify Savannah and hold a hearing for interested parties, with the company having the opportunity to contest the decision and submit objections. The managing authority would then decide whether to accept, partially accept, or reject those objections — a process that could extend the licencing timeline beyond the January 2027 target date.