England fans were involved in running battles with the police for the second night running in the Algarve in Portugal.
Portuguese police said 32 fans had been arrested overnight, in addition to the 12 held on Monday night.
Riot police clashed with around 400 bottle-throwing supporters in Albufeira – the base for many of the England fans who have travelled to Portugal for Euro 2004.
UK Sports Minister Richard Caborn told the ITV News Channel: “These are not fans, they are hooligans, thugs who just go out there to cause trouble.”
But Mr Caborn does not believe England will be thrown out of the competition.
“I have been talking to the Portuguese authorities, Uefa and my colleagues in the Football Association.
“They know that we have taken every step possible to root out this rogue element.”
UEFA have previous warned England that hooliganism could see them expelled.