Sweden EPR
- Ordinance (2022:1274) on Producer Responsibility for Packaging
- In force since 1 January 2023
- Supervised by Naturvårdsverket (Swedish Environmental Protection Agency – Swedish EPA)
Does this apply to e-commerce & online sales?
Yes — explicitly. Sweden includes distance sellers in its producer definition. You are considered a producer if you:- Sell packaged goods from another country directly to end users in Sweden
- Operate an online shop shipping goods to Swedish consumers
- Sell via marketplaces and ship directly to Sweden
Who is the “Producer” in Sweden
Under Ordinance (2022:1274), a producer is any entity acting professionally that:- Fills or uses packaging to protect/present products
- Manufactures packaging in Sweden
- Imports empty packaging into Sweden
- Imports packaged goods into Sweden
- Sells packaged goods or packaging from abroad directly to Swedish end users
Who Must Register for EPR Packaging in Sweden
Any producer must:- Register with Naturvårdsverket
- Join a Producer Responsibility Organization (PRO)
- NPA (Näringslivets Producentansvar AB)
- TMR (Tailor-Made Responsibility)
- Fee collection
- Reporting aggregation
- Operational recycling responsibilities
Sweden EPR Packaging – Registration Threshold
Under the current Swedish packaging EPR system, there is no formal de minimis packaging volume threshold that exempts a business from having to register as a producer if it places packaging on the Swedish market. In other words:
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If you place packaging on the Swedish market, regardless of the amount (kg/tonnes), you are considered a producer and required to register with the Swedish Environmental Protection Agency (Naturvårdsverket) and comply with producer obligations (e.g., affiliate with a PRO, report volumes).
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Packaging Covered (and Excluded)
Covered Packaging
Sweden’s EPR applies to:- Household (consumer) packaging
- Non-household (commercial/industrial) packaging
- Primary, secondary and transport packaging
- Service packaging
- E-commerce shipping packaging
- Paper & cardboard
- Plastic
- Metal
- Glass
- Wood
- Composite materials
Prohibited / Restricted Packaging (Single-Use Plastics)
Sweden implements EU Single-Use Plastics rules. Key restrictions include:- EPS (expanded polystyrene) beverage containers – banned
- EPS food containers and cups – banned
- Single-use cups containing more than 15% plastic – banned since 1 January 2024
- Tethered caps requirement for beverage containers – effective 3 July 2024
- Recycled plastic content requirement for PET bottles – effective 1 January 2025
Producer Responsibility Organization (PRO)
A PRO is an approved compliance scheme responsible for:- Organizing national collection systems
- Managing recycling operations
- Charging eco-fees
- Reporting to authorities
EPR Registration in Sweden – Step-by-Step
- Determine if you qualify as a producer
- Register in the Swedish EPA EPR portal
- Join an approved PRO
- Submit packaging data
- Pay eco-fees
- Maintain reporting compliance
Authorized Representative
If you are not established in Sweden, you may appoint a producer representative (producentombud) established in Sweden. Requirements:- Written power of attorney
- Representative must be legally established in Sweden
What Data Must Be Reported
Producers must report packaging placed on the Swedish market by: Material Type- Plastic
- Paper/cardboard
- Glass
- Metal
- Wood
- Composite
- Household vs non-household
- Single-use plastic categories (if applicable)
- Recycled plastic content (for certain PET bottles)
- Data required under littering-fee categories
First Reporting Period
- Ordinance effective: 1 January 2023
- First major PRO reporting to authority: 31 March 2025 (for 2024 data)
- Monthly or quarterly
- Typically by the 25th day after reporting period
EPR Reporting Deadlines
| Obligation | Deadline |
| Registration | Before placing packaging on market |
| Producer → PRO reporting | Monthly/Quarterly (often by 25th) |
| PRO → Swedish EPA | Annually by 31 March |
| PET recycled content report | 31 March annually |
Labels & Marketing Claims
Material Identification Labels Not mandatory, but if used must comply with EU Decision 97/129/EC coding system.Mandatory Labels
Single-use plastic cups must:- Include mandatory EU marking
- Be labelled in Swedish
- “Recyclable”
- “Sustainable”
- “Eco-friendly”
EPR Eco-Fees & Eco-Modulation
PRO Eco Fees Fees are based on:- Weight (kg/tonnes)
- Material type
- Recyclability
- Environmental performance
- More recyclable packaging = lower fees
- Hard-to-recycle packaging = higher fees
Enforcement Fee (Authority Fee)
Producers must pay:- SEK 1,250 per year
- Producers placing less than 1 tonne per year are exempt (except littering-fee categories).
Littering Fees
Apply to certain single-use plastic packaging categories. Structure:- Fixed annual fee (since 2023)
- Variable product-based fee (since 2024)
Risks, Penalties & Common Mistakes
Environmental Sanction Fees| Violation | Penalty |
| Late registration | Sanction fee (from 1 Jan 2024) |
| Not joining PRO | SEK 30,000 |
| Late reporting | SEK 10,000 |
| Missing SUP labeling | SEK 10,000 |
| Tethered caps non-compliance | SEK 10,000 |
Common Mistakes by E-commerce Sellers
- Assuming importer is responsible
- Failing to register before selling
- Not joining a PRO
- Underreporting packaging weight
- Ignoring single-use plastic restrictions
- Missing reporting deadlines
What E-commerce Sellers Should Do Now
- Map supply chain responsibility
- Confirm producer status
- Register before selling
- Join PRO (NPA or TMR)
- Collect packaging weight data
- Check single-use plastic compliance
- Prepare internal compliance calendar
When does PPWR apply
From 12 August 2026, EU-wide packaging reforms begin applying.Register online
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FAQ
Do small sellers need to comply?- Yes. Even small sellers must register and join a PRO. The enforcement fee may be exempt under 1 tonne.
- Not mandatory, but recommended if not established in Sweden.
- Only for specific single-use plastic items.