Sweden EPR

Provinces
Packaging
Provinces
Packaging
About
Packaging
About
Packaging
Packaging
Packaging
Sweden’s Extended Producer Responsibility (EPR) for packaging makes producers financially and operationally responsible for the collection, sorting, recycling, reporting, and environmental performance of packaging placed on the Swedish market. The current legal framework is:
  • Ordinance (2022:1274) on Producer Responsibility for Packaging
  • In force since 1 January 2023
  • Supervised by Naturvårdsverket (Swedish Environmental Protection Agency – Swedish EPA)
The law implements EU waste and packaging directives and will further align with the upcoming EU Packaging and Packaging Waste Regulation (PPWR) from 12 August 2026.

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
If you place packaging on the Swedish market through cross-border e-commerce, you likely have direct EPR obligations.

Who is the “Producer” in Sweden

Under Ordinance (2022:1274), a producer is any entity acting professionally that:
  1. Fills or uses packaging to protect/present products
  2. Manufactures packaging in Sweden
  3. Imports empty packaging into Sweden
  4. Imports packaged goods into Sweden
  5. Sells packaged goods or packaging from abroad directly to Swedish end users
The key concept is:  Who first places the packaging on the Swedish market? That entity carries the obligation.

Who Must Register for EPR Packaging in Sweden

Any producer must:
  • Register with Naturvårdsverket
Registration must be completed before placing packaging on the Swedish market. Registration is done via the Swedish EPA EPR e-service portal.
  • Join a Producer Responsibility Organization (PRO)
Producers must affiliate with an approved PRO to fulfill collection and recycling obligations. Approved PROs in Sweden include:
  • NPA (Näringslivets Producentansvar AB)
  • TMR (Tailor-Made Responsibility)
The PRO manages:
  • 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:

  • 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
Packaging materials include:
  • 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
PROs must report annually to Naturvårdsverket by 31 March (starting with 2024 reporting data).

EPR Registration in Sweden – Step-by-Step

  1. Determine if you qualify as a producer
  2. Register in the Swedish EPA EPR portal
  3. Join an approved PRO
  4. Submit packaging data
  5. Pay eco-fees
  6. Maintain reporting compliance
Failure to register before market placement can result in penalties.

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
If you are established in Sweden but sell into another EU/EEA country where you are not established, you must appoint a representative there.

What Data Must Be Reported

Producers must report packaging placed on the Swedish market by: Material Type
  • Plastic
  • Paper/cardboard
  • Glass
  • Metal
  • Wood
  • Composite
Weight (kg or tonnes) Packaging Type
  • Household vs non-household
  • Single-use plastic categories (if applicable)
Additional data may include:
  • Recycled plastic content (for certain PET bottles)
  • Data required under littering-fee categories
PROs may require monthly or quarterly data submission.

First Reporting Period

  • Ordinance effective: 1 January 2023
  • First major PRO reporting to authority: 31 March 2025 (for 2024 data)
Producers generally report to PRO:
  • 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
Marketing claims such as:
  • “Recyclable”
  • “Sustainable”
  • “Eco-friendly”
Must comply with EU consumer protection law and must not be misleading.

EPR Eco-Fees & Eco-Modulation

PRO Eco Fees Fees are based on:
  • Weight (kg/tonnes)
  • Material type
  • Recyclability
  • Environmental performance
Eco-modulation means:
  • More recyclable packaging = lower fees
  • Hard-to-recycle packaging = higher fees

Enforcement Fee (Authority Fee)

Producers must pay:
  • SEK 1,250 per year
Exception:
  • 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

  1. Map supply chain responsibility
  2. Confirm producer status
  3. Register before selling
  4. Join PRO (NPA or TMR)
  5. Collect packaging weight data
  6. Check single-use plastic compliance
  7. Prepare internal compliance calendar

When does PPWR apply

From 12 August 2026, EU-wide packaging reforms begin applying.

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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.
Do foreign sellers need a Swedish representative?
  • Not mandatory, but recommended if not established in Sweden.
Is packaging labeling mandatory?
  • Only for specific single-use plastic items.
 
February 24, 2026 43
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