Sweden EPR

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).

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

Labels & Marketing Claims

Sweden does not require mandatory recycling labels on general packaging. However, material-specific sorting labels are widely used voluntarily by producers to help consumers dispose of packaging correctly.

An example of what a label looks like on packaging for Sweden

This packaging shows a "Pappersförpackningar" (paper packaging) sorting label — a black square pictogram with a carton icon. It indicates that the packaging should be placed in the paper packaging collection stream, and is commonly found on beverage cartons and food boxes.

📎 Download the Pappersförpackningar label:

•  PNG – best for digital use.
•  SVG  - ideal for printing and scaling.

Single-use plastics mandatory label

This packaging shows two mandatory symbols required under the EU Single-Use Plastics Directive. The red symbol indicates the product should not be flushed down the toilet. The blue symbol with a turtle warns that the product contains plastic. The text "Produkten innehåller plast" ("This product contains plastic") is mandatory in Sweden for wet wipes and similar single-use plastic products.

📎 Download the the Single-Use Plastics labels:

•  PNG – best for digital use.

Any environmental claims such as "recyclable" or "eco-friendly" must be substantiated and must not mislead consumers under Swedish and EU consumer protection law.

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

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.

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.