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Producer responsibility for packaging

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Information and guidelines regarding the Swedish producer responsibility scheme for packaging.

If your business fills or otherwise uses packaging, imports packaged products, sells packaging or packaged products in Sweden, you are likely covered by the producer responsibility. This means that you must register as a producer of packaging with the Swedish Environmental Protection Agency and be affiliated to a suitable collection scheme. This applies regardless of the material from which the packaging is made.

The producer responsibility for packaging exists to reduce the amount of packaging waste. Producers of packaging who take their responsibility contribute, among other things, to reduced resource consumption and reduced emissions to the environment. Producers who take responsibility also contributes to a sustainable development and a circular economy.

Target group

Foreign companies that place or use packaging for their products and services on the Swedish market and foregin companies that provide, manufacture or import plastic carrier bags on the Swedish market.

Good to know

The Swedish government has decided on an ordinance (2022:1274) on producer responsibility for packaging. The ordinance comes into force on 1st of January 2023. Some provisions enter into force later. This guidance will be updated with the new regulations. 

News

The Swedish government has decided on an ordinance (2022:1274) on producer responsibility for packaging. The ordinance comes into force on 1st of January 2023. Some provisions enter into force later. Here you will find a summary of the new ordinance and information on the division of roles and responsibilities between stakeholders.  

Roles and responsibilities between stakeholders 

The new regulations aim to make it easier for households and businesses to sort and leave their packaging waste for recycling. Source separation should contribute to recycle more waste, that the handling of waste becomes more resource-efficient and that the need for new raw materials decreases, resulting in reduced CO2 emissions. The ordinance means that municipalities, producers, PRO-os and the Swedish EPA get new roles and tasks.  

New role for municipalities 
  • From 1 January 2024, the municipalities have the operational responsibility for collecting packaging waste from households and certain businesses and for informing households about preventive measures and sorting of packaging waste. 
  • No later than 1 January 2027 all municipalities must have introduced door-to-door collection of packaging waste from households. The packaging waste must be collected according to following materials:  paper, plastic, metal and glass (colored and non-colored glass). 
  • Bulky packaging waste made of paper and plastic must be collected at easily accessible public collection points.   
  • All packaging materials including packaging materials made of wood, ceramics, textiles and like must be collected at the municipality's recycling center. 
  • From 1 January 2026, the municipalities must collect packaging waste in squares, in parks and in other popular places outdoors. 
  • The producers must, through their affiliated PRO-os, reimburse the municipalities for the costs of the collection. The compensation is determined in regulations issued by the Swedish Environmental Protection Agency. 
Packaging waste from businesses 

From 1 January 2024, the producer responsibility organization with the largest market share will be obliged to establish collection sites for packaging waste from businesses.  

The collected waste from the collection sites will be distributed to producer responsibility organizations based on their respective market share. Other producer responsibility organizations, i.e. those that are not the largest, must compensate the largest producer responsibility organization for reasonable costs associated with operating the collection sites. 

Certain businesses whose waste management is co-located with households can require that the municipality collects their packaging waste. This applies to those businesses that use the same containers and space, together with households, for handling of waste on a property. That choice is made through a notification to the municipality.  

Businesses can also hand over their packaging or their packaging waste to so-called market-driven systems for reuse or material recycling. 

Producers and PRO-os 

All producers of packaging must be affiliated with an approved producer responsibility organization or provide a producer responsibility organization. The operations of producer responsibility organizations must be approved by the Swedish Environmental Protection Agency. The application for approval must be received no later than March 31 of the year before the operation begins. 

New regulations on return deposit systems 

The new regulation also includes rules on return deposit systems (i.e. bottles and cans). The responsibility for enforcement for the return system will be transferred as of 1 January 2023 from the Swedish Agency for Agriculture to the Swedish Environmental Protection Agency through a change in the ordinance on environmental enforcement. Return systems that have an existing approval can continue to operate by this approval until January 1st, 2027. After that, they may be re-examined by the new ordinance. 

On 3 November 2021, the Swedish Government decided on regulations implementing the Directive (EU) 2019/904 on the reduction of the impact of certain plastic products in the environment in Swedish legislation. The first rules came into force 1 January 2022. This means new requirements for you who are a producer of single-use plastic packaging. The single-use plastic packaging that are covered are beverage containers, cups, food containers, packets and wrappers made of flexible material and plastic carrier bags. In order for food containers, packages and wrappers to be covered by the Directive, they must contain foods that are intended to be consumed directly from the packaging or wrapper without further preparation.

In cases where a product is both a single-use plastic product (covered by the Directive on Single-use Plastics) and a packaging (as defined in Article 3 (1) of the Directive on Packaging and Packaging Waste), the requirements of both Directives must be met. In the event of a conflict between the two directives, the Directive on Single-use Plastics shall take precedence.

In accordance with the ordinance (2018:1462) on producer responsibility for packaging, a permit for a collection scheme for packaging waste was mandatory from 1 January 2021. Collection was not allowed unless a permit from the Swedish Environmental Protection Agency was issued.

The purpose of the ordinance is to make it mandatory to collect in packaging close-to-home and that the collection will be expanded throughout the country by 2025. On 20 May 2020, the Swedish Environmental Protection Agency announced two decisions to reject FTI:s (Packaging and Newspaper Collection) and TMR:s (Tailor Made Responsibility) applications for a permit for a collection scheme for packaging waste close-to-home.

The Swedish Environmental Protection Agency submitted a request on 15 June 2020, outlining the problems the agency see with the ordinance. The situation meant that there was a lack of a permit-required collection system as of January 1, 2021. The government will also review the rules on close-to-home collection of packaging and has decided on changes on the transitional provisions. The current collection of packaging under producers' responsibility will continue until further notice.

Packaging producers and their responsibilities

According to the Swedish regulation on producer responsibility for packaging a producer is anyone that professionally;

  • bring in packaged items or packaging to the Swedish market.
  • manufactures packaging in Sweden, or
  • places a packaged item on the Swedish market,
  • fills or otherwise uses a package for the purpose of protecting, presenting or facilitating the handling of an item. Does not apply service packaging. 
  • sells a packaged product or  packaging to an end user in Sweden from another country (this definition applies from 1 January 2023). 

As a producer, you have a responsibility to:

  • design and label packaging
  • collect packaging
  • register and report information to the Swedish Environmental Protection Agency

Definitions

Packaging is defined as a product that has been manufactured to: 

  • Contain an item 
  • Protect an item 
  • Present an item 
  • Used to deliver an item 
  • Otherwise handle a product 

This applies "from raw material to final product and from producer to user", according to section 7 of the Ordinance (2018:1462) on producer responsibility for packaging. 

Examples of packaging are milk cartons, shampoo bottles, cardboard cartons, packaging and trays.

Single-use products that are filled are also defined as packaging, and from 1 January 2023 this also applies to single-use cups that are sold empty. 

Read about service packaging to find out if your business uses packaging that is exempt from the producer responsibility.

The general concept of plastic carrier bags is defined in the Ordinance (2021:996) on single-use products as a plastic bag provided to enable consumers to pack and carry goods from the place where the goods are provided. Thin plastic carrier bags are defined as a plastic carrier bag thinner than 50 micrometers. Very thin plastic carrier bags are bags that are thinner than 15 micrometers and are needed for hygiene reasons or are provided for food sold in bulk. Plastic carrier bags that have been designed for long-term use are exempt by the rules.

Examples of beverage containers are plastic beverage bottles, including corks and lids, and beverage containers in composite materials, including corks and lids. 

The following four criteria can be used to determine whether a beverage container or beverage bottle is covered by the Regulation: 

  • is made entirely or partly of plastic, 
  • is not a mug, 
  • has a capacity not exceeding three liters, and 
  • is a container intended for liquid. 

A beverage container may be composed of more than one material, one of which may be plastic. In cases where one of the materials is plastic, the end product is considered to be partly made of plastic and is covered by the Directive on Single-use Plastics. When, for example, paper or cardboard-based beverage containers have a plastic lining or a plastic coating on the surface, they are partly made of plastic and are thus covered by the directive. 

Beverage containers in glass or metal with corks and lids made of plastic are not covered. 

Beverage containers and beverage bottles used for food for special medical purposes as defined in Article 2.2 g of Regulation (EU) No 609/2013 of the European Parliament and of the Council (21) and in liquid form shall be exempted from Article 6 in accordance with point b of Part C and point b of Part F of the Annex.

Cups are defined in the Ordinance on single-use products as glasses, cups or mugs intended for beverages (cold or hot) which are usually drunk directly from the container. A cup can be with or without a lid. 

Cups used for liquid, which meet the requirements set out above and are sold empty, are also covered by the ordinance (2018: 1462) on producer responsibility for packaging. 

A cup can be made entirely of plastic or composed of more than one material, one of which can be plastic. In cases where one of the materials is plastic, the end product is considered to be partly made of plastic and is covered by the Directive on Single-use Plastics. When, for example, paper or cardboard-based cups have a plastic lining or a plastic coating on the surface, they are partly made of plastic and are thus covered by the directive.

According to the Ordinance on single-use products, food containers are packages, with or without lids, that are molded or mostly unchanged in shape after the contents are added or removed. The food container can, for example, be used for fast food such as meals with cold or hot food, sandwiches, wraps and salads. Containers for foods containing fresh or processed foods that do not require any further preparation, such as fruits, vegetables and desserts, are also included.

A food container can be made entirely of plastic or composed of more than one material, one of which can be plastic. In cases where one of the materials is plastic, the end product is considered to be partly made of plastic and is covered by the Directive on Singe-use Plastics. When, for example, paper or cardboard-based food containers have a plastic lining or a plastic coating on the surface, they are partly made of plastic and are thus covered by the directive.

In order for a food container to be covered by the Ordinance on single-use products, it must be used for fast food. A food container, with or without a lid, is therefore covered by the regulation if it is used for food that: 

  • are intended to be consumed directly (at the point of sale or elsewhere), 
  • is usually consumed directly from the packaging, 
  • and is ready to be consumed without any further preparation (for example, cooking, cooking, heating).

In addition to the above criteria, the probability that a food container will become debris due to its volume or size must be included in the assessment to determine whether it is a disposable plastic product covered by the Directive.

Food containers used for food that meet the requirements of the Directive but are sold empty and are not intended to be filled at the point of sale are also covered by the Directive.

According to the Directive on Single-use Plastics, packets and wrappers are defined as packaging made of a flexible material. In the Ordinance (2018: 1462) on producer responsibility for packaging, a flexible wrapper is a flexible disposable plastic product that contains foods that are intended to be consumed directly from the packaging without further preparation.

A flexible wrapper for food can be made entirely of plastic or composed of more than one material, one of which can be plastic. In cases where one of the materials is plastic, the end product is considered to be partly made of plastic and covered by the Disposable Plastics Directive. When, for example, paper-based flexible wrappers have a plastic lining or a plastic coating on the surface, they are partly made of plastic and are thus covered by the directive.

Design and labelling requirements for packaging

As a producer of packaging, you have a responsibility to design packaging based on the requirements set by legislation.

New design requirements 

As of 3 July 2024, beverage containers must have attached corks and lids during the entire use in order to be provided on the Swedish market. This requirement applies to beverage containers that have corks and lids containing plastic. The requirement is considered to be met if the beverage container complies with the criterias in the harmonized standard SS-EN 17665 or if the producer in other ways can show that the beverage container is designed so that the requirement is met. The requirement does not apply to beverage containers in glass or metal or which are intended for special medical purposes.

As of 1 January 2025, single-use bottles for beverages consisting of polyethylene terephthalate (PET) must contain at least 25 % recycled plsatic in order to be placed on the Swedish market.  The calculation of the content of recycled plastic will be made as an average of the content of the bottles that a producer has provided on the Swedish market during a calendar year. Exemptions to the requirement are PET bottles with a volume of more than three liters and bottles that are intended for special medical purposes.

From the year 2030, all bottles for beverages that are a single-use plastic product up to three liters must contain at least 30 % recycled plastic to be available on the Swedish market. The content of recycled plastic will be calculated in the same way as was previously done for PET bottles and the same exemptions applies. 

The producers responsibility

The producer has a responsibility to produce packaging so that it fulfills the purpose of the regulation, which is to reduce the amount of packaging waste.

This means that:

  • packaging should only be used when necessary
  • has a volume and weight that is limited to the minimum required to maintain a good level of safety and hygiene;
  • can be reused or recycled; and
  • is designed so that emissions of harmful substances are minimized and the environmental impact is otherwise limited when packaging waste is treated or residual products from the disposal of packaging waste are disposed of.

The manufacturer must ensure that the packaging can be reused or recycled. Emissions of harmful substances must be minimized when packaging waste is treated. The impact on the environment in general shall be limited when the packaging waste or residual products from disposal are disposed of.

Reusable packaging means packaging which during normal use:

  • can be reused several times,
  • can be treated in accordance with hygiene and safety requirements for workers and which
  • can be recycled when no longer in use.

Recyclable packaging means packaging that can be recycled through material utilization, energy recovery or composting but handling packaging waste shall be done according to the waste hierarchy.

Standards have been developed for how packaging should be designed to meet the requirements. Standards have been developed within the EU. However, it is optional to use the standards and the producer can instead choose to demonstrate that the requirements are met.

Packaging - Packaging and the environment – Terminology at SIS

Standards have been developed for how packaging should be designed to meet the requirements. Standards have been developed within the EU. However, it is optional to use the standards and the producer can instead choose to demonstrate that the requirements are met.

Packaging - Packaging and the environment – Terminology at SIS

Commission Decision 97/129 / EC p contains proposals for lalbeling of packaging. According to the Packaging Regulation in Sweden, labeling is not compulsory, but if packaging is labeled, the labeling must be made in accordance with the proposal contained in the Commission decision. The obligation to label packaging may vary in different EU countries. It is therefore good to check this for every country where you are a producer.

Cups that are a single-use plastic product must be provided with a clear and standardized marking. The marking must show how the product is to be handled as waste, describe the negative environmental effects of the product and the presence of plastic in the product. The purpose of the marking requirement is to inform consumers about proper handling to reduce litter.

The cups must have the marking when they are placed on the market and it is the producer of the cups who is responsible for the requirement being met. The information text on the marking must be written in the official language or languages of the Member State or Member States in which the cup is placed on the market. This means that products placed on the market in Sweden must have a marking in Swedish.

The EU Commission determined on 17 December 2020 in the EU regulation on marking (EU 2020/2151) what the marking should look like and where it should be placed:

Commission implementing regulation (EU) 2020/2151

Print original (pictogram in vectorized format)

Restrictions on placing on the market

Certain single-use plastic products, where adequate replacement alternatives exist, are completely prohibited within the EU and have been decided in Swedish legislation by ordinance (2021: 996) on single-use products. Adequate replacement alternatives means that the product is already on the market in another material or as a reusable alternative. The prohibition only applies to those who put the products on the market for the first time, ie the producers. Others who sell or supply these products may continue to do so even after the requirement has come into force. 

Prohibited packaging:

  • Beverage containers containing expanded polystyrene (eg styrofoam).
  • Single-use cups and single-use food containers containing expanded polystyrene.
  • Corks and lids containing expanded polystyrene which are used for

    A) Single-use food containers
    B) Beverage containers, or
    C) Single-use cups.
  • Single-use cups containing more than 15 % plastic (this prohibition applies in Sweden from 1 January 2024).

Please note that this is not a complete list of prohibited products. The prohibited products listed here are those that concern packaging.

Targets

If it emerges that the targets may not be achieved in time, further measures may be needed.

According to Sections 24-25 of the Ordinance (2021: 996) on single-use products, the consumption of cups and food containers that are single-use plastic products shall be reduced by 50% by 2026. All actors who professionally supply or use cups and food containers that are single-use plastic products must actively work to achieve this target as of 1 January 2024.

Another target is to generally reduce the consumption of plastic carrier bags and ensure that the consumption of thin plastic carrier bags is no more than 40 per person and year by 31 December 2025. This calculation does not include plastic carrier bags that are thinner than 15 micrometers and are needed for hygiene reasons or provided mainly as packaging for food sold in bulk.

Consumption can be reduced in several different ways, such as offering alternative products that can be reused or single-use plastic products that are not free of charge.

Reduced consumption includes

  • Food containers
  • Cups
  • Plastic carrier bags
  • Thin plastic carrier bags

This target will be followed up by the information that producers must report annually to the Swedish Environmental Protection Agency.

Producers of single-use plastic packaging are obliged to contribute effectively to achieving the target of reducing litter. The target is to reduce single-use plastic packaging outdoors by 50% until 2030 compared with 2023. This target will be followed up by waste measurements carried out by the Swedish Environmental Protection Agency from 2023 and every other year thereafter. Reduced litter includes:

  • Flexible wrappers
  • Food containers that are single-use plastic products
  • Cups that are single-use plastic products
  • Single-use plastic lids for cups or food containers
  • Plastic bottles for beverages that hold less than 0.6 liters
  • Plastic bottles for beverages that hold more than 0.6 liters
  • Beverage containers other than plastic bottles that hold less than 0.6 liters
  • Beverage containers other than plastic bottles that hold more than 0.6 liters
  • Thin plastic carrier bags

Producers of packaging consisting of more than 50% plastic must effectively contribute to the target of using recycled plastic in plastic packaging. By 2030, the packaging must on average consist of at least 30% recycled plastic. 

Export

An Authorised Representative must be appointed if a producer is established in Sweden and sells certain single-use plastic products to another country in the European Economic Area (EEA) where the producer is not established. The representative shall be responsible for the obligations of the producer in that country.

This applies if the producer sells one of the following single-use plastic products:

  • Beverage containers
  • Flexible wrappers
  • Thin plast carrier bags
  • Cups
  • Food containers
  • Single-use plastic lids for cups or food containers

Producers who are not established in Sweden may appoint a representative established in Sweden. It is thus not a requirement to appoint a representative, but if a representative is not appointed, it is the producer who is responsible for their obligations in Sweden. If a representative is appointed, it must be done by a written power of attorney. The representative shall then be responsible for the producer's obligations in the Ordinance (2018:1462) on producer responsibility for packaging and the Ordinance (2021:1002) on littering fees. The representative must also do a registration to the Swedish Environmental Protection Agency. Information about registration will be published on this page.

Collection

It is the producers who place or provide packaging on the market who are responsible for ensuring that there are suitable collection schemes. A collection scheme is suitable if it is easily accessible, makes it easier for the person who hold and want to dispose packaging waste and provides good service to those who are to leave packaging waste to the scheme. For a collection scheme to be suitable, it must also contribute to the goal of material recycling, and as of year 2023 contribute to the goal of reduced litter. 

Today, most producers take their responsibility to collect by joining so-called material companies that offer collection on behalf of the producers. Even if they in this way instruct another party to carry out the collection, it is the producers who are responsible for fulfilling the obligations.

From 1 January 2023, a permit from the Swedish Environmental Protection Agency is required for a collection scheme to be able to collect packaging waste from households. Producers must then be connected to a collection scheme with a permit. A permit is not required for the collection of packaging waste that arises in connection with professional activities.

Recycling system for plastic bottles and metal cans

In order to sell plastic bottles and metal cans for beverages on the Swedish market, they must be part of an approved recycling system. From 2023, this also applies to plastic bottles or metal cans that mainly consist of vegetable, fruit or berry juice.

It is the one who professionally bottles the beverage or professionally brings the beverage to Sweden who is responsible for the plastic bottles and metal cans being included in an approved recycling system. For more information please visit the Swedish Board of Agriculture’s website.

Recycling system for plastic bottles and metal cans (jordbruksverket.se)

Serving in reusable cups and food containers

As of 1 January 2024, businesses that sell food or beverages must be able to offer the opportunity to have it served in reusable cups and food containers, according to the ordinance (2021: 996) on single-use products. Businesses must also inform consumers about this opportunity.

The one who is to provide reusable cups and food containers must choose the ones that have the least negative impact on the environment and human health. The reusable cups and food containers must also be part of a rotation system in order for them to be reused.

At the point of sale, consumers must be informed about the environmental impact of single-use cups and food containers and the benefits of a reduced consumption of single-use cups and food containers.

Exemption from serving in recyclable cups and food containers

The one who provides a single-use cup or food container that consists entirely of paper or cardboard and that has not been chemically modified in a way that delays the decomposition is exempted from the requirement. 

Anyone who provides less than 150 single-use cups or food containers per day is also not covered by the requirements. The number provided shall be calculated as an average during the days that the point of sale is open during a calendar year. Those who are not covered by the requirements and who do not choose to provide reusable cups and food containers must create routines to ensure that no more than 150 single-use cups or food containers are provided per day on average. As of 1 January 2026, the exemption are fewer than 75 single-use cups or food containers.

Information requirements regarding plastic bags

Those who professionally provides plastic carrier bags must inform consumers about the environmental impact:

  • the environmental impact of plastic carrier bags 
  • the benefits of reducing the consumption of plastic carrier bags 
  • measures that can be taken to reduce the consumption of plastic carrier bags

The information provided should encourage responsible consumer behavior and should be easily accessible and recurring to the consumer.

The requirement for information has been decided in the ordinance (2021:996) on single-use products and does not cover plastic carrier bags provided remotely. This also does not apply to plastic carrier bags that are thinner than 15 micrometers and are needed for hygiene reasons or provided mainly as packaging for food sold in bulk.

E-services for registration and reporting

The Swedish Environmental Protection Agency (EPA) has launched an application for registering of Extended Producer Responsibility. To log in you must have an e-ID. 

The Swedish Tax Agency uses our login service and has foreign e-ID as the login method on its website. If you want to test your e-credentials, you can do so at The Swedish Tax Agency.

The Swedish Tax Agency

  • BankID  
  • Telia  
  • Freja elD +  
  • Foreign elD  
  • BankID Norge 

The following countries have been approved by Sweden Connect and can log in with foreign e-identification.  

  • Belgium
  • Estonia
  • Italy
  • Croatia
  • Latvia
  • Luxemburg
  • Portugal
  • Slovakia
  • Spain
  • the Czech Republic
  • Germany

If your country does not have a valid e-ID then you can agree with a licensed collection scheme to report for you. 

How to register

According to the Swedish Packaging Ordinance (2018:1462), all parties defined as a producer are to register with the Swedish EPA.

  • name; contact information; personal or corporate identification number; and
  • the collection scheme the producer is affiliated with.

Information is provided via the e-service

As a packaging producer, you are to register in the e-service for Disclosure for Producers with Extended Producer Responsibility (EUPA). If you need to update or modify information, you can do so using the same service.

When registering in the e-service, identification occurs through electronic identification (eID). For foreign parties, foreign eID is available as an alternative. Eight European countries are currently affiliated with the eID system.

If your country is not affiliated with eID, you can instead:

  • ask your collection scheme to make the registration for you;
  • appoint a person with a valid eID who can register for you.

If your organisation’s contact information is registered with the Swedish Companies Registration Office, it is automatically retrieved when the corporate identification number is entered. The same applies if you have used the e-service before, such as when you reported that you are offering electronics or batteries on the Swedish market.

The Swedish EPA is also working on a technical solution to allow existing information to be transferred from the collection schemes register to the Swedish EPA’s register.

You can use the e-service to log in with your identification number as a producer and double check that the collection scheme has submitted correct information.

If your company has registered as a producer of packaging but is not defined as one anymore, you must deregister. In order to deregister you must send an e-mail to the Swedish Environmental Protection Agency, kundtjanst@naturvardsverket.se, with the following information:

  • The company name and organization number
  • Describe and state reasons why your company no longer should be in the Swedish Environmental Protection Agency's register of producers
  • State the date from which your company ceased operations related to the producer responsibility you intend to deregister
  • Indicate if your company has products stored that are covered by a producer responsibility and will be sold during the current year or later.

If your company has packaging or packaged goods that have been sold or will be sold during the current year, the company can not be deregistered until the following year's reporting has been submitted. Return with your request to deregister and response to the above information after next year's reporting is done. You must also deregister with your collection scheme.

How to report

The Swedish Environmental Protection Agency receives and compiles information that producers report or the information reported by material companies on behalf of the producers. The Swedish EPA then compares the statistics with the targets set in Swedish and EU legislation.

The reporting requirement applies if a producer, during the previous calendar year, has: 

  • filled or otherwise used  packaging (that is not  service packaging) for the purpose of protecting, presenting or facilitating the handling of an item 
  • brought a packaged product to Sweden 
  • manufactured  service packaging in Sweden 
  • brought  service packaging to Sweden

As of year 2023, the reporting requirement also applies to those who, during the previous calendar year, have: 

  • sold a packaged product or  packaging from a country other than Sweden to an end user in Sweden
  • manufactured a single-use cup in Sweden or brought a single-use cup to Sweden 

When to report?

Reporting is to take place no later than 31 March of each year.

Packaging and reusable packaging

The report shall contain information on the amount of packaging that the producer has provided or placed on the Swedish market during the previous calendar year. The information must state the quantity of the packaging which is consumer packaging, reusable packaging and reusable consumer packaging. The quantity must be stated by weight and specified by packaging material.

Packaging with hazardous substances

In cases where the packaging producer has provided or placed packaging on the Swedish market that is reported to the European Chemicals Agency's SCIP database, these packaging must also be stated in the E-service. The SCIP database aims to increase knowledge about hazardous chemicals in goods and products.

Plastic carrier bags

The report shall contain information on the number of plastic carrier bags manufactured in or brought into Sweden intended for the Swedish market. The information must be specified in thin plastic carrier bags and thick plastic carrier bags. These data must indicate the amount of thin plastic carrier bags that have walls thinner than 15 micrometers, are needed for hygiene reasons or are provided as packaging for bulk food.

Single-use plastic products

As of year 2023, the report shall contain information on the number of single-use plastic products that are packaging and that the producer has provided or placed on the Swedish market during the previous calendar year. The single-use plastic products that are packaging and to be reported are:

(a) food containers

(b) cups 

(c) single-use plastic lids for cups 

(d) flexible wrappers

(e) plastic bottles for beverages that hold less than 0.6 liters 

(f) beverage containers other than plastic bottles that hold less than 0.6 liters

The information must be specified in each product category.

Regarding food containers (a) and cups (b) that are single-use plastic products, the report shall also include information on the weight of the plastic used in food containers (a) and cups (b).

As of year 2024, producers of single-use beverage bottles made from PET will report how much recycled plastic has been used in the bottles during the previous calendar year. In 2030, this reporting requirement applies to producers who supply all types of beverage bottles that are a single-use plastic product.

The EU Commission Implementing Decision (2019/665) amending Decision 2005/270 / EC establishing the format of the database for the database according to Directive 94/62 / EC of the European Parliament and of the Council on packaging and packaging waste states that:

Composite packaging and other packaging consisting of more than one material are calculated and reported per material included in the packaging. Member States may deviate from this requirement if a particular material constitutes an insignificant part of the packaging unit and under no circumstances more than 5% of the total mass of the packaging.

Composite packaging

A composite packaging is a packaging with two or more layers of different materials that can not be separated by hand and that forms an integrated unit, consisting of an inner container and an outer casing, which is filled, stored, transported and emptied as such (Packaging Directive, Article 3).

In some contexts in the packaging industry, the terms "composite" and "laminate" have different meanings. Where composite refers to mechanically mixed materials, while laminate refers to materials of several layers that can be separated. In packaging reporting, both of these concepts are included in the definition of composite packaging.

Examples of composite packaging and packaging that consists of more than one material 

  • A beverage packaging in cardboard where the inside is laminated with plastic is an example of a compost packaging. 
  • A glass packaging with a screw cap in metal is an example of another packaging that consists of more than one material.

Possible handling of insignificant parts (5% criterion) 

In cases where a composite packaging contains a material that constitutes less than 5 percent of the total mass of the packaging, this can be handled in two ways.

Reporting of the insignificant part to current material 

Preferably, the weight of the packaging is reported per material included in the packaging, even for those materials that make up less than 5 percent of the total mass of the packaging.

Allocate the insignificant part to the dominant material

It is also possible to allocate the insignificant part to the predominant material in the packaging. The example below is from the EU Commission's guidelines.

If a composite packaging consists of

  • 75 percent paper, 
  • 21 percent plastic and 
  • 4 percent metal

it is allowed to allocate the amount of metal to the predominant material paper. It is thus permitted to report 79 percent paper and 21 percent plastic.

Fees

In accordance with the polluter pays principle, littering fees are introduced in order to reduce the negative impact that litter of single-use products in outdoor environments has on the environment. Littering fees consist of an annual fee and a product fee.

The Swedish government has decided on the fees in ordinance (2021:1002) on littering fees.

Annually, an enforcement fee will be sent out to producers of packaging. The fee is SEK 500 per producer and calendar year. As of 2023, the enforcement fee is SEK 1,000 per producer and calendar year.

The fee shall cover the Swedish Environmental Protection Agency's enforcement. The enforcement includes, among other things, to provide and administrate a register of producers and ensure compliance with the rules on producer responsibility.

Sanctions

If a company has not complied with the legislation, it may lead to an environmental sanction fee. An environmental sanction fee is an administrative fee that is charged by a supervisory authority when an operator has committed violations of a fee-based provision in accordance with the Environmental Code, or the rules that have been decided on the basis of the Environmental Code.

In the event of a violation of the rules regarding producer responsibility for packaging or single-use products, the Swedish Environmental Protection Agency, as the supervisory authority, shall charge environmental sanction fees. The violations that are to result in an environmental sanction fee are stated in Chapter 11. §§ 19-23 Ordinance (2012: 259) on environmental sanction fees.

An operator may in certain cases be allowed to sell out the stock of goods that are now prohibited, or unmarked products that are subject to marking requirements. Whether the goods may be sold depends on whether they are considered to be released on the market before 1 January 2022 or not.

If a producer places a prohibited single-use plastic product on the Swedish market from 1 January 2022, an environmental sanction fee may be charged. The size of the environmental sanction fee depends on how many products have been placed on the Swedish market: 

  • SEK 5,000 if 100 or fewer products have been placed. 
  • SEK 10,000 if more than 100 but a maximum of 1,000 products have been placed. 
  • SEK 20,000 if more than 1,000 but a maximum of 20,000 products have been placed. 
  • SEK 50,000 if the infringement of more than 20,000 products has been placed. 

As of 1 January 2024, disposable cups containing more than 15% plastic are also covered by the environmental sanction fee.

If a producer places a product on the Swedish market without having provided the product with the required marking, an environmental sanction fee of SEK 10,000 may be charged. This applies from 4 July 2022.

If a producer has submitted information when reporting late to the Swedish Environmental Protection Agency, an environmental sanction fee of SEK 10,000 may be charged.

If a business sells food or drink in a single-use cup or food container and does not offer the opportunity to have the food or drink served in reusable cups or food containers, an environmental sanction fee of SEK 10,000 may be charged. This applies from 1 January 2024.

If a producer provides a beverage container on the Swedish market without being designed with the cork or lid consisting of plastic attached to the container during the entire use, an environmental sanction fee of SEK 10,000 may be charged. This applies from 3 July 2024.

If your company does not comply with the legislation above, this may lead to you having to pay an environmental sanction fee. You will receive a letter from the Swedish Environmental Protection Agency with a proposal for a decision on the environmental sanction fee. We send this letter to you as a notification that we are considering chargingan environmental sanction fee.

You then have the opportunity to comment on the proposed decision within the time stated in the letter. This means that you can provide information on why you believe that you should not be charged an environmental sanction fee. A comment can be sent by letter or e-mail.

Valid reasons to not charge an environmental sanction fee are described in Chapter 30, Section 2 of the Environmental Code.

 An environmental sanction fee shall be charged even if the violation has not taken place intentionally or through negligence. However, the fee does not need to be charged if it would be unreasonable with regard to:

  1. illness which has resulted in you not being able on your own or by instructing someone else to do what your duty was,
  2. that the violation was due to a circumstance which could not or should not have been foreseen or which you could not influence,
  3. what youhave done to prevent a violation from occurring, or
  4. that the violation has given rise to penalty in accordance with the provisions of Chapter 29.

The environmental sanction fee shall accrue to the Swedish state. Law (2006:1014).

If you choose not to comment, or if the information you provided in the statement cannot be the basis for not charging an environmental sanction fee, you will receive a decision on an environmental sanction fee.

The decision contains information on when and how to pay the environmental sanction fee. You pay the environmental sanction fee to Kammarkollegiet and it goes to the state. You will receive the decision together with a service receipt that the authorized person must date, sign and send back to the Swedish Environmental Protection Agency.

You can appeal the decision within three weeks from the day you received the decision.

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