Support and information

Producer responsibility for packaging

Hopvikta pappkartonger

Here you can find support and information for you who are a producer of packaging and thus have producer responsibility for packaging.

On this page you can read about who is defined as a producer, which packaging is covered by the regulation and other information that you primarily need to know in order to fulfill your producer responsibility according to the regulation.

Target group

You as a producer of packaging and you as a producer representative for a packaging producer. 

Good to know

The Swedish government has decided on 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 continuously. 

The information for producers of packaging is divided into fundamental and in-depth support. This page contains what you primarily need to know. In-depth support for you as a packaging producer and you as a producer representative can be found here:

In-depth support and information for producers of packaging

Swedish Ordinances (in Swedish only)
EU directives 

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. 

Who is a producer of packaging?

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

  • fills or otherwise uses packaging (that is not a service packaging) for the purpose of protecting, presenting or facilitating the handling of an item 
  • brings a packaged product to Sweden.
  • manufactures packaging in Sweden
  • brings packaging to Sweden
  • sells packaging or a packaged product to an end user in Sweden from another country 

If your business falls under any of the above points, you are defined as a producer.

Anyone who fills or uses service packaging is exempt from producer responsibility. To determine whether you are filling or otherwise using packaging that is exempt from producer responsibility, you can read more under "Products covered".

As a producer, you have a responsibility to, for example:

  • Be affiliated to a collection scheme (as of November 1st 2023, an approved producer responsibility organization)
  • Register with the Swedish Environmental Protection Agency
  • Report information to the Swedish Environmental Protection Agency
  • Pay an annual enforcement fee to the Swedish Environmental Protection Agency

Products covered

Packaging that is covered by the producer responsibility is defined as a single-use item or other product that has been manufactured to: 

  • Contain a product 
  • Protect a product 
  • Present a product
  • Used to deliver a product or in other ways handle a product  

This applies from raw material to final product and from producer to user.

The product is covered if it has any of the above functions and is a:

  • Consumer packaging (packaging which, at the point of sale, constitutes a sales unit for the final user or consumer of the goods)
  • Group packaging (packaging which at the point of sale comprises a group of sales units and can be removed without affecting the goods)
  • Transport packaging (packaging that facilitates the handling and transport of a number of sales units or group packaging to prevent damage during handling or transport damage, can for example be wooden pallets, plastic boxes and metal cages), or
  • Service packaging (packaging that is filled at the point of sale or used for unprocessed products from agriculture or horticulture, may for example be carrier bags, pizza boxes, egg boxes and bags for potatoes)

This applies regardless of the material the packaging is made of.

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. 

Definitions

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.

Collection scheme

Until October 31st 2023, the following applies to you as a producer;

To ensure that your packaging is taken care of when it becomes waste, you as a producer must be affiliated with a suitable collection scheme. A collection scheme is suitable if it is easily accessible, makes it easier for those who have packaging waste to leave it and provides good service to those who must leave the packaging waste.

As of November 1st 2023, you must hire or provide an approved producer responsibility organization instead of a suitable collection scheme. Which producer responsibility organizations that have been approved by the Swedish Environmental Protection Agency will be published on the Swedish Environmental Protection Agency's website. For those of you who are already affiliated to a suitable collection scheme, this means that you need to check whether the collection scheme has been approved as a producer responsibility organization by the Swedish Environmental Protection Agency. If not, you need to hire an approved producer responsibility organization.

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.

Recycling system for plastic bottles and metal cans (only in swedish)

Register

As a producer of packaging, you must be registered with the Swedish Environmental Protection Agency before you provide packaging on the Swedish market. You who are affiliated to a suitable collection scheme (approved producer responsibility organization from November 1st) can look at the possibility to register with the Swedish Environmental Protection Agency through the collection scheme. However, it is still your responsibility as a producer that the registration has been made.

It is also possible to register on your own in the Swedish Environmental Protection Agency’s e-service. You can also get a certification that you are registered as a producer.

If a producer of packaging does not register the Swedish Environmental Protection Agency can, for example, decide on an injunction directed against the producer. An injunction can be combined with a fine.

When making a registration you must provide the following information to the Swedish Environmental Protection Agency:

  • The name of the producer 
  • Contact details 
  • Personal or corporate identification number (if such does not exist – tax registration number or VAT-number)Which collection scheme you are affiliated to (as of November 1st, which approved producer responsibility organization you have hired). If the Swedish Environmental Protection Agency has decided on an exemption according to Chapter 4 2 §, you provide that instead.

On which basis you are a producer according to the definition in Chapter 1 6 § Ordinance (2022:1274) on producer responsibility for packaging. That is, if you professionally:

  • fills or otherwise uses packaging (that is not a service packaging) for the purpose of protecting, presenting or facilitating the handling of an item 
  • brings a packaged product to Sweden.
  • manufactures packaging in Sweden
  • brings packaging to Sweden
  • sells packaging or a packaged product to an end user in Sweden from another country

If you as a producer of packaging are established in Sweden and sell packaging to another country in the European Economic Area (EEA) where your company is not established, you must appoint a producer representative in that country. The representative shall be responsible for your obligations in that country.

If you are not established in Sweden, you can get a producer representative who is established in Sweden. If a representative is not appointed, you are responsible for your obligations in Sweden. If you choose to appoint a representative, it must be done through a written power of attorney. The presentative must then be responsible for your obligations according to the Ordinance (2022:1274) on producer responsibility for packaging and the Ordinance (2021:1002) on littering fees.

The representative in Sweden must register with the Swedish Environmental Protection Agency. You who intend to register as a producer representative must then send an e-mail to the Swedish Environmental Protection Agency, kundtjanst@naturvardsverket.se, with the following information:

  • The name of the producer representative, contact details and personal or organization number, or if such does not exist – tax registration number
  • A copy of the power of attorney
  • The producer’s name, contact details and tax registration number
  • Information about which product you, as a producer representative, will be responsible for

Then you log into the Swedish Environmental Protection Agency's e-service and add yourself as contact person for the producer you are a representative for.

Report

Every year, a producer must submit a report to the Swedish Environmental Protection Agency if the producer 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
  • sold packaging or a packed product to an end user in Sweden from another country, or
  • manufactured a single-use sup in Sweden or brought a single-use cup to Sweden

You who are affiliated to a collection scheme (approved producer responsibility organization from November 1st) can look at the possibility to report to the Swedish Environmental Protection Agency through the collection scheme. The collection scheme then hands over the information you submitted to them.

However, it is still your responsibility as a producer, that the information is correct and submitted on time to the Swedish Environmental Protection Agency. Therefore, you need to ensure that you have done what is necessary for the collection scheme to be able to hand over the data. It is also possible to report on your own in the Swedish Environmental Protection Agency's e-service.

Below is a description of the information to be provided.

The report must contain information on the amount of packaging that the producer has provided on the Swedish market during the preceding calendar year. The data must show the quantity of the packaging that is

  1. Consumer packaging
  2. Reusable packaging
  3. Reusable consumer packaging
  4. Beverage bottles that are single-use plastic products
  5. Plastic beverage bottles and metal cans which is part of a return system

The information on quantity must be given by weight and specified in each included packaging material. The information in point 5 must also be stated in numbers.

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.

The report must contain information on

1. the number of packaging that a producer has provided on the Swedish market during the preceding calendar year which is:

a) food containers which are single-use plastic products,

b) cups that are single-use plastic products,

c) single-use plastic lids for mugs,

d) flexible wrappers,

e) plastic bottles for drinks that hold less than 0.6 liters,

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

g) thin plastic carrier bags, and

h) thick plastic carrier bags, and

2. the amount of plastic used in food containers and mugs which are single-use plastic products.

The information must show how many of the thin plastic carrier bags constitute carriers whose wall is thinner than 15 micrometres and

  1. needed for hygiene reasons, or
  2. provided as primary packaging for foods sold in bulk.

The data must be specified in each product category.

In cases where the producer has provided or placed packaging on the Swedish market that has been reported to the European Chemicals Agency's SCIP database, these must also be reported to the Swedish Environmental Protection Agency. 

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

Register a new producer or change information on already registered producer

The e-service for submitting data for annual reporting of packaging is closed. An updated version will be opened in the new e-service portal on 01/25/2023.

  • 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. 

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