The PPWR applies from 12 August 2026. Some of the provisions will not take effect until the following years. Below, we outline some of the key requirements and changes.

From 12 August 2026:

• New definition of producers

Introduced on 12 August 2028:

• Labelling requirements for packaging

Introduced in 2030

• New classification of material recyclability – class A-C. Packaging with less than 70% recycling rate will be banned. As a producer, you already need to familiarize yourself with which packaging is at risk of being banned in 2030.
• Minimum standards for packaging dimensions and empty spaces in packaging
• Requirements for the percentage of recycled content in plastic packaging
• Targets for reuse
• Targets for refilling refillable packaging

Introduced in 2035

• Assessment of recyclability based on packaging large-scale recyclability

Introduced in 2038

• Ban on packaging with class C recyclability

Introduced in 2040

• Increased requirements for recycled content in packaging
• Increased recycling targets

Further information can be found in the document ‘A brief introduction to the PPWR’, which is available to you as a customer. You are also welcome to contact us for advice.

The PPWR is a comprehensive set of regulations with many requirements, some of which we already fulfil in Sweden, for example through a widespread return and deposit system. The new requirements added by PPWR are mainly requirements for the recyclability of packaging through design for recycling, minimization of packaging material, recycled material in packaging, labelling, re-use and refilling of packaging and environmental claims on packaging. Furthermore, the Regulation contains some explicit prohibitions.

Packaging can only be placed on the market if it fulfils the requirements set out in the Regulation.

Further information can be found in the document ‘A brief introduction to the PPWR’, which is available to you as a customer. You are also welcome to contact us for advice.

The PPWR applies to all packaging and packaging waste, regardless of the material used and regardless of whether the packaging waste has been used in or comes from, for example, industry, other manufacturing, households, or retail.

All companies that place packaging on the EU market – whether they are manufacturers, importers, or distributors – are covered by the regulations. This also applies to e-commerce businesses and brand owners.

The Regulation contains a new definition of producers. As a general rule, the producer is the economic operator who, as a manufacturer, importer or distributor established in a Member State, makes packaging or packaged products available for the first time from the territory of that Member State and on the same territory. The aim of the new producer definition is that only one company should be the producer for a single packaging unit.

PPWR stands for Packaging and Packaging Waste Regulation and is a new EU regulation that replaces the previous directive on packaging and packaging waste. The aim of the PPWR is to establish a coherent regulatory framework across the EU to achieve the objectives of reducing packaging waste, increasing circularity, and promoting the internal market of EU. The PPWR requires producers to ensure that packaging is recyclable, and that waste management is efficient.

The easiest way to find out if your wood packaging is part of a market-driven system for reuse is to check the intended use with your supplier.

See the Swedish EPA:S definition of market-driven systems for reuse (in Swedish only)

Find which market-driven systems for reuse that are registered with the Swedish EPA (In Swedish only)

For handling of wood pallets and similar, there are established systems for packaging intended for multiple use, so called market-driven systems for reuse. This is where you as a producer need to be extra observant.

The concept of market-driven systems for reuse was introduced in the new ordinance that was decided on by the Swedish government in 2022. It refers to systems that can ensure that a packaging makes several rotations during its life cycle and that it can be recycled when it becomes waste. These systems must also be registered with the Swedish Environmental Protection Agency.

These kinds of rotation systems are common for pallets, where the packaging is reused until its fully consumed. There are also pallets that are made for single-use, for this reason it’s important that you know which type of pallet you’re using in order for the report to be correct.

Just like with any other packaging, you first need to determine whether your packaging should be reported as private use or other than private use. Wood boxes for cheese or wine and such, is reported as 7110 – Wood packaging single-use, private use.

Wood pallets that are part of a market-driven system for reuse is only reported the first time they are put on the market, as 7215 – Wood packaging in systems for reuse, other than private use. It is only wood packaging that are intended for reuse that should be reported as wood packaging in systems for reuse. This regards most often wood pallets, cable drums and such, and they are only reported the first time they are put on the market.

What counts as packaging is governed by the ordinance on producer responsibility for packaging. A packaging is defined as a single-use article or other product that has been produced to:

• contain,
• protect,
• present,
• deliver or in other way handle a product.

Examples of usual wood packaging are boxes for cheese or wine, pallets and cable drums.

The owners of Näringslivets Producentansvar are the five industry organisations DLF Sweden, Swedish Food Retailers Federation, Swedish Trade Federation, the Swedish Brewers Association and the Spirit and Wine Suppliers Association.

Näringslivets Producentansvar do not distribute any profits – our focus is that you as a customer should receive as much as possible for your packaging fee.

Näringslivets Producentansvar is a producer responsibility organisation that helps you as a producer of packaging to take your producer responsibility.

A foreign company that sells to a recipient in Sweden who is the end user of the product, has producer responsibility and must report the packaging and pay the packaging fee. This can be, for example, input goods in production or e-commerce aimed at consumers. This does not apply to products that are resold.

Every company must report the packaging for which it is the producer according to article 3.1.15 in the PPWR.

Packaging means an item that is intended to be used by an economic operator for the containment, protection, handling, delivery or presentation of products to another economic operator or to an end user, and that can be differentiated by packaging format based on its function, material and design. The definition of packaging is set out in Article 3.1.1 of the PPWR.

In the ordinace on producer responsibility for packaging, Chapter 8, Section 2, the following definition serves as the basis for reporting packaging for private use:

“In this chapter, packaging intended for private use refers to packaging normally used by private individuals or intended for use by both private individuals and businesses.”

An example of packaging considered intended for private use is a one-liter milk carton. Whether the milk carton is purchased and used by employees at a company or used by private individuals, it is considered packaging intended for private use. However, a larger milk carton (e.g., 10 liters) is not considered packaging intended for private use. This is because it is assumed to be intended for use by a business (e.g., in large kitchens or other restaurant operations) and not by private individuals.

Producer responsibility is a statutory obligation. Producer responsibility is based on the Polluter Pays Principle (PPP). If your company introduces packaging to the Swedish market, you, as the producer, have a legal and financial responsibility for the collection and recycling of the packaging. Producer responsibility is the foundation of the collection and recycling system for packaging in Sweden.

The basic idea behind producer responsibility is to reduce the amount of waste, but also to ensure that any waste that is generated is recycled and used to make new products.

 

The definition of a producer is set out in Article 3.1.15 of the PPWR.

In general terms, the producer is any manufacturer, importer or distributor that, irrespective of the selling technique used, including by means of distance contracts, first places packaging or a packaged product on the Swedish market. This may be done either for a fee or free of charge.

If no other party is the producer, the producer is the manufacturer, importer or distributor who unpacks packaged products without being the end user.

With the introduction of the PPWR, the assessment of who is the producer has changed from previous Swedish practice, and the assessment has also been made dependent on, amongst other things, the type of packaging in question and under whose name or trade mark the packaging is manufactured. The examples below are intended to provide NPA’s customers with general guidance but are not exhaustive and are not legally binding. In the event of any conflict between the examples and the PPWR, the PPWR shall prevail. Each operator is responsible for determining, on the basis of the provisions of the PPWR, whether they have producer responsibility.

Read the Swedish Environmental Protection Agency’s guidance (in Swedish)

The fees are based on the packaging’s net cost for collection and processing. The fees are used to reimburse the municipalities for their costs for the collection of packaging waste from households and co-located businesses that have chosen municipal collection, as well as for the municipality’s information efforts in accordance with the packaging regulation. The principle is that each type of material should bear its own costs, with no cross-subsidization between the categories. All types of materials are handled on a competitive-neutral basis. Näringslivets Producentansvar does not distribute any profit to its owners – what you pay is used to increase recycling in Sweden.

Clear labels on packaging make it easier for consumers to sort packaging for recycling. By using the Swedish Waste Management’s labeling system, it becomes easy to source-separate the packaging because the same symbols are found at the municipality’s recycling stations, recycling centers and in recycling rooms. Incorrectly sorted waste compromises the quality of the material, which could mean that the facility won’t accept it and it will have to be incinerated instead of recycled.