Consulation responses
Consultation response: model for environmental sanctions can be used against free-riding
Näringslivets Producentansvar welcomes the Government's proposal for fixed and variable environmental sanctions and wants the new approach to be used to tackle free-riding within producer responsibility for packaging.
Free-riding, that is, packaging placed on the market without being reported to a producer responsibility organisation, is a serious problem. According to the Swedish Environmental Protection Agency, non-registered producers account for around 40 per cent of plastic packaging on the Swedish market, corresponding to lost fees of approximately SEK 600 million per year.
Today, the cost of not being affiliated with a producer responsibility organisation is SEK 30,000, which is not a sufficient deterrent. The sanction is also neither proportionate nor effective enough. It does not take into account whether the producer is a microenterprise or a large company. It does not take into account whether the producer places one package on the market or a million.
However, such considerations could become possible with the Government’s proposal for a new system with both fixed and variable environmental sanctions. Under the proposal, variable charges are to be set with regard to, among other things, the company’s turnover and the nature and extent of the infringement. This enables a proportionate sanction.
In the Government’s proposal, the new variable charges are applied in areas such as greenhouse gases and ecodesign. Näringslivets Producentansvar urges the Government to do the same for producer responsibility for packaging.
We propose that the same approach that the memorandum uses for ecodesign is also used for packaging:
- Two levels of fixed charge for late submission of data to the Swedish Environmental Protection Agency, where the charge for medium-sized and large companies should be twice as high as for small companies.
- A variable charge for free-riding enables the supervisory authority to take into account both the company’s turnover and the seriousness of the infringement.
- Most producers affiliated with Näringslivets Producentansvar pay packaging fees of less than SEK 30,000 per year. They account for a very small share of the packaging. More than 100 producers pay over SEK 5 million per year. The range of amounts must therefore be wide for the supervisory authority to have an effective tool against all types of infringement.
These are changes that should be possible to make already now, in connection with the decision on environmental penalty charges. Otherwise, the matter should be investigated without delay.
More Consulation responses
Consultation response on revised compensation regulations
Näringslivets Producentansvar has submitted comments on the Swedish Environmental Protection Agency’s proposal for revised compensation to municipalities for the collection of packaging waste. NPA is calling for more accurately targeted compensation for transfer stations and for the breakdown by material type to be retained for kerbside collection.
Consultation response: How Swedish alignment with the PPWR can improve recycling
Näringslivets Producentansvar has submitted proposals to the Government Offices to improve quality, increase collection rates and ensure that more producers take responsibility for packaging waste.
Consultation response to memorandum on reforming waste legislation
The memorandum “Reform of waste legislation for increased material recycling and for a more circular economy” contains proposals for a reformed and modernized waste legislation with the aim of preventing waste and increasing material recycling so that Sweden can achieve the goals set by the EU in this area. The proposed amendments to the constitution will enter into force on 1 January 2026. Näringslivets Producentansvar is one of many consultation bodies and we have now submitted our consultation response.