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.
NPA supports the fundamental principle of distributing compensation according to a standardised model – this creates a level playing field, provides predictability and incentivises cost-effective collection operations. It is positive that the revision did not evaluate compensation for kerbside collection, as this should only be done once the system has been fully implemented.
We broadly welcome the Swedish Environmental Protection Agency’s revised proposal on compensation to municipalities for the collection of packaging waste, but see a need for adjustments in this and future revisions of the compensation regulations.
More accurately targeted compensation for transfer stations
The fixed compensation should be differentiated according to the type of transfer station used by the municipality. Only one third of municipalities operate their own transfer stations; the remainder use other solutions with lower investment costs.
Retain differentiation for kerbside collection
The packaging fee funds the collection and recycling of each item of packaging. NPA applies the principle that each item of packaging should bear its own cost, and the allocation of costs by material type is a cornerstone of the current compensation regulations. If this differentiation is removed, it will no longer be possible to track the collection costs for each fraction, which affects both producers and producer responsibility organisations.
Compensation should incentivise results, not merely cover infrastructure costs
Future reviews of the compensation model should take into account how much material is actually collected and the quality of the collected material. Clean material streams are important for ensuring high-quality recycled material.
Read the full consultation response
More Consulation responses
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.
Consultation response on littering fees and regulations that determine the size of the product fee
Producer responsibility for packaging includes contributing to reduced littering. The littering regulation establishes the financial responsibility of the producers concerned.