The aim of the proposals is to increase resource efficiency, create long-term perspectives and better planning conditions for companies and municipalities and promote investments in innovative technical solutions. There are also proposals to strengthen and streamline supervision in the waste area to avoid distorted competition and increased illegal waste management.
Näringslivets Producentansvar works to contribute to Sweden reaching its material recycling targets and to ensure that the collection of household packaging is carried out in a cost-effective manner, where the requirements for the collection system are reasonable in relation to the environmental benefit achieved. For fair competition, the costs of collection must be distributed equally between PROs and between the producers who have producer responsibility for packaging.
– Among our proposals is an increased environmental sanction fee for producers who are not affiliated with a PRO. The current fee of SEK 30,000 is too low to constitute an incentive for producers to take their statutory responsibility. An increased fee in combination with active and outreach supervision from the Swedish Environmental Protection Agency should lead to a desirable development where the number of free riders at the producer level decreases, says Henrik Nilsson, Head of Business Development & Community Relations at Näringslivets Producentansvar.
The rollout of curbside collection of packaging is in full swing in Sweden’s municipalities, which is a consequence of the new packaging regulation that came into force in 2023. The memorandum contains proposals that affect how and where municipalities should collect household packaging.
– We would like to see a greater flexibility for Sweden’s municipalities when it comes to curbside collection than the memorandum suggests. Municipalities have different conditions and needs, and should be given the opportunity to adapt their collection to what is most resource- and cost-effective, while maintaining environmental benefits, says Henrik Nilsson.
The memorandum also proposes that packaging waste from secondary sorting facilities should be able to be delivered to a producer responsibility organization without cost or volume restrictions.
– We support the proposal as such but want a requirement for material quality to be introduced to ensure that as much as possible can actually go to material recycling. We also think it is reasonable to require that the material should consist of at least 90 percent packaging waste, says Henrik Nilsson.
Regarding the proposal for additional sorting of waste, Näringslivets Producentansvar sees that there are several shortcomings that need to be addressed before the proposal can be applied in practice. Among other things, we request an investigation into how the proposed regulation should be handled in practice.
Read the full consultation response here