Consultation response: How Swedish alignment with the PPWR can improve recycling

The final phase is now under way to align Swedish legislation with the EU Packaging and Packaging Waste Regulation (PPWR), which will start to apply on 12 August this year. In our consultation response to the Swedish Environmental Protection Agency’s interim report on implementation in this area, NPA puts forward several proposals.

Improving quality

• Up to one third of the packaging waste that municipalities hand over to producer responsibility organisations consists of residual waste and moisture. The quality of the material needs to improve in order to increase recycling. We propose that clear quality criteria should be developed.
• We also propose that municipalities should compensate producer responsibility organisations for waste handed over that is not packaging waste. This ensures that the correct actor bears the costs and provides both municipalities and households with incentives to work towards better source separation.

Extended responsibility must be introduced at the right pace

We do not believe there are sufficient grounds to abolish the market-driven collection of packaging from businesses, as proposed by the Swedish Environmental Protection Agency. If the government nevertheless decides to do so, more time is required. Establishing an entirely new system requires significant effort, and the change should therefore take place no earlier than the turn of the year.

We also reject the proposal to increase packaging fees so that two per cent is allocated to waste prevention measures. Setting such a high proportion of the packaging fees goes beyond what the PPWR requires. We propose a lower level to ensure that the system can operate efficiently. This change should also take place no earlier than the turn of the year.

Put an end to free-riding

• The government now has an opportunity to increase penalty charges for free-riders, i.e. producers who do not comply with their producer responsibility obligations. Everyone must contribute and pay their share, and failing to take responsibility should be costly. At present, the charge is significant for small companies but not for large ones. This is not a fair system. We propose that the penalty charge should be increased and linked to the company’s turnover.

Clarify the rules

• Several of the proposals circulated for consultation need to be clarified in order to be applicable in practice. One example is what is meant by “packaging which, due to its hazardous properties, must be sorted as hazardous waste when it becomes waste”. If this is not defined, there is a risk that producers will interpret it differently.
• It should also be clarified what is meant by “environmentally justified” and “technically feasible” in relation to high-quality material circulation.

Do not go beyond the PPWR

• With regard to takeaway food, Sweden should follow Article 33 of the EU Packaging Regulation, so that the obligation to offer reusable alternatives for takeaway food applies only to the HORECA sector, and that an exemption for micro-enterprises is applied. The Swedish Environmental Protection Agency’s proposal would go beyond the requirements of the PPWR.

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Read more

Read NPA’s consultation response (in Swedish only)

Read more about the consultation on the Government Offices’ website (in Swedish only)