Consultation response on littering fees and regulations that determine the size of the product fee

Littering fees must be paid by producers who provide the following packaging on the Swedish market:

1. Disposable plastic lids for mugs
2. Flexible covers
3. Lunch boxes that are disposable plastic products
4. Mugs that are single-use plastic products
5. Plastic bottles for drinks that hold less than 0.6 litres
6. Beverage containers other than plastic bottles for beverages that hold less than 0.6 liters
7. Thin plastic carrier bags

NPA has now sent in its referral responses for the Swedish Environmental Protection Agency’s request for changes to the ordinance on littering fees and for the Swedish Environmental Protection Agency’s referral of regulations that determine the size of the product fee.

NPA’s views in brief

• It is welcome with a clarification of which producers must pay littering fees and that responsibility rests with those who are obliged to report according to the packaging regulation.
• The NPA appreciates that the Swedish Environmental Protection Agency drew attention to the fact that the wording ”release on the Swedish market” risks leading to littering fees being paid by more than one producer and acted to avoid it, by changing it to ”provide on the Swedish market”. The change is also necessary to be able to invoice affected producers at all.
• NPA believes that it is a fundamental problem that there is a lack of accepted and proven definitions of when cleaning efforts must be carried out and when these efforts are to be considered complete.
• We are positive that the compensation to the municipalities is changed, from standard-based to being based on determined costs from the Swedish Environmental Protection Agency, and believe that this solution better contributes to fulfilling the purpose of the littering regulation.
• We would like to emphasize the importance of the Swedish Environmental Protection Agency announcing with good foresight when the littering fee will be invoiced and the level of the product fee, so that the producers are given the opportunity to implement these additional costs.
• In order to determine the cost of the different single-use plastic categories, litter measurements must be carried out by the respective municipality. Here we believe that there are shortcomings that need to be addressed, regarding the number of litter measurements and significant uncertainties in the litter measurement method.
• The costs of littering must be borne by SUP-producers. Here, however, there is a large number of companies that are not connected to a PRO and therefore do not report SUP either. Here we want to once again highlight the need for the Swedish Environmental Protection Agency to supervise producers, in order to ensure a fair distribution of the municipalities’ costs.

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Read both referral responses in full (in Swedish only):

Referral response: The Swedish Environmental Protection Agency’s referral of regulations that determine the size of the product fee

Referral response: The Swedish Environmental Protection Agency’s petition for changes to the ordinance on littering fees