• The upcoming EU PPWR legislation will have a major impact on packaging producers. It is therefore highly desirable that the Swedish Environmental Protection Agency informs and guides producers in good time about upcoming changes, in order to prevent producers from making choices or investments that risk not meeting upcoming requirements in the PPWR. It is also of great importance that the legislation is not over-implemented in Sweden, which would work against the harmonization between the EU countries that the legislation aims for.
• The overall goal of both plan and program is a more circular and resource-efficient society. The new packaging regulation aims at the same thing, but its requirement for curbside collection for all types of material leads to unreasonably high collection costs for metal packaging, due to small collection volumes. High costs risk leading to a transition from a fully recyclable material to less recyclable/non-recyclable packaging made of paper and plastic, something we have previously pointed out.
• We wish that measures for the municipality, county board and other public administration are supplemented with measures for increased authority supervision. Supervision is an effective tool to achieve waste reduction and increased recycling, but also to promote fair competition. For example, the amount of free riders in the producer ranks contributes to greatly distorted competition in the market, something that increased authority supervision could correct.
  We believe that the plan’s and program’s level of ambition to “inspire action” is set too low in relation to the actual social challenges we face. We would like to see the seriousness also reflected in the form of more powerful formulations in both plans and programs.

Read the full referral response (in Swedish only)