Producer responsibility for packaging

The definition of a producer is set out in Article 3.1.15 of the PPWR.

In general terms, the producer is any manufacturer, importer or distributor that, irrespective of the selling technique used, including by means of distance contracts, first places packaging or a packaged product on the Swedish market. This may be done either for a fee or free of charge.

If no other party is the producer, the producer is the manufacturer, importer or distributor who unpacks packaged products without being the end user.

With the introduction of the PPWR, the assessment of who is the producer has changed from previous Swedish practice, and the assessment has also been made dependent on, amongst other things, the type of packaging in question and under whose name or trade mark the packaging is manufactured. The examples below are intended to provide NPA’s customers with general guidance but are not exhaustive and are not legally binding. In the event of any conflict between the examples and the PPWR, the PPWR shall prevail. Each operator is responsible for determining, on the basis of the provisions of the PPWR, whether they have producer responsibility.

Read the Swedish Environmental Protection Agency’s guidance (in Swedish)

Producer responsibility is a statutory obligation. Producer responsibility is based on the Polluter Pays Principle (PPP). If your company introduces packaging to the Swedish market, you, as the producer, have a legal and financial responsibility for the collection and recycling of the packaging. Producer responsibility is the foundation of the collection and recycling system for packaging in Sweden.

The basic idea behind producer responsibility is to reduce the amount of waste, but also to ensure that any waste that is generated is recycled and used to make new products.

A foreign company that sells to a recipient in Sweden who is the end user of the product, has producer responsibility and must report the packaging and pay the packaging fee. This can be, for example, input goods in production or e-commerce aimed at consumers. This does not apply to products that are resold.

If your company puts packaging on the Swedish market, by law, you are an obligated packaging producer and have a financial responsibility to ensure that the packaging is collected and recycled. All producers must be affiliated to an approved producer responsibility organization and through it finance the collection, reception and recycling of all types of material. Näringslivets Producentansvar is an approved producer responsibility organization and through us you take your producer responsibility for packaging.