Packaging reporting

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)

Every company must report the packaging for which it is the producer according to article 3.1.15 in the PPWR.

Packaging means an item that is intended to be used by an economic operator for the containment, protection, handling, delivery or presentation of products to another economic operator or to an end user, and that can be differentiated by packaging format based on its function, material and design. The definition of packaging is set out in Article 3.1.1 of the PPWR.

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.

In the ordinace on producer responsibility for packaging, Chapter 8, Section 2, the following definition serves as the basis for reporting packaging for private use:

“In this chapter, packaging intended for private use refers to packaging normally used by private individuals or intended for use by both private individuals and businesses.”

An example of packaging considered intended for private use is a one-liter milk carton. Whether the milk carton is purchased and used by employees at a company or used by private individuals, it is considered packaging intended for private use. However, a larger milk carton (e.g., 10 liters) is not considered packaging intended for private use. This is because it is assumed to be intended for use by a business (e.g., in large kitchens or other restaurant operations) and not by private individuals.

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.

The easiest way to find out if your wood packaging is part of a market-driven system for reuse is to check the intended use with your supplier.

See the Swedish EPA:S definition of market-driven systems for reuse (in Swedish only)

Find which market-driven systems for reuse that are registered with the Swedish EPA (In Swedish only)

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.