Who must register for packaging EPR in Sweden, and how

Compared with the consolidated text of förordning 2022:1274 on 29 September 2026. This is general information about Regulation (EU) 2025/40 and Sweden's national EPR scheme, not legal advice. Thresholds, fees, penalty amounts and go-live dates come from national law and PRO schedules that change: treat every figure as needing a fresh check, and confirm anything you act on with the national authority or qualified counsel.

The register and what it involves

A producer must notify Naturvårdsverket (the Swedish EPA) before it first supplies packaging on the Swedish market (ch. 4 s5), and contract an approved PRO before that first supply (ch. 4 s1). The governing law is Förordning (2022:1274) om producentansvar för förpackningar (in force since 1 January 2023). Naturvårdsverket's list of approved producer responsibility organisations names Näringslivets Producentansvar (NPA) and TMResponsibility (TMR).

Both steps are needed: the notification to Naturvårdsverket and a contract with an approved PRO (which often files the Naturvårdsverket report on your behalf, with fees payable to the PRO). A business selling packaged goods from outside Sweden directly to a final user in Sweden, by distance contract, counts as a producer there.

De-minimis: none in the regulation

We found no turnover or weight exemption in förordning 2022:1274. Vendor guides quote a SEK 1,000,000 turnover exemption and weight reliefs at 500 kg and 1,000 kg a year, but none of them could be traced to the regulation. Chapter 11 s15 lets Naturvårdsverket exempt producers of certain packaging from the annual report by its own rules, so confirm any relief with Naturvårdsverket before building a plan around it.

The Authorised Representative rule

Swedish law makes a representative optional. A producer not established in Sweden may (“får”) appoint a producentombud established in Sweden, by written power of attorney. The producentombud then carries out the producer's obligations under the regulation and notifies Naturvårdsverket of its appointment (ch. 4 ss7 and 8 of förordning 2022:1274). Without one, a non-established seller deals with Naturvårdsverket and its PRO itself, and the notification accepts a tax registration number where there is no Swedish organisation number. The regulation has been amended for the PPWR and still says “får”.

The EU rule is separate. Since 12 August 2026, Article 45(3) of Regulation (EU) 2025/40 has required a producer that makes packaging available directly to end users in a member state where it is not established to appoint an authorised representative for EPR there. That catches a web shop in Finland or Germany shipping to Swedish consumers just as it catches a seller outside the EU. A supplier to Swedish retailers who resell the goods unchanged is not the producer in Sweden and is not caught. The second sentence of Article 45(3) lets a member state require a representative from non-EU producers more generally, which Sweden's “får” does not do. A proposal to suspend Article 45(3) until 2035, COM(2025) 982, is stalled: the Council ended negotiations on it in April 2026 and left it out of its 24 June 2026 mandate, and the rule applies today.

Reporting and penalties

Reporting is annual: a producer with a reporting duty under Article 44(7) or (8) of the PPWR sends Naturvårdsverket, by 31 March each year, the quantity of packaging it made available on the Swedish market in the previous calendar year, with consumer, reusable and single-use-plastic items shown separately (ch. 11 s1). Naturvårdsverket enforces through environmental sanction fees (miljösanktionsavgift) under förordning 2012:259, which apply on strict liability. Penalties for breaching the PPWR itself are for member states to set under Article 68, with national rules due by 12 February 2027. Since 1 January 2024 the municipalities have had operational responsibility for collecting household packaging waste.

How onerous is it?

Moderate. Two steps (a notification to Naturvårdsverket plus a compulsory PRO contract) and one annual report that the PRO largely prepares. A seller outside Sweden that ships to Swedish consumers also needs an authorised representative under Article 45(3), even though Swedish law on its own leaves that optional.

Frequently asked questions