Sweden – Lovat Compliance

Extended producer responsibility for packaging in Sweden

Since January 1, 2023, Sweden has established strict new rules for packaging manufacturers and distributors aimed at improving recycling and preventing waste. According to these rules, every manufacturer and seller is now responsible for the waste generated after the packaging is used.

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Who must register

Companies and sellers are subject to the extended product liability rules if they meet at least one of the following conditions:

They manufacture packaging within Sweden;
They import packaging into Sweden;
Import a packaged product into Sweden;
Sell a packaged product or packaging to an end-user in Sweden from a country other than Sweden.

In these situations, companies are accountable for adhering to extended producer responsibility regulations in Sweden.

Threshold

There are no specific thresholds. Companies and manufacturers that produce the goods to be packaged or the packaging itself in Sweden or import it from abroad must register.

Registration procedure

Manufacturers who want to register for the EPR packaging rules should follow the following steps

Select the required PRO company for registration;
Make sure it is registered with the Swedish Environmental Protection Agency;
Sign a contract with the company;
Submit the required waste reports to the public authority through the compliance organization;
Pay the required fees (eco-fees);
Operate successfully in the market.

Authorized representative

There is no obligation to appoint a representative.

Reporting Deadline

Depending on the quantity and price per package, the deadlines are divided into three periods: a month, a quarter, and a year. Reports must be submitted by the 25th day of the month following the reporting period. Payment for the reports must be made within 30 days of the invoice, otherwise, a percentage penalty will be charged.

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Extended producer responsibility for EEE in Sweden

According to a new decree of the Swedish government dated 30.06.2022, every company that places electronic or electrical equipment must comply with the rules of EEE regulation. Individuals or entities that introduce electrical and electronic equipment (EEE) to the market in Sweden are classified as producers and, as such, bear a producer’s duty. This obligation encompasses the responsibility to accept discarded items once have reached the end of useful life, along with managing waste electrical and electronic equipment (WEEE) and assuming financial accountability for related endeavors.

Who must register

Individuals or entities engaged in the promotion of electrical or electronic equipment within the Swedish market bear the obligation for subsequent recycling. This responsibility encompasses the following categories:

Those who are based in Sweden and engage in the manufacturing of EEE (Electrical and Electronic Equipment) or have EEE designed or manufactured, subsequently marketing it within Sweden under their own name or trademark.
Entities situated in Sweden that engage in the resale of equipment under their own name or trademark, which has been produced by other suppliers. This applies if the reseller is not considered the ‘producer,’ as defined in point 1.
Entities based in Sweden that introduce EEE from a third country or another EU Member state into the Swedish market.
Those who sell EEE through remote communication methods directly to users in an EU Member State where the seller lacks a physical establishment.

Individuals or entities meeting any of the criteria mentioned above are subject to the producer responsibility provisions outlined.

Threshold

There are no thresholds for registration. All manufacturers and companies that produce or sell electrical and electronic equipment in Sweden are subject to registration.

Registration procedure

The following steps are required to comply with all regulations regarding electronic and electrical equipment:

First, need to register with the Swedish Environmental Protection Agency (EPA).
The next step is to register with in one of two approved Swedish collective systems for EEE compliance.
Provide general information about the company and conclude relevant cooperation agreements.
Submission of waste management reports.
Paying the required contributions to the collective and state systems.
Providing evidence of compliance upon request of the government.
Labeling of manufactured products.
Developing plans to reduce and reuse products.

Authorized representative

Companies and producers that are Swedish citizens must report and pay for waste without appointing a representative. However, companies that are not Swedish residents must appoint a representative to ensure full compliance with all the necessary requirements.

Reporting Deadline

Electrical and electronic equipment reports must be submitted to the Swedish EPA by March 31. This can be done through the respective producer’s responsibility organization.