PPWRSweden

Regulation (EU) 2025/40 · applicable since 12 August 2026

Packaging obligations in Sweden, handled from Sweden

If you send packaged goods to Sweden and you are not established here, the PPWR requires you to appoint someone who is. We do that, and we are lawyers.

See what applies to you Deadline timeline

The suspension did not cover you

A proposal to suspend the authorised representative obligation was widely reported and left an impression that the requirement had gone away. It covered producers established in the EU. Producers established outside the EU were excluded and remain fully in scope under Art. 45(3). If you are outside the EU, you carry an obligation some of your EU competitors may not.

Three things changed on 12 August 2026

Sweden's producer definition was replaced

The EU definition now governs. Responsibility moved between parties across the whole market. For own-brand goods filled by a third party in Sweden, the brand owner now carries producer responsibility, and it cannot be contracted away.

An authorised representative became mandatory

One per member state, appointed by written mandate. There is no single-window appointment, so a seller shipping to three countries needs three representatives.

Conformity documentation became a condition of sale

Every packaging placed on the market needs a conformity assessment, an EU declaration of conformity and a technical file. There is no grace period for existing formats.

Sweden only

31 March 2027 is a Swedish deadline with no equivalent elsewhere

Because the producer definition changed mid-year, volumes must be reported for two separate periods on the same date: 1 January to 11 August 2026 under the old Swedish definition, and 12 August to 31 December 2026 under the new EU definition. For some companies those periods have different responsible parties. Working out which figures belong in which report is the part that takes time.

EPR registration and reporting

What we do

Producer assessment

Whether you are the producer for your Swedish sales, channel by channel. The question everything else depends on.

SEK 21,750

Authorised representative

We act as your Article 45 representative in Sweden, registered with Naturvårdsverket.

SEK 36,000 / year

EPR registration and reporting

Producer register, affiliation with an approved organisation, and the annual report.

From SEK 14,250

Packaging audit

Your portfolio against PFAS, recyclability, recycled content and labelling, with dates attached.

From SEK 44,250

Declaration of conformity

The technical file and declaration every packaging has needed since August 2026.

SEK 29,250

Regulatory monitoring

Around thirty delegated acts are still to come. We tell you which ones matter to you.

SEK 27,000 / year

What is coming

  1. 11 Feb 2025

    In force

  2. 12 Aug 2026

    General application

  3. 31 Mar 2027

    Sweden: transitional reporting

  4. 12 Feb 2028

    Compostability and empty space

  5. 12 Aug 2028

    Harmonised labelling

Full timeline to 2040

Start with the question that decides everything else

Whether you are the producer, on which channels, and what follows. Fixed fee, written conclusion, no obligation to continue.

Request an assessment See fees