What applies to you

Two regimes, two sets of duties

Extended producer responsibility is about waste. Who pays for collecting and recycling the packaging you put on the market. It is administered nationally, so you register in each member state separately and pay fees there. This is where the authorised representative obligation sits, under Art. 45(3).

Product requirements are about the packaging itself. What it may contain, how it must be designed, what it must say, and what documentation must exist. These follow the packaging, not the market, and they sit with the manufacturer or importer.

A producer can satisfy one and breach the other. Appointing a representative does not give you a declaration of conformity; holding a technical file does not register you for EPR.

Are you the producer?

Under the EU definition that replaced Sweden's on 12 August 2026, the producer is the party that first makes packaging available on the Swedish market. That may be a manufacturer, an importer or a distributor, and it depends on the packaging type and where the party is established.

Two patterns catch companies out. Selling directly to Swedish consumers online generally makes you the producer, even with no presence here. And for own-brand goods manufactured in Sweden by a third party, the brand owner now carries producer responsibility rather than the filler, whatever the supply agreement says about it.

The answer is often different across channels within one business. A producer assessment settles it in writing.

If you are the producer and not established in Sweden

• Appoint an authorised representative in Sweden by written mandate Art. 45(3)
• Register in the Swedish producer register with Naturvårdsverket Art. 44
• Affiliate with an approved producer responsibility organisation
• Report packaging volumes annually by 31 March
• Pay eco-modulated EPR fees, adjusted by how recyclable your packaging is Art. 47

If you place packaging on the market

• Carry out a conformity assessment and draw up an EU declaration of conformity
• Keep technical documentation, five years for single-use and ten for reusable packaging
• Respect substances-of-concern limits and the PFAS restriction in food-contact packaging
• Carry identification and contact details on the packaging
• Meet labelling requirements from August 2028 and design requirements from January 2030

Micro-enterprises

Micro-enterprises are relieved of certain obligations, including preparing technical documentation, which shifts to the EU-established supplier. There is no micro-enterprise exemption from extended producer responsibility. A small non-EU seller shipping to Sweden still needs to register and still needs a representative.

Sweden sits on top of the EU rules

The PPWR harmonises national packaging EPR frameworks; it does not replace them. Sweden's packaging ordinance has been amended to fit the regulation and further national rules are expected. Practically, that means complying with the regulation is necessary but not by itself sufficient. What Sweden requires sets out the local layer.