Regulatory monitoring
Keeping track of the delegated acts, implementing acts and Swedish rules still to come, and telling you what they change.
- What it is
- Ongoing monitoring of PPWR secondary legislation and Swedish implementation.
- Why
- Around thirty delegated and implementing acts are expected. Most are not yet adopted.
- Annual fee
- SEK 27,000
The PPWR is a framework that is still being filled in. The Commission is expected to adopt roughly thirty delegated and implementing acts covering registration and reporting formats, harmonised labelling, design-for-recycling criteria, recycled content calculation and the empty space methodology. As of mid-2026 almost none had been adopted.
Sweden is adding its own layer. The national packaging ordinance has already been amended, and Naturvårdsverket has been instructed to propose further complementary rules. More national adjustments are expected.
That creates a planning problem rather than a reason to wait. The underlying deadlines do not move because the secondary legislation is late, so companies have to plan against requirements whose final form is not yet fixed, and adjust as it settles.
What the retainer covers
- Monitoring of PPWR delegated and implementing acts as they are adopted
- Monitoring of Swedish complementary legislation and Naturvårdsverket guidance
- A written note when something lands that affects your packaging, not a newsletter
- A standing line for short questions, answered without a new engagement
- An annual review of your position against the next deadline
Clients with an authorised representative appointment receive monitoring of the EPR provisions as part of that service. This retainer covers the product requirements as well.