The purpose of the Regulation is to establish harmonised rules across the European Union governing the design, reuse and recycling of packaging. Its objectives are to reduce the consumption of packaging materials, improve resource efficiency and minimise emissions associated with packaging and logistics.

The requirements will be implemented progressively over the coming years, with the first provisions taking effect this autumn. As Member States are permitted a degree of national implementation, certain requirements may vary between countries. In Sweden, the Swedish Environmental Protection Agency (Naturvårdsverket) is the competent supervisory authority. We recommend monitoring its guidance to remain informed of the latest regulatory developments.

The Key Points

Who is the Manufacturer?

The Manufacturer is the party that specifies the overall design of the packaging. As this party determines the packaging's weight and volume, it is also responsible for ensuring compliance with PPWR requirements.

In the vast majority of cases, you, our customer, are considered the Manufacturer under PPWR.

Who is the Supplier?

The Supplier is the party that manufactures the packaging and supplies it to the Manufacturer.

In most cases, we fulfil the role of Supplier under PPWR.

Who Holds Producer Responsibility?

Producer responsibility rests with the Manufacturer if the packaging is placed on the Swedish market.

If the packaging is exported, producer responsibility generally lies with the importer in the country where the goods are placed on the market.

If the destination is outside the EU, PPWR does not apply.

(There is currently an ongoing interpretation regarding whether producer responsibility may also apply in other EU Member States. Based on the current interpretation, however, producer responsibility applies only within Sweden.)

An exception applies if the Manufacturer places products on the Swedish market but qualifies as a small enterprise. In this case, producer responsibility transfers to us as the Supplier.

A small enterprise is defined as having:

• fewer than 10 employees, and
• annual turnover or an annual balance sheet total not exceeding EUR 2 million.

If this applies to your business, please let us know and we will assume producer responsibility.

What Does Producer Responsibility Mean?

From 12 August 2026, Manufacturers with producer responsibility must document their packaging in a new way.

This includes:

• Packaging traceability marking – This may be provided on a delivery note or another suitable information carrier.
• Technical documentation – Including product specifications, materials used, information on refurbishment, reuse and recycling, and confirmation that the packaging does not contain hazardous substances.
• EU Declaration of Conformity – Confirming that the packaging placed on the market complies with PPWR.

Reuse Systems

From 12 August 2026, there will be two recognised systems for the reuse of packaging.
These systems are already widely used throughout Sweden and will continue to operate, but they will now be classified as either closed systems or open systems.

Closed Systems
This applies to businesses operating their own reuse systems.
You are responsible for managing your system and will need to document how it operates.

Open Systems
An open system has no single owner. Instead, multiple organisations work together to collect, sort, refurbish and reuse packaging.
These systems will continue to operate as before. However, your Technical Documentation should indicate whether the packaging is suitable for multiple uses.

How We Can Help

We can provide supporting information to help you prepare the required Technical Documentation, including:

• Dimensions and weight
• Drawings (subject to availability; generic drawings are acceptable)
• Confirmation that we comply with Article 5 regarding chemical substances
• Information about the materials used
• Recyclability
• Reusability

• Refurbishability

Disclaimer

The information provided above reflects our current interpretation of PPWR and the guidance issued by the Swedish Environmental Protection Agency.

Requirements, official guidance and interpretations may change over time as the regulation is implemented.