👤 Who is considered a packaging “producer”?

You must register and report if you are a producer as defined in the ordinance—commonly if you professionally:

• Fill or otherwise use packaging for a product
• Bring packaged products into Sweden
• Manufacture packaging in Sweden
• Bring packaging into Sweden
• Sell packaged products/packaging directly to final users in Sweden from another country

✅ Compliance checklist (what you must do)

1) Join an approved PRO

Naturvårdsverket lists the approved PROs for packaging:

• Näringslivets Producentansvar i Sverige AB (NPA)
• TMResponsibility AB

2) Register with Naturvårdsverket (producer register)

Registration is your responsibility (often handled by a PRO as part of their service). If you do not register, Naturvårdsverket can issue an injunction (which may include a fine), and from 1 January 2024 it can impose an environmental sanction fee for late registration.

3) Report packaging data every year

Each year you must ensure Naturvårdsverket receives the required report (commonly submitted via your PRO). Reporting requirements are defined in the ordinance and further specified through regulations including NFS 2023:13.

🖥️ Registration & reporting portal (e-service)

Naturvårdsverket’s producer responsibility e-service allows companies to:

• register as a producer
• submit reports
• update company details (e.g., invoice/contact data)
• download a registration certificate
• view previously reported data

📊 What must be reported for packaging (practical summary)

Packaging placed on the Swedish market (previous calendar year)

You must report the amount of packaging placed on the market in Sweden during the previous calendar year:

• by weight per packaging material (e.g., plastic, wood, aluminium)
• and show amounts of consumer packaging, reusable packaging, and reusable consumer packaging
• plus certain beverage-related packaging (including return system items that must also be reported in numbers)

Single-use plastic packaging (unit counts + plastic content details)

Your report must include unit counts for specific single-use plastic packaging categories (e.g., certain food containers, cups, lids, flexible wrappers, small beverage containers, thin/thick plastic carrier bags) and additional detail on plastic used in certain categories.

Composite / multi-material packaging (the 5% rule + exceptions)

Composite packaging is calculated and reported per material. An “insignificant part” (never more than 5% of total mass) may be allocated to the dominant material—except for specific single-use plastic categories, which must always be calculated and reported separately.

Packaging linked to SCIP (hazardous substances information)

If packaging placed on the market has relevant substance information submitted to ECHA’s SCIP database, you must provide information about that packaging to Naturvårdsverket.

🧾 Data & traceability: what you should have ready

To keep reporting accurate and defensible, a strong operating model includes:

• SKU-level packaging BOMs (material + weight, including composite splits)
• Change control (version history for supplier/material changes and lightweighting)
• Clear market logic (what counts as “placed on the Swedish market”)
• Evidence pack (source files, calculations, approvals, and submission confirmations)

This reduces rework, improves consistency across years, and supports audits and PRO coordination.

🗓️ Operational context (why it matters)

Sweden’s system assigns municipalities operational responsibility for collecting household packaging waste from 1 January 2024, and requires door-to-door collection nationwide by 1 January 2027 (by material streams such as paper, plastic, metal, and glass).

🧩 What this service includes (registration, reporting, traceability)

🧭 1) Obligation scoping

• Confirm producer role(s) and packaging scope
• Identify packaging flows and categories that drive reporting requirements

📝 2) Registration support (producer register readiness)

• Prepare the registration dataset (company ID/VAT where relevant, contacts, PRO details, producer basis)
• Maintain controlled updates so register details remain accurate

📈 3) Reporting-ready packaging dataset

• Material-weight reporting structure aligned to Naturvårdsverket requirements
• Single-use plastic category mapping and unit counts
• Composite packaging material splits and 5% rule handling (with correct exceptions)

🔎 4) Audit-ready traceability

• Calculation logic documentation and approval workflows
• Evidence storage aligned to reporting lines and submissions
• Year-over-year consistency checks

⭐ Why ComplyMarket

ComplyMarket provides Sweden Packaging EPR support through its Compliance Management Software and integrated EPR platform, helping companies manage registration, annual reporting, and traceability in one controlled workflow:

• Registration support: producer-role mapping and register-ready information aligned to Naturvårdsverket requirements
• Reporting control: structured packaging datasets for material weights, reusable/consumer splits, single-use plastic unit counts, and composite packaging rules
• End-to-end traceability: audit trails, evidence retention, version control, and approvals to keep submissions defensible year after year