All About Sweden's EPR: Your Complete Guide!

Swedish EPR Regulations

In line with many other markets, Sweden has introduced several schemes relating to Extended Producer Responsibility (EPR). EPR schemes are designed to ensure that ‘producers’ are responsible for the entire life-cycle of their products.
Within the EU, the various Directives on EPR mean that many Member States will have already implemented or plan to implement schemes to target specific areas of trading. In Sweden, we will cover some common areas EPR schemes have been implemented in:

• Packaging
• Batteries
• WEEE

Packaging

The sale of packaging and packaged goods is covered by the Ordinance (SFS2022:1274) on producer responsibility for packaging.
‘Packaging’ covers materials that are:

• Used to cover and/or protect goods
• Filled at the point of sale
• Deliver, transport or handle products

A wide variety of packaging materials are covered, including plastics, wood, aluminium, steel, glass, paper/cardboard and fibre.

Do I need to apply?

The following parties will need to apply for packaging EPR:

• Manufacturers – manufacturers of any packaging in Sweden
• Importers – importing packaged goods/packaging into Sweden
• Retailers – selling packaged goods/packaging in Sweden
• International distributors – selling packaged goods/packaging (including distance sales) in Sweden

What are my responsibilities?

Businesses that are covered by the Ordinance must:

• Appoint an approved Producer Responsibility Organisation (PRO)
• Register with the Swedish Environmental Protection Agency (EPA) for an EPR number
• Submit timely reports to the EPA
• Pay an annual enforcement fee to the EPA

Reporting can be completed on a monthly, quarterly or annual basis depending on the packaging usage for the previous year.
As of 2023, online marketplaces are introducing EPR verification measures to ensure businesses trading in Sweden are compliant.
From the 1st January 2024, the EPA can impose sanctions for late registration.

Contribution fees

Businesses that have registered for Packaging EPR will need to pay at least contribution fee:

• EPA: annual enforcement fee, applicable if supplying > 1 ton of packaging or selling single-use products
  • 2023: SEK 1250 per annum
• PRO: contribution fee, based on EPR reporting
  • Minimum fee of SEK 1000

Batteries:

The sale of goods containing batteries is covered by the Ordinance (2014:1075) on producer responsibility for batteries.
There are several types of batteries covered under the Ordinance:

• Portable
• Industrial
• Vehicle and other automotive

Do I need to apply?

The following parties will need to apply for Batteries EPR: 

• Manufacturers/producers – domestic producers selling in Sweden
• Importers – importing products into Sweden to sell
• Retailers – selling products in Sweden, including those produced abroad
• Distributors – selling products to stores in Sweden
• International distributors – making sales to other businesses in Sweden

What are my responsibilities?

Businesses are categorised as either a ‘small’ or ‘large’ producer for the purposes of registration:

Contribution fees

The contribution fees due will differ depending on whether your business is categorised as a small or large producer.

Small producers:

• EPA: annual fee
  • SEK 1250 per annum
• Batteries contribution: based on sales
  • No minimum fee

Large producers:

• EPA: annual fee
  • SEK 1250 per annum
• PRO: batteries contribution, based on sales

Minimum fee of SEK 2000 per annum

WEEE:

Waste Electrical and Electronical Equipment is an EU-wide EPR category.  Sweden implemented the EU WEEE Directive by the Ordinance (2022:1276) on producer responsibility for electrical and electronic equipment.

The scope of products covered under WEEE follows the EU-wide definitions:

• Temperature exchange equipment
• Screens, monitors or equipment containing screens with surface area > 100cm²
• Lamps
• Large equipment
• Small equipment
• Small IT and telecommunication equipment

In addition, the Ordinance defines WEEE as:

• Equipment relying on electric currents/electromagnetic fields to function
• Equipment for generating/transferring/measuring electric currents/fields
• Where the equipment voltage does not exceed 1000V (AC) or 1500 (DC)

Do I need to apply?

The following parties will need to apply for WEEE EPR: 

• Manufacturers/producers – domestic producers selling in Sweden
• Importers – importing WEEE into Sweden to sell
• Retailers – selling WEEE in Sweden, including those produced abroad
• Distributors – selling WEEE to stores in Sweden
• International distributors – making sales to other businesses in Sweden

What are my responsibilities?

Businesses that are covered by the Ordinance must:

• Appoint an approved Producer Responsibility Organisation (PRO) – the responsible organisation is Recipo
• Register with the Swedish Environmental Protection Agency (EPA) for an EPR number
• Submit timely reports to the EPA
• Pay an annual enforcement fee to the EPA

Reporting can be completed on a monthly or quarterly basis, subject to the requirements of the nominated PRO. 

Contribution fees

Businesses that have registered for WEEE will need to pay two separate contribution fees:

• EPA: annual enforcement fee
  • Minimum fee of SEK 1250 per annum
• PRO: contribution fee, based on EPR reporting
  • Minimum fee of SEK 2000 per annum

Not sure where or how to start with Sweden EPR? TBA Global can assist you in navigating the requirements to ensure your business remains compliant. You can reach out to us via email at info@tbaglobal.com or WhatsApp for a free one-to-one consultation.