What Sweden requires
The national layer that sits on top of the regulation, and the transitional deadline unique to this market.
Registration
Producers register with Naturvårdsverket through its producer responsibility e-service. Authorised representatives register there too, and then manage their appointments through the same service. Registered producers are publicly listed, so whether a company has registered is visible to anyone who looks, including its competitors and its customers.
Producer responsibility organisations
Registration alone does not discharge your responsibility. Every producer must affiliate with an approved producer responsibility organisation, which finances the collection, reception and recycling of packaging waste and reports to Naturvårdsverket.
Sweden has two approved organisations: Näringslivets Producentansvar i Sverige AB and TMResponsibility AB. Which fits depends on your materials, volumes and route to market.
Annual reporting
Volumes are reported to Naturvårdsverket by 31 March each year. A producer may let its producer responsibility organisation carry out registration and reporting on its behalf, but the obligation remains the producer's.
The 2026 transitional year
Sweden's producer definition was replaced by the EU definition on 12 August 2026, mid-reporting year. The consequence is a split report due on 31 March 2027:
- 1 Jan to 11 Aug 2026
- Volumes reported by producers under the previous Swedish definition.
- 12 Aug to 31 Dec 2026
- Volumes reported by producers under the EU definition.
- Both due
- 31 March 2027
An entity can be responsible for one type of packaging in the first period and a different type in the second, and a company that only became a producer in August has an obligation for the later period alone. Establishing which figures belong where is the work; filing is the easy part.
The reporting regime changes again
The new reporting requirements under the regulation are expected to apply at the earliest in 2028, for reference year 2027. Until then the existing Swedish reporting content continues, with the new producer definition governing who reports it. Two moving parts at once is the reason this year is worth getting advice on rather than guessing.
National rules are still being written
Sweden has amended its packaging ordinance and related legislation to fit the regulation, and Naturvårdsverket has been instructed by the government to propose further complementary rules. More adjustments are expected. Our regulatory monitoring covers them.
Get registered properly the first time
We handle registration, affiliation and the split reporting for the transitional year together, so nothing is left half-finished.