Terms of engagement
These terms govern our services unless we have agreed something different with you in writing.
1. Who we are
PPWR Sweden is a business name of Ascendance AB, a Swedish limited company with registration number 559584-9364, registered office in Stockholm. We provide legal and compliance services.
2. When these terms apply
These terms apply to every engagement we accept, from the moment we confirm it in writing. A signed engagement letter prevails over them where they conflict. For recurring services we will give at least 30 days' written notice of a change to these terms, and you may terminate before it takes effect.
3. Scope of our services
Our scope is what we confirm in writing when accepting the engagement. The following are outside scope unless expressly agreed:
- Laboratory testing, recyclability certification and recycled content verification
- Packaging design, engineering and supplier sourcing
- Obligations in EU member states other than Sweden
- Tax advice, customs classification and product safety outside packaging
- Representation in court, arbitration or enforcement proceedings
Our advice addresses the facts you give us at the time it is given. The PPWR is being supplemented by delegated and implementing acts and by Swedish national rules, and assessments made under the current state of the law may change as those are adopted. We do not undertake to update advice unless you engage us to monitor it.
4. Accepting an engagement and client due diligence
Before accepting any engagement we carry out client due diligence, including identification and verification of you, your ownership structure and your beneficial owners, with ongoing monitoring during the engagement. We may decline, suspend or terminate where we cannot complete it to our satisfaction, and are not required to give reasons. We also check for conflicts of interest.
5. Fees
Fixed fees are published on our fees page and apply to the scope described there. Work outside that scope is agreed with you before it is carried out. All fees are stated in SEK and exclusive of VAT; for business customers outside Sweden, VAT is generally accounted for by the customer under the reverse charge mechanism.
Currency. SEK is the currency of the engagement. We can invoice in EUR, GBP or USD on request, converted at the exchange rate applicable on the date of invoice. You bear conversion costs and exchange rate movement.
Third-party costs. Authority fees, producer responsibility organisation fees, EPR fees and testing costs are payable by you and are not included in our fees. Disbursements we incur on your behalf are payable in advance whatever the amount.
We review fees annually. For recurring services a change takes effect at the next renewal, on at least 30 days' notice.
6. Payment
Invoices are payable within 30 days. We may require payment in advance for one-off services and for the first period of a recurring service. Late payment carries interest under the Swedish Interest Act (räntelagen 1975:635). If an invoice is unpaid 14 days after its due date we may suspend work and resign from any representative appointment under clause 8.
7. Your responsibilities
We rely on the information you give us, including packaging specifications, material data and volume figures. You are responsible for its completeness, accuracy and timeliness. We do not independently verify it, and we are not liable for the consequences of reporting, registering or advising on the basis of data that proves incorrect.
You must keep your contact details current and tell us promptly when your products, volumes, sales channels or corporate structure change, since each can alter your obligations.
8. Representative appointments
8.1 Scope of our authority
Where we act as your authorised representative for extended producer responsibility under Article 45 of Regulation (EU) 2025/40, our authority is limited to the tasks set out in the written mandate: registration, reporting, payment administration and acting as contact point for Swedish authorities. It does not authorise us to bind you commercially, accept liability on your behalf, or act in any other capacity.
The appointment covers Sweden only. It does not discharge obligations in any other member state, and it does not transfer your product conformity obligations, which remain with you.
8.2 Term, renewal and termination
Appointments run for twelve months and renew automatically unless either party gives written notice at least one month before the start of the next contract year. Fees are payable annually in advance and are not refundable on early termination.
We may resign on one month's written notice, and with immediate effect where clause 4 or 6 applies. You are responsible for appointing a replacement before our appointment ends. You authorise us, and undertake to take any step we reasonably request to allow us, to deregister our appointment with Naturvårdsverket on or after the termination date. Where you have not done so, we may deregister ourselves.
8.3 Indemnity
Acting as your representative exposes us to obligations towards Swedish authorities. You will indemnify us against any claim, penalty, fine, fee, cost or liability we incur as a result of the appointment, including any arising from data you provided, except to the extent it results from our own gross negligence or wilful misconduct. This clause survives termination.
9. Limitation of liability
We are liable for damage caused by our negligent breach of these terms. Our total liability is limited to the aggregate fees you have paid us in the twelve months preceding the event giving rise to the claim.
We are not liable for indirect or consequential loss, loss of profit, business or goodwill, for loss arising from information you gave us that was incorrect or incomplete, for EPR fees or authority charges properly payable by you, or for the consequences of changes in law or in delegated or implementing acts adopted after our advice was given.
Nothing limits liability that cannot be limited under Swedish law, including for gross negligence or wilful misconduct. A claim must be notified in writing without undue delay and in any event within twelve months of completion of the engagement concerned.
We maintain professional indemnity insurance. Details of the cover are available on request.
10. Confidentiality
We keep information about you and your matters confidential, except with your consent, where disclosure is necessary to carry out the engagement, or where required by law, including under anti-money-laundering legislation, which may prohibit us from telling you that a disclosure has been made.
11. Data protection
We process personal data as described in our privacy notice.
12. Retention of records
We retain engagement records for the period required by law, and at least five years after the end of the engagement where anti-money-laundering legislation applies. Where we have prepared or held conformity documentation on your behalf, we retain our file for five years, but you remain responsible for retaining the documentation itself for the periods the regulation requires.
13. Intellectual property
We retain copyright and other intellectual property rights in documents and materials we produce. You receive a right to use them for the purpose for which they were provided.
14. Termination
You may terminate an engagement at any time on written notice. We may terminate for non-payment, failure to provide information we reasonably require, conflict of interest, inability to complete client due diligence, or breakdown of the relationship of trust. Clause 8.2 governs representative appointments. Fees and disbursements up to termination remain payable.
15. Complaints
Contact us first. We acknowledge complaints within five working days and respond substantively within 10 working days.
16. Governing law and disputes
Swedish law governs these terms and any engagement, excluding its conflict of law rules. Disputes are settled by the Swedish courts, with Stockholms tingsrätt as first instance.