Registering for packaging EPR in Sweden yourself — the one country that does not make a non-EU seller appoint a representative

Does this apply to you

Since 12 August 2026 the producer definition in the EU packaging regulation replaces the older Swedish one. Naturvårdsverket sets out the definition in full, and the parts that catch a cross-border seller are the ones that say “established in a Member State or in a third country” and supplying, for the first time on another Member State's territory, transport, service or primary-production packaging — or products packaged in other packaging — directly to end users. The agency adds the sentence that closes the marketplace loophole: this applies regardless of the sales method, including through distance contracts.

What the producer then owes is stated just as plainly: “Producers must register and report the quantity of packaging they have made available on the Member State's market to the designated competent authority, which in Sweden is Naturvårdsverket.” Extended producer responsibility also means either taking the responsibility yourself or engaging a producer responsibility organisation approved by the agency to organise collection and treatment on your behalf.

One clarification the agency makes that saves arguments later: the design and labelling requirements in the regulation are aimed at manufacturers and importers, while the registration and financing duties are aimed at the producer. The same company is often both, but they are different sets of obligations, and a seller of unbranded goods bought in from a supplier is usually the producer without being the manufacturer.

The steps

Sweden's sequence is short, and step 2 is where most guides written for the whole EU get Sweden wrong.

1 · Register with Naturvårdsverket — a foreign seller gives a VAT number

Companies with producer responsibility for packaging must notify that responsibility to Naturvårdsverket. The agency notes that producer responsibility organisations often do this for their customers as a service, so check whether it is in your contract — but it also says plainly that “it is also possible to register on your own in Naturvårdsverket's e-service”, and that it is the company's responsibility to make sure it is registered.

The information required on registration is short:

• the producer's name;
• contact details;
• a personal or organisation number — and here is the sentence that matters to a foreign seller: “If you are a producer and not established in Sweden but sell directly to the final end user in Sweden, you give a VAT registration number instead.”

That is the whole identity requirement. There is no Swedish e-identity gate on registration of the kind Poland has, and no compulsory intermediary of the kind Austria has. You can also pull a certificate of registration in the producer register out of the same e-service, which is the document to keep when a marketplace asks you to prove Swedish registration.

If you do not register, the agency can issue an injunction against the company, and the injunction may be combined with a conditional financial penalty.

2 · The representative question: EU sellers must, non-EU sellers need not

Two different answers, both from Naturvårdsverket, and it is worth having both in front of you because a provider quoting you for a Swedish representative may be quoting the wrong one.

Producers established in another EU country. The agency's questions-and-answers page asks it directly — must producers in other EU countries appoint a producer representative in Sweden from 12 August 2026? — and answers: “Yes, the requirement in Article 45(3) that producers in other Member States must appoint a producer representative in Sweden applies from 12 August 2026.” The representative must be established in the country where the packaging or packaged product is first made available, is appointed by written power of attorney, and through that power of attorney takes over the producer's obligations under the regulation. Where a producer has appointed a representative in Sweden, that representative registers in Naturvårdsverket's producer register on the strength of the power of attorney and files the producer's reports — usually via an approved producer responsibility organisation, though it is equally possible to register directly by logging into the agency's e-service.

Producers established outside the EU. The agency's answer is the one quoted at the top of this page: the EU packaging regulation contains no requirement for these producers to engage a representative, and Naturvårdsverket has proposed that the same requirement should apply as for producers in other EU countries. A proposal is not a rule. Treat it as a live change to watch, not as a current obligation — and note the direction it would move in if adopted.

One more official detail worth knowing before shopping for a representative: “there is no special approval or authorisation procedure at Naturvårdsverket for becoming an authorised representative for extended producer responsibility”. Nobody is licensed for this role in Sweden. Anyone who tells you they are “the approved Swedish representative” is describing something that does not exist.

3 · Contract with one of the two approved producer responsibility organisations

Companies with producer responsibility must engage — or themselves provide — an approved producer responsibility organisation. Naturvårdsverket publishes the list, and it is short. There are two:

• Näringslivets Producentansvar i Sverige AB — organisation number 559420-2391 (npa.se)
• TMResponsibility AB — organisation number 556685-2439 (tmr.se)

Both are linked from the agency's own page, which is the check to make before you sign: an organisation that is not on that list is not approved. What the organisations do is take operational or financial responsibility for collecting and treating packaging waste, and report collection and treatment data to Naturvårdsverket. Note that they report to the agency quarterly, within a week of the end of each calendar quarter, so their internal deadlines for your data will be quarterly even though your own statutory report is annual.

4 · Report by 31 March, and pay the supervision fee

“By 31 March each year, companies with producer responsibility must report data to Naturvårdsverket.” What has to be reported is set out in chapter 11 of Ordinance (2022:1274) on producer responsibility for packaging. Most producers report through their producer responsibility organisation. The agency notes that the EU regulation will increase the level of detail required, but that those requirements apply only in a few years' time.

There are two Swedish charges that are not the packaging fee, and both are easy to miss:

• Supervision fee (tillsynsavgift) — 1,250 SEK per producer per calendar year, charged by Naturvårdsverket to run the digital register and enforce the rules. Producers that made available less than one tonne of packaging on the Swedish market do not pay it — unless they pay litter fees, in which case they pay it regardless of quantity. The legal basis is chapter 7, section 8 s of Ordinance (1998:940).
• Litter fees (nedskräpningsavgifter) — a fixed annual fee, payable since 2023, plus a variable product fee, payable since 2024, on certain single-use plastic packaging: plastic bottles, cups and food containers, and the plastic wrappers common on ice cream, sweets and snacks.

If you stop being a producer you have to deregister, and the agency requires you to have reported for both the previous and the current year first, with documentation proving it, before the deregistration goes through.

The two approved organisations

Sweden sits between the German model and the Dutch one: more than one organisation, but only two, and both approved and supervised by the environmental protection agency rather than merely licensed to compete.

The comparison points are the ordinary commercial ones, and the agency explicitly declines to do them for you — it tells producers to “check with your producer responsibility organisation what applies in your case”. Ask about: the fee per material and how they classify your packaging, the minimum term and whether it renews automatically, the notice period, whether they file your Naturvårdsverket registration and annual report as part of the service or as an extra, and their quarterly data deadlines, which are the ones you will actually live with.

One structural fact about how the fee is set, from the agency: the packaging fee must cover the costs of collecting and treating packaging waste, and when the organisation calculates it, it takes into account both the quantity you make available on the Swedish market and the recyclability of the packaging. That is why the Swedish rate table on this site has separate rows for paper and plastic that are compatible, partly compatible and not compatible with material recycling — the design of your packaging moves your bill.

Reporting: what you file and when

• To Naturvårdsverket, annually: by 31 March, the data listed in chapter 11 of Ordinance (2022:1274). Most producers file through their organisation; you can file yourself in the e-service.
• To Naturvårdsverket, on change: you have a duty to notify the agency without delay of changes to the information you gave. The agency warns that its producer register is not linked to the companies register, so a change filed at Bolagsverket does not reach it — you must tell the agency and your organisation separately.
• Your organisation → Naturvårdsverket, quarterly: within one week of the end of each calendar quarter.
• On deregistration: company name, organisation number, reason, the date you ceased to be a producer, the date you reported for the relevant year, and documentation proving you reported.

When you actually need a provider

Sweden has the smallest genuine need for a paid intermediary of the five countries in this set, and one specific fact that should change how you read any offer to take the work off your hands.

The liability does not transfer. Naturvårdsverket's position is explicit: a manufacturer or producer may engage a civil-law agent to perform tasks on its behalf, but in the agency's interpretation it is not possible to contract away either the public-law manufacturer responsibility or the producer responsibility under the EU packaging regulation. It then gives the consequence in the case that actually happens: if a civil-law agent fails to report on time, the agency considers that the environmental sanction charge should be directed at the producer, not the agent. You can buy the work; you cannot buy the risk.

• You do not need a representative if you are established outside the EU — see step 2 — and there is no approval procedure that would make one “official” if you did.
• You do need one if you are established in another EU country, from 12 August 2026, but the requirement is that they be established in Sweden and hold a written power of attorney, not that they be a compliance firm.
• You do not need a provider to register or report: the agency's e-service takes a VAT number from a foreign seller and issues a registration certificate.
• Judgement calls worth paying for: classifying packaging by recyclability, since that band moves the fee; and reconstructing tonnages for a year already traded.

We have no commercial relationship with either approved organisation or with any compliance provider, and we take no referral fees.

What it costs

Three separate charges, only one of which is the packaging fee.

• Packaging fee to your organisation — per kilogram by material and by recyclability band. Every row on this site carries its source document and the date we verified it: the recyclable paper row, the recyclable plastic row and the glass row are the three most sellers need; the full table shows what happens to the plastic rate when the packaging is only partly, or not, compatible with material recycling.
• Supervision fee to Naturvårdsverket — 1,250 SEK per producer per calendar year, waived below one tonne unless you also pay litter fees.
• Litter fees — a fixed annual fee and a variable product fee on listed single-use plastic packaging.
• Representative — a commercial fee, and one you may well not owe: nil if you are established outside the EU, on the agency's current position.

For the opposite arrangement — a country where a foreign distance seller must appoint a representative before anything else can happen — see our Austrian registration guide.