SvenskaOn August 12, 2026, the EU’s Packaging Regulation (PPWR) will take effect. This regulation changes the definition of who is considered a producer. For you, this may mean a new role and new obligations.
This is changing
Currently, the person who fills a package is normally considered the producer. This applies even if the package bears someone else’s brand name. Starting August 12, however, it will be you—the person who commissions the manufacture of packaging or has your product packaged under your own name or brand—who is considered the producer. Responsibility is thus shifting from the person who fills the packaging to you, the brand owner.
Liability cannot be waived by agreement
You can agree with another party on who will report and pay the packaging fees. However, the producer responsibility itself always remains with you. You can have someone else handle the task, but they cannot assume the responsibility.
Start by reviewing your packaging workflows
Where do you source your packaging? Where does the packaging take place—in Sweden, within the EU, or outside the EU? Once you’ve mapped out your supply chains, you’ll be able to see what role you’ll play and what’s required of you. Keep in mind that reporting requirements may also change. For some, this means starting to report; for others, it means stopping. We recommend that you begin your review well in advance.
If you run a small business, you may be exempt. You are considered a micro-enterprise if you have fewer than ten employees and annual revenue of less than 2 million euros.
Would you like to know what role you’ll be assigned and what’s required? Get in touch with us, and we’ll help you figure it out.
Christian Håkansson
christian.hakansson@tmr.se