Packaging Compliance in Sweden: Circulate’s Master Guide for e-commerce

The Legal Framework: Current & Future

Packaging for e-commerce - e.g., boxes, mailers, tape, polybags, silk paper, hangtags—is governed by a shifting landscape of Swedish and EU laws:

Swedish Ordinance SFS 2022:1274: (Active Now) The national law for Extended Producer Responsibility (EPR). It makes reporting and recycling fees mandatory for everyone placing packaging on the Swedish market.
EU PPWR (Regulation 2025/40): (Active/Phasing in) Entered into force Feb 11, 2025. It replaces old directives with binding rules on design, recyclability, and waste reduction.
Single Use Plastics Directive and Textile EPR: (Active/Expanding) Covers single-use plastics and, as of 2025, extends responsibility to textile-related items like labels, hangtags, and plastic
spare-button bags.

Who Must Comply?

If you ship to a Swedish customer, you are the one placing the packaging on the market and seen as the "Producer" of the packaging. This applies regardless of where your company is based. You are responsible for:

Product Packaging: e.g., polybags, glassine bags, shoe boxes, hangtags, labels, etc.
Shipping Packaging: e.g., mailers, boxes, tape, labels, silk paper, etc.

Threshold Note: Brands with a Swedish turnover exceeding 1 million SEK must formally register with the Swedish EPA and a compliance scheme (PRO). Below this, you are still legally liable for using compliant materials, but administrative reporting is simplified.

Implementation Guide: Now vs. Future-Proof

1. Optimization & "Shipped Air"

Active Now: You must minimize packaging weight and volume.
Future-Proof (2030): Under PPWR Article 24, the maximum void space ratio is 50%. Brands should audit box sizes now to avoid high penalties for "shipping air."

2. "Only Recyclable" (The 70% Rule)

70% recyclable 2030: All packaging must be "Designed for Recycling" (DfR) and graded A, B, or C. To stay legal (Grade C), at least 70% of the unit’s weight must be effectively recyclable.
The Risk: If your box has a heavy plastic coating or non-removable glues (>30% of total weight), it will be banned by 2030.
80% recyclable 2038: Only Grades A (95%) and B (80%) will be permitted; Grade C will be phased out.

3. Prove Actual Recycling Rate (Recycled at Scale)

Future-Proof (2035): It is no longer enough to be "recyclable on paper." You must prove your packaging is Recycled at Scale.
The Target: You must prove that at least 55% of that specific packaging type is effectively collected, sorted, and recycled across the EU through audited Conformity Assessments.
You will be required to provide audited data from your PRO (like NPA or TMR in Sweden) and digital documentation (likely a Digital Product Passport) showing that the materials you use are actually being processed by real-world recycling plants, not just sent to incinerators.

4. Material Strategy: The "No-Plastic" Move

Active Now: Sweden uses Eco-modulated fees to financially penalize fossil plastics.
Paper is Cheaper: Moving to a 100% paper-based shipment (Paper bag/box + tape + label + fill) creates a "Mono-material" unit. This qualifies for Grade A recyclability and the lowest EPR fees as it is the easiest for Swedish systems to recycle.
Remove expensive "Hidden" Plastics: You must report weight and info on every plastic component. Most brands overlook: Tape, labels, stickers, seals, bubble wrap, air pillows, plastic "kimble" strings on hangtags, plastic wrap/film

5. Mandatory Recycled Content (Plastics only)

If you cannot remove plastic (e.g., polybags), you must meet the mandatory targets:

By 2030: At least 35% recycled content for most plastic packaging
By 2040: This target rises to 65%.
Pro-tip: Switch to GRS-certified recycled content now to avoid 2030 supply shortages and price increases

6. Labelling & Sorting

Active Now: Voluntary use of Nordic Sorting Symbols is the gold standard for consumer trust
Mandatory WEEE symbols on outer packaging/boxes for electronics.
Future-Proof: The EU will introduce mandatory harmonized labels across all member states under PPWR.

7. Digital Product Passport (DPP): The Identity Card for Packaging

The EU is phasing in the Digital Product Passport to make the 2035 proof requirements possible.

What is it? A digital record (likely via QR code) that travels with your packaging. It must contain the material composition, recyclability grades, and the proof of actual recycling rates.
Future-Proof: Without a digital "link" between your packaging and its data, you will be unable to sell in the EU market. Ensure you have all supply chain data readily available

Reporting & Fees: The Data Nightmare

To stay compliant, you must join a Swedish PRO (like NPA or TMR), report material weights quarterly, and pay fees per kilo.

Manual reporting is an operational nightmare: Most brands—and even suppliers—lack exact weights for tape, labels, or recycled content percentages per SKU. Tracking these small items across thousands of orders is nearly impossible without automation.

Volumes are reported monthly or quarterly, not later than the 25th day of the month after the end of the reporting period.

Quarterly reporting
A company whose packaging fees are below SEK 120,000/calendar year reports quarterly, the month after a completed quarter (i.e. April, July, October, and January) unless otherwise agreed.
Monthly reporting
A company whose packaging fees exceed SEK 120,000/calendar year reports monthly, after the end of the month.

How the Circulate Tool Solves This

We create transparency, full control of your data and bridge the gap between your Packaging Supply chain, your Warehouse and the Authorities.

Technical DNA: Circulate captures the material breakdown of everything you buy automatically. We store up to 200 data points per item—including weights and specs—so you don't have to chase suppliers. Your data is consistent, verified and DPP-ready from day one.
Volume placed in Sweden: Your warehouse must track how many units of each packaging were shipped to Sweden.
One-Click Compliance: Combine your shipment counts with the technical data in your Circulate portal. You get a verified, ready-to-file report in minutes.

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The Risk of Non-Compliance

Sanction Fees: Start at SEK 30,000 for missing registration.
Marketplace Bans: Amazon, Zalando, and others now require a valid Swedish EPR number to keep your listings active.
Retroactive Costs: Authorities can audit and charge fees for past unreported years.