Status as of 9 November 2026.
The pause of the packaging representative requirement is not decided yet. And the two proposals on the table work in opposite ways.
Since 12 August 2026, a company in another EU country that sells packaged products directly to users in Sweden needs an authorised representative here under the Packaging Regulation (PPWR, Article 45). There is no general exemption for small producers.
In October, the European Parliament and the Council each adopted a position on pausing that requirement for EU-based producers:
→ Parliament: micro and small enterprises are exempt, regardless of how much packaging they place on the market. That means fewer than 50 employees and turnover or balance sheet below EUR 10 million.
→ Council: producers placing less than 1 tonne of packaging per year in a country are exempt, regardless of company size, until 2032.
A small company selling 20 tonnes into Sweden would be exempt under the first and not under the second. A large company selling 300 kg would be exempt under the second and not under the first.
Negotiations between the two have not started yet. Until they agree and the text is published in the Official Journal, the requirement applies as written. And even when a pause comes, it only removes the representative. Registration with Naturvårdsverket, membership in a producer responsibility organisation and reporting stay with the producer.
The Commission’s proposal also covered the representative requirement for batteries. Parliament kept batteries in, with the same small-company test. The Council’s position covers packaging only. For batteries, a pause is even less certain, and the requirement applies as written.
At STRUKT we act as authorised representative in Sweden for packaging, electrical equipment and batteries, independent of the Swedish producer responsibility organisations. Questions: contact@strukt.se or +46 707 61 73 46.
