In Sweden, pallet makers are now packaging producers
Since 12 August 2026 Sweden uses PPWR's producer definition. For transport packaging that moves producer responsibility from the company that fills the pallet to the one that makes or first supplies it. First report: 31 March 2027.
Until this summer, the producer of a wooden pallet under Sweden's packaging rules was mainly whoever filled it: the supplier putting goods on it. That changed on 12 August 2026. Sweden's amended packaging ordinance (SFS 2026:1462) now uses PPWR's definitions. For transport packaging, the producer is the manufacturer, importer or distributor that first makes the packaging available in Sweden, empty or filled (Naturvårdsverket, packaging producer).
What it means
For many pallet makers this is new:
Register with Naturvårdsverket as a producer.
Join an approved PRO, NPA or TMR, if you became a producer only through the new definition.
Report by 31 March each year. The first report under the new definition, covering 12 August to 31 December 2026, is due by 31 March 2027 (Naturvårdsverket, national rules).
Operators of reuse systems have a separate new duty: notify Naturvårdsverket of the system and report each year.
What the industry says
Skogsindustrierna agrees that responsibility now sits with the wood packaging makers. In its consultation response it asks that fees cover only pallets that end up as waste in Sweden. Many pallets are exported, and the maker, now the producer, can't know which (Skogsindustrierna, 1 April 2026). Naturvårdsverket's proposals for wood packaging are due by 1 December 2026, so expect more detail then.
Getting the numbers
A producer report is a count per year: how much packaging, of which kind, made available in Sweden, single-use or in a reuse system. The fee gap is large. NPA charges SEK 2.50 per kg for single-use wood in commercial use against SEK 0.05 per kg for wood in a reuse system (NPA, 2026 fees). Knowing which pallets went into which system is worth money.
Resupply records each pallet movement per counterparty and site at the dock, with the pallet types and counts read from a photo of the waybill, and keeps balances under each packaging agreement. Resupply is building PPWR reports on top of that record.
General information, not legal advice.
First Swedish report due in March? Ask Resupply for a short proposal: resupply.se (in Swedish).