Different Rules for Plastic Packages: Comparing the Implementationof EU Rules in Sweden and Denmark

Policies targeting the reuse and recycling of plastic packaging have been central to the European Union’s circular economy agenda on plastic packaging waste. Recent reforms have shaped a complex and multi-level policy framework that seeks to balance the common EU waste policy goals, the flexibility afforded to Member States in waste treatment, and the preservation of an effective single market for products.

This article examines the implementation of the minimum requirements for extended producer responsibility (EPR) in Sweden and Denmark, focusing on the introduction of eco-modulated fees. Using tools of comparative studies, the study identifies both similarities and differences in the implementation.

Contrary to the hypothesis derived from theories of differentiated EU policy implementation—which posits that institutionally well-prepared Member States would enact environmental regulations comprehensively and without significant restrictions—Sweden’s approach was minimalistic. In contrast, Denmark, despite starting its EPR for packaging system from scratch, adopted a comprehensive implementation strategy. Various factors were found to explain these outcomes, including country-specific regulatory contexts and differing timelines in relation to broader EU packaging regulations.

The findings contribute to a deeper understanding of the complexities inherent in EU regulatory implementation processes, highlighting the interplay between national contexts and supranational policy frameworks.