In the paper, upper bounds for the rate of convergence in laws of large numbers for mixed Poisson random sums are constructed. As a measure of the distance between the limit and pre-limit laws, the Zolotarev $ζ$-metric is used. The obtained results extend the known convergence rate estimates for geometric random sums (in the famous R{é}nyi theorem) to a considerably wider class of random indices with mixed Poisson distributions including, e. g., those with the (generalized) negative binomial distribution.