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🇸🇪 EPR Compliance for WEEE in Sweden |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Electrical and Electronic Equipment – 7 Steps to Compliance + Step-by-Step Checklist

In Sweden, the European WEEE Directive is implemented through a national regulation overseen by the Swedish Environmental Protection Agency (Naturvårdsverket).

What sets Sweden apart from other European markets: Registration with Naturvårdsverket must be carried out by an authorized person within the company itself – no service provider can perform this task on behalf of a company based in Sweden. At the same time, the system allows foreign companies to fully delegate their obligations to a local authorized representative.

What does this mean in practice?

Here are the 7 most important steps – including a practical checklist.

Who is considered a “manufacturer” (Producent) under the Swedish WEEE regulations?

The definition is based on the first placing on the Swedish market:

  • Companies based in Sweden:
    • Producent: Anyone who manufactures EEE domestically and sells it under their own name or brand.
    • Importer: Anyone who commercially imports EEE into Sweden from abroad (EU or third country).
  • Companies from other EU countries: Anyone who sells EEE directly to Swedish end consumers via distance selling (online store).
  • Companies outside the EU: Anyone who delivers directly to Swedish customers via e-commerce. In B2B supply chains, the first Swedish importer is considered the legal producer.
  • White-label / private-label manufacturers: Any entity that sources devices from third parties but places them on the market in Sweden under its own brand name.
  • Marketplace operators: Platforms such as Amazon.se and Fyndiq bear subsidiary liability under Swedish consumer protection and environmental law. They automatically verify registration and block sellers who cannot provide proof of Swedish EPR compliance.

Practical example: A German company sells small kitchen appliances directly to Swedish end customers via Amazon.se → is considered a producer → must appoint an authorized representative in Sweden → the authorized representative registers the company in the EEB register with Naturvårdsverket → membership in an approved collection system → POM report → annual consolidation by March 31.

The 7 Most Important Steps for EPR Compliance in Sweden

Step 1: Appoint an Authorized Representative (for foreign companies)

Companies not established in Sweden that sell directly to Swedish end users via distance selling (B2C or B2B) are required to appoint an authorized representative established in Sweden. This applies to both EU companies and companies from third countries.

Requirements for the authorized representative:

  • A natural or legal person established in Sweden
  • A written power of attorney in Swedish or English
  • No Hague Apostille required – however, the Swedish registry conducts random checks of the foreign signatory’s authority to act as an authorized representative (e.g., based on an extract from the commercial register)
  • The authorized representative assumes full legal and financial responsibility (registration, reporting, payment of disposal fees)

Step 2: Classify the product into an EEE category

Sweden follows the 6 categories of the WEEE Directive 2012/19/EU:

CategoryDescriptionExamples
1Heat exchangersRefrigerators, air conditioners, heat pumps
2Screens & displays (>100 cm²)Televisions, monitors, laptops
3LampsLEDs, fluorescent tubes, energy-saving bulbs
4Large appliances (>50 cm)Washing machines, stoves, large household appliances
5Small appliances (≤50 cm)Coffee makers, tools, vacuum cleaners
6Small IT & telecommunications devices (≤50 cm)Smartphones, tablets, routers, GPS

Important distinction: Household EEE vs. professional EEE

This distinction has direct legal consequences in Sweden:

  • Household EEE: Mandatory membership in an approved collection system
  • Professional EEE (B2B): Also requires mandatory affiliation with an authorized collection system; however, unlike in the B2C sector, this system does not need to have a nationwide infrastructure. The manufacturer remains responsible for demonstrating compliant waste management and for providing detailed reports on collected quantities to the Environmental Protection Agency (which is typically handled through the system).

Step 3: Membership in an Approved Collection System

In Sweden, there are several systems approved by the relevant environmental authority – known as Producer Responsibility Organizations (PROs) – that assume the legally mandated producer responsibility for waste electrical and electronic equipment (WEEE) and batteries.

Alternative: Self-Compliance: Theoretically possible for professional (B2B) equipment. For household appliances (B2C), self-compliance is effectively impossible, as the manufacturer would have to demonstrate a nationwide take-back system comparable to the established systems – a practically insurmountable burden for most companies.

Step 4: Mandatory registration in the EEB Register with Naturvårdsverket

Competent authority: Naturvårdsverket (Swedish Environmental Protection Agency)

Register: EEB Register (Register för elektrisk och elektronisk utrustning samt batterier – Register for Electrical and Electronic Equipment and Batteries)

Procedure:

  1. Registration via Naturvårdsverket’s e-services – Swedish companies via BankID, foreign companies via a special international access channel
  2. Provision of company information, product categories, brands, and distribution channels
  3. Mandatory proof of membership in an approved collection system (for household EEE)
  4. Receipt of a unique Swedish manufacturer number

Important: Registration in the agency’s EEB Register is a separate requirement – it does not replace membership in an approved collection system, and conversely, PRO membership does not replace the agency’s registration. However, this is a two-step linking process: A manufacturer can only successfully register in the government registry after having previously entered into a contract with an approved collection system.

Step 5: Financial Obligations & Fee Structure

The disposal fee is calculated per unit or per kilogram of EEE placed on the market, in accordance with the rate tables of the approved collection systems, which are tiered by product category.

Fee Structure:

ComponentDetails
Annual Service Fee Fixed amount (covers administrative costs)
Environmental FeeVariable, based on number of units or weight, depending on product category
B2C Rates Fixed rates; finance the ongoing, municipally supported household recycling program
B2B Rates B2B rates: For purely B2B equipment, Swedish take-back systems often charge only a small basic administrative fee, as the actual disposal costs are incurred only when the equipment is physically scrapped.

Eco-modulation: The systems apply eco-modulation criteria. Products that are easy to disassemble or contain a verified percentage of recycled plastic receive discounts on the disposal fee.

Step 6: Reporting Requirements: POM Report & Annual Report

Quantity Report (Put on Market – POM)

  • Content: Weight (kg) and number of units of EEE sold, broken down by category and B2C/B2B use
  • Frequency: Varies by manufacturer and selected system

Channel: Digitally via the respective manufacturer portal

Annual Consolidation to Naturvårdsverket

  • Deadline: March 31 of the following year
  • The collective systems automatically submit the aggregated POM data on behalf of all affiliated manufacturers to Naturvårdsverket’s central EEB registry
  • The manufacturer thus fulfills its annual legal reporting obligation by correctly and consistently entering data into the respective manufacturer portal

Difference between household and professional EEE in reporting:

  • Household EEE: Manufacturers report only the POM data; the collective systems handle the reporting on WEEE treatment
  • Professional EEE: Manufacturers must also specify how much WEEE was collected and treated – based on information from the contracted recycling companies

Step 7: Labeling Requirements & Take-Back Obligations for Retailers

1. Crossed-out trash can (WEEE symbol): Must be permanently and clearly visible on the device.

2. Manufacturer information on the product: The brand name, logo, or registered company name must be permanently affixed to the product.

Step-by-Step Checklist

(a) Companies based in Sweden

1. Classify products into the correct WEEE categories and determine the household/commercial proportion

2. Enroll in an authorized system – mandatory for household EEE

3. Register independently via BankID in the EEB Register at Naturvårdsverket

4. Regularly report quantities in kilograms and units via the manufacturer portal

5. For professional EEE: Document proof of collection and treatment (obtain information from recyclers)

6. Affix the crossed-out trash can symbol and manufacturer information to the product

(b) Companies from other EU countries

1. Check the distribution channel: Direct sales to Swedish end customers (e-commerce)? → Proceed to Step 2

2. Appoint an authorized representative based in Sweden (written power of attorney in SE or EN)

3. The authorized representative enters into a membership agreement with an approved system on behalf of the EU manufacturer

4. The authorized representative activates the registration in the EEB Register via Naturvårdsverket’s international access

5. Submit the Swedish registration confirmation to sales platforms (Amazon.se, Fyndiq)

6. Send structured quantity data (weight, quantity, category, B2C/B2B) to the authorized representative

7. Check labeling: Waste bin symbol + manufacturer information on devices intended for the Swedish market

(c) Companies from third countries (outside the EU)

1. Validate the supply chain: Is the product being shipped via a Swedish importer? → Legal obligations rest with the importer; submit all weight and material data in a timely manner

2. For direct shipping (e-commerce) without a Swedish intermediary: Appoint an authorized representative in Sweden (mandatory) – follow the same steps as in (b)

3. Ensure proof of compliance on Swedish marketplaces

4. Customs declaration: Correctly assign registration data to the authorized representative

Are you planning to sell your products in Sweden?

We’ll help you ensure compliance with Sweden’s EPR regulations for WEEE so you can get started with legal certainty.

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