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

Extended Producer Responsibility (EPR) for Batteries and Rechargeable Batteries – 7 Steps to Compliance + Step-by-Step Checklist

Anyone selling batteries or battery-powered devices in Sweden has a legal obligation: Extended Producer Responsibility makes companies jointly responsible for the end-of-life management of their batteries. As of August 18, 2025, a fundamentally reformed system has been in effect in Sweden – the old national battery regulation was replaced by the directly applicable EU Battery Regulation (EU 2023/1542), supplemented by the Swedish implementing regulation 2025:813. The system continues to be administered by Naturvårdsverket (the Swedish Environmental Protection Agency).

What does this mean specifically for your company? Here are the 7 most important steps – including a checklist to get you started.

Who is considered a “producer” under Sweden’s Battery EPR?

Producer responsibility (Producentansvar) is determined by the first placing on the market in Sweden – regardless of the company’s registered office. Specifically, this applies to:

  • Domestic producers – those who manufacture batteries (either individually or built into devices) domestically and sell them under their own name or brand
  • Importers – anyone who commercially imports batteries or battery-containing devices into Sweden from abroad (EU or third countries)
  • EU companies engaged in distance selling – anyone who delivers batteries or battery-containing goods directly to Swedish end customers via online stores or marketplaces (B2C or B2B)
  • Non-EU companies – those that ship directly to Swedish end customers via e-commerce; in traditional B2B supply chains, the first Swedish importer is legally considered the producer
  • White-label / private-label products – companies that sell devices with built-in or included batteries under their own brand in Sweden
  • Marketplace operators – platforms such as Amazon.se are vicariously liable under national enforcement rules; they conduct automated checks and suspend accounts without proof of Swedish EPR compliance

Practical example: A German company operates an online store and ships electrical appliances with built-in batteries directly to Swedish end customers → is considered a “producer” within the meaning of the Battery EPR → must appoint an authorized representative based in Sweden → must be a member of an approved Producer Responsibility Organization → must register with Naturvårdsverket and receive a SEBATT number → must report quantities quarterly → must upload proof of compliance to the Amazon.se backend

The 7 Most Important Steps for Battery Compliance in Sweden

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

Foreign manufacturers without a branch in Sweden who sell directly to Swedish customers via distance selling must appoint an authorized representative (Producentombud) based in Sweden – regardless of whether the end customers are private households or businesses.

The authorized representative assumes legal and financial responsibility (registration, reporting, payment of disposal fees).

Requirements for the power of attorney documentation:

  • A written agreement in Swedish or English, signed by the authorized representatives of both parties
  • A Hague Apostille is not required as a matter of course; however, the authority to represent (e.g., an extract from the foreign company’s commercial register) is validated digitally
  • Registration is carried out by the authorized representative using the foreign VAT ID or an assigned administrative ID directly on the Naturvårdsverket portal

Step 2: Mandatory Registration with Naturvårdsverket

Competent Authority: Naturvårdsverket (Swedish Environmental Protection Agency)

Registration Platform: Naturvårdsverket’s e-services – EE Register and Battery Register

Procedure:

  1. Fully digital application process; domestic companies use BankID
  2. Provision of company master data, the five battery categories, chemical composition (e.g., lithium-ion, lead-acid), and brands
  3. Mandatory proof of membership in an approved producer responsibility organization (OfH)
  4. Assignment of a unique registration number

Step 3: Membership in an Approved Producer Responsibility Organization (PRO)

The reform of August 18, 2025, introduced the role of the Producer Responsibility Organization – which has an expanded legal scope of responsibility compared to the previous collection systems for the collective fulfillment of EPR obligations.

Currently, there are several Producer Responsibility Organizations to choose from.

Individual compliance: Practically impossible for portable batteries, as a comprehensive, municipality-based collection system is required. For industrial and EV batteries in the purely B2B sector, however, self-management through contractually agreed direct take-back arrangements with commercial end customers is common practice.

Step 4: Classify batteries into the 5 EU categories

CategoryExamples
Portable batteriesAA, AAA, button cells, rechargeable batteries in consumer devices
LMT batteries E-bikes, e-scooters, light electric vehicles
Starter batteries (SLI)Starter batteries for motor vehicles
Industrial batteriesStationary energy storage systems, professional power tool batteries
Electric vehicle (EV) batteriesTraction batteries for passenger cars, trucks, and buses

Correct classification determines both the selection of the responsible waste management organization and the contribution rates.

Step 5: Calculate and Pay Financial Contributions

Calculation: The recycling fee is calculated per kilogram or per unit placed on the market, differentiated by battery type and system tariff. Lithium-ion batteries are subject to higher rates than alkaline batteries due to the logistical safety risk.

Eco-modulation: Swedish systems are increasingly incorporating criteria from the EU Battery Regulation. Batteries that can be easily removed from the device or that are verifiably made from a high proportion of recycled material receive fee discounts.

Step 6: Comply with Reporting Requirements

Quantity Reporting:

  • Report weight and quantity, broken down by chemical composition, intended use, and B2C/B2B market

Deadlines and Intervals:

  • By default, data must be submitted quarterly (in the month following the end of the quarter) directly through the respective system’s portal
  • Small distributors may switch to annual reporting
  • Additionally: Annual reporting of quantities placed on the market directly to Naturvårdsverket by March 31 of the following year at the latest

Regulatory reporting: The PROs submit the aggregated data to Naturvårdsverket’s central registry, thereby fulfilling the manufacturer’s annual reporting obligation to the government.

Expanded obligations under the EU Battery Regulation:

  • CO₂ footprint: Manufacturers of EV batteries must submit a verified CO₂ footprint declaration digitally or link it to the product
  • Due diligence: Larger manufacturers must document evidence of compliance for their raw material supply chains (lithium, cobalt, nickel)

Step 7: Comply with labeling requirements

  • Crossed-out trash can symbol: Must be displayed on every battery; if there is insufficient space, it may be placed on the packaging
  • Capacity rating: Required for all portable batteries and automotive batteries – must be specified in mAh, Ah, or Wh

Step-by-Step Checklist

(a) Companies based in Sweden

1. Classify batteries into the 5 EU categories

2. Register with an authorized PRO

3. Complete registration on the Naturvårdsverket portal (BankID) and obtain a SEBATT number

4. Submit CO₂ footprint documentation (if EV batteries are placed on the market)

5. Set up quarterly volume reporting via the PRO portal

6. Ensure annual reporting to Naturvårdsverket by March 31

7. Check labeling: trash can symbol and capacity information on all batteries

(b) Companies from other EU countries

1. Check the distribution channel: Are direct sales to Swedish end customers made via e-commerce? If yes → proceed to Step 2

2. Appoint an authorized representative based in Sweden and execute a written power of attorney

3. The authorized representative applies for PRO membership on behalf of the foreign manufacturer

4. The authorized representative activates the registration on the Naturvårdsverket portal and receives the SEBATT number

5. Upload the registration certificate to the backend of Amazon.se and other marketplaces

6. Ensure quarterly volume reporting is submitted via the authorized representative

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

1. Review the supply chain: Delivery to a Swedish importer → the importer is considered the manufacturer; submit all weight and material data (chemical composition) in a timely manner

2. Direct shipment to end consumers without a Swedish intermediary → all steps listed in (b) must be handled through the authorized representative

Are you planning to sell your products in Sweden?

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

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

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65760 Eschborn