Support and information

Producer responsibility for batteries

Batterier
Last reviewed: ‎26‎ ‎September‎ ‎2025

The person who first supplies batteries in Sweden has producer responsibility (EPR) and must, among other things, ensure that batteries are taken care of when they are no longer used. Many EPR requirements were changed on August 18, 2025.

The electrification of society is important for quickly reducing greenhouse gas emissions and limiting temperature increases. The need for batteries is therefore expected to increase sharply for the foreseeable future. This in turn leads to environmental impact throughout the battery value chain - from raw material extraction to waste management. Preventing these batteries from becoming waste and ultimately utilizing them in the best way is crucial to achieving a circular economy for batteries. This is the main purpose of producer responsibility.

Target group

The information is primarily intended for companies and others who first supply batteries in Sweden (producers), producer representatives, producer responsibility organizations, waste management operators, recycling operators, distributors and municipalities.

Good to know

This guidance is about new rules in the Battery Regulation regarding producer responsibility and waste management. However, the Regulation covers the entire life cycle of the battery, including product and information requirements, supply chain due diligence requirements and product passports. Please familiarise yourself with the Regulation to understand how you are affected. 

News

On August 18, new regulations for producer responsibility for batteries started to apply. This means, among other things, that battery producers need to register with the Swedish Environmental Protection Agency (EPA) in line with the new requirements. For existing producers, this involves updating their current registration via the e-service for producer responsibility.

An updated registration must include information on how the responsibility is fulfilled when the batteries become waste. The responsibility can be fulfilled collectively by appointing an authorised producer responsibility organization (PRO) to fulfill obligations on the producer’s behalf, or fulfilling the requirements individually, i.e. on its own. A producer who chooses to fulfill the requirements on its own must also be authorised by the Swedish EPA.

Until there are authorised PROs or the producer itself is authorised to fulfill the requirements individually, it will only be possible to register preliminary. This means, among other things, that it will be stated in both the e-service and the registration certificate that the registration is not complete. The registration is then not complete until one or more authorised PRO(s), or the case number for the authorised decision, has been entered. Authorised PROs will be able to update the registration on behalf of their producers. 

To update an existing registration, follow the steps below:

  1. Log in to the Swedish EPA’s e-service for producer responsibility, available here: E-services for producer responsibility
  2. Click on the box for "Batteries" on the landing page under "Producer responsibility” and “Systems you are registered for".
  3. Click on "Change registration" and follow the steps in the registration. Remember to complete all steps and click submit for the registration to be updated.

The provisions on waste management and producer responsibility in the EU Battery Regulation (2023/1542) apply since the 18th August 2025. However, the provisions in the EU Battery Regulation cannot be fully applied until all complementary national provisions have been adopted and entered into force and producers or producer responsibility organisations (PROs) have been authorised for the fulfilment of producer responsibility. Pending this, the Swedish Environmental Protection Agency (EPA) believes that the provisions should be applied as far as possible. Based on this, the Swedish EPA interpretation is that, among other things, batteries should be removed in accordance with the EU Battery Regulation and are then handed over to a producer of the battery category in question, or to a waste management operator designated by the producer. It follows from Article 70 of the EU Regulation that batteries may only be handed over for treatment to a facility that meets the requirements of the EU Battery Regulation (Article 70 and Annex XII).

Supervision and sanctions

From the 18 August 2025, the Swedish Environmental Protection Agency (EPA) has supervisory responsibility for the obligations of producers and producer responsibility organisations (PROs) under Regulation (2025:813). 

However, the government has not yet decided on the penalties for violations of the EU Battery Regulation. When this will happen, the Swedish EPA cannot say. However, as a regulatory authority, the Swedish EPA has the possibility to take regulatory measures to ensure that the rules are adhered to.

Since the 18 August 2025, the waste management provisions of the Battery Regulation applies at EU level, which means, among other things, new rules regarding producer responsibility.

Important changes (although not all changes) are:

  • New definitions, including for producer.
  • New categories of batteries, including the categories of electric vehicle batteries and batteries for light means of transport (electric scooters and electric bicycles).
  • The role of producer responsibility organization (PRO) is introduced, for the collective fulfillment of the obligations regarding extended producer responsibility (EPR). PROs will have greater responsibility than the organizations that are currently responsible for collective collection systems.
  • Both producer responsibility organisations (PROs) and producers that do not appoint a PRO but choose to fulfil their own obligations regarding extended producer responsibility, need to be authorised by the Swedish Environmental Protection Agency (EPA).
  • Only waste operators selected by the producer or producer responsibility organisation may collect or treat battery waste.
  • All operators who collect used batteries must hand them over to the producer or producer responsibility organisation, or a waste operator selected by the producer or producer responsibility organisation.
  • Specific provisions on the recycling of batteries.
  • Waste management operators who recycle batteries will be responsible for achieving the recycling targets and for reporting the data to the Swedish Environmental Protection Agency.
  • Tougher requirements regarding the export of battery waste, especially if the treatment is to be counted towards the recycling targets.
  • New requirements for treatment and storage.
  • Increased requirements for information to end users, waste management operators and recyclers.
  • Requirements for distributors who are part of collection systems for waste batteries.
  • Increased collection targets for portable batteries, new collection targets for batteries for light means of transport.
  • Increased and new recycling targets, both for the entire battery and for certain battery metals.

Batteries covered – three exceptions

Producer responsibility covers all batteries, regardless of design, chemistry or application, with very few exceptions. This means, for example, that batteries built into electrical equipment and vehicles are covered by producer responsibility.

A battery can be a battery cell, a battery module or a battery pack. Cells and modules are batteries if the intention is to use them directly as batteries without assembly into a module or pack.

Batteries not covered

The three exceptions from producer responsibility apply to batteries that are included in, or specifically designed to be included in:

  • Equipment intended for military purposes.

  • Equipment intended to be sent into space.

  • Equipment specifically intended for the safety of nuclear facilities

The EU Battery Regulation divides batteries into five categories. The categories of electric car batteries and batteries for light means of transport (electric bicycles and electric scooters) have been added. In addition, the definitions of the different categories have changed slightly compared to before. It is important to correctly determine which category of batteries you as a producer are providing on the market, as both producer responsibility and product requirements vary depending on the category.

Please note, for example, that a battery weighing more than 5 kg cannot be a portable battery, but that a battery weighing less than 5 kg can be an industrial battery. And that an important criterion for whether it is an industrial battery instead of a portable battery is whether it is specifically designed for industrial uses. Just because a battery is sometimes used by businesses does not mean that it is necessarily an industrial battery.

Also, note that the category of starter batteries does not only include batteries in cars. More information about the categories can be found in, among other things, recital 15 of the Battery Regulation (i.e. the introductory paragraphs before the articles themselves). The different battery types below are explained in the definitions section at the end of this guidance.

  • Portable batteries
  • Light means of transport battery (or LMT battery)
  • Industrial battery
  • Starting, lighting and ignition battery or ‘SLI battery
  • Electric vehicle battery

Further guidance

Definitions

Companies and others who professionally carry out the separate collection or treatment of waste batteries.

Any device delivering electrical energy generated by direct conversion of chemical energy, having internal or external storage, and consisting of one or more non-rechargeable or rechargeable battery cells, modules or of packs of them, and includes a battery that has been subject to preparation for re-use, preparation for repurposing, repurposing or remanufacturing.

A battery that is sealed, weighs 25 kg or less and is specifically designed to provide electric power for the traction of wheeled vehicles that can be powered by an electric motor alone or by a combination of motor and human power, including type-approved vehicles of category L within the meaning of Regulation (EU) No 168/2013 of the European Parliament and of the Council ( 43 ), and that is not an electric vehicle battery.

A battery that is sealed, weighs 5 kg or less, is not designed specifically for industrial use and is neither an electric vehicle battery, an LMT battery, nor an SLI battery.

A battery that is specifically designed to provide electric power for traction in hybrid or electric vehicles of category L as provided for in Regulation (EU) No 168/2013, that weighs more than 25 kg, or a battery that is specifically designed to provide electric power for traction in hybrid or electric vehicles of categories M, N or O as provided for in Regulation (EU) 2018/858.

A battery that is specifically designed for industrial uses, intended for industrial uses after having been subject to preparation for repurposing or repurposing, or any other battery that weighs more than 5 kg and that is neither an electric vehicle battery, an LMT battery, nor an SLI battery.

A battery that is specifically designed to supply electric power for starting, lighting, or ignition and that can also be used for auxiliary or backup purposes in vehicles, other means of transport or machinery.

Any manufacturer, importer or distributor or other natural or legal person that, irrespective of the selling technique used, including by means of distance contracts, either:

  1. is established in a Member State and manufactures batteries under its own name or trademark, or has batteries designed or manufactured and supplies them for the first time under its own name or trademark, including those incorporated in appliances, light means of transport or other vehicles, within the territory of that Member State;
  2. is established in a Member State and resells within the territory of that Member State, under its own name or trademark, batteries, including those incorporated in appliances, light means of transport or other vehicles, manufactured by others, on which the name or trademark of those other manufacturers does not appear;
  3. is established in a Member State and supplies for the first time in that Member State on a professional basis, batteries, including those incorporated in appliances, light means of transport or other vehicles, from another Member State or from a third country; or
  4. sells batteries, including those incorporated in appliances, light means of transport or other vehicles, by means of distance contracts directly to end-users, whether or not they are private households, in a Member State, and is established in another Member State or in a third country;

A legal entity that financially or financially and operationally organises the fulfilment of extended producer responsibility obligations on behalf of several producers. 

A natural or legal person established in a Member State in which the producer places batteries on the market and which is different from the Member State where the producer is established, and is appointed by the producer in accordance with Article 8a(5), third subparagraph, of Directive 2008/98/EC to fulfil the obligations of that producer under Chapter VIII of this Regulation.

Any making available of a battery for distribution or use on the Union market within the framework of a commercial activity, whether in return for payment or free of charge.

Producer responsibility should encourage companies to develop products that are resource efficient, easy to reuse and recycle, and free of environmentally hazardous substances. This will result in Sweden and other EU countries generating less waste, separate waste fractions, and less littering.