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Producer responsibility for batteries

Batterier

Battery producers

Last reviewed: 26 September 2025

This information will help you determine whether you have producer responsibility for batteries and if so, what you need to do. The rules described here came into effect on August 18th , 2025 and stem from the EU Battery Regulation and supplementary national regulations.

The purpose of producer responsibility (EPR) for batteries is to prevent batteries from becoming waste, and to manage batteries in the best possible way when they are no longer usable.

Target group

Companies or others who first make available a battery in Sweden, usually through sale (i.e. producers). According to the legal requirements, you have a financial responsibility for the battery being discarded after use.

Good to know

The Battery Regulation gradually replaces the Battery Directive. The parts of the regulation that deal with producer responsibility for batteries came into force on the 18 August 2025. 

News

On 18 August, 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) according to the new requirements. For existing producers, this involves updating their current registration via the e-service for producer responsibility.

 

An updated registration must, among other things, contain 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 their behalf, or alternatively fulfill the requirements individually, i.e. on their own. A producer who chooses to fulfill the requirements on their own must 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 authorisation decision has been entered. Authorised PROs will be able to update the registration for their producers.

To update an existing registration, follow the steps below:

  1. Log in to the Swedish Environmental Protection Agency's e-service for producer responsibility, which is 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.

Since the 18 August 2025, the waste management provisions of the Battery Regulation at EU level will apply and this means, among other things, new requirements regarding producer responsibility.

Important changes (although not all changes) are:

  • New definitions, including those of producer.
  • New categories of batteries, including the categories of electric car batteries and batteries for light means of transport (e-scooters and e-bikes).
  • The role of producer responsibility organization (PRO) is introduced, for the collective fulfilment of the obligations regarding extended producer responsibility (EPR). PROs will have greater responsibility than the organisations currently responsible for collective collection systems.
  • Both producer responsibility organisations (PROs) and producers who do not appoint a PRO but choose to fulfil obligations regarding extended producer responsibility themselves, need to be authorised by the Swedish EPA.
  • Only waste operators selected by the producer or producer responsibility organisation may collect or treat battery waste.
  • All operators who collect waste batteries must hand them over to the producer or producer responsibility organization (PRO), or a waste operator selected by the producer or PRO.
  • Specific provisions on the recycling of batteries.
  • Waste management operators who recycle batteries will be responsible for achieving the recycling targets and reporting the data to the Swedish Environmental Protection Agency (EPA).
  • 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 involved in 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 whole battery and 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 definition of the categories has 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 use. 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, among other things, in recital 15 of the Battery Regulation (i.e. the introductory paragraphs before the articles themselves). The different types of batteries below are explained in the definitions section.

  • Portable batteries
  • Light vehicle batteries
  • Industrial batteries
  • Starter batteries
  • Electric vehicle batteries

Is your company a producer?

Companies or others who first make available a battery on the Swedish market become, in most cases, the producer of that battery. For example, your company becomes a producer if it imports batteries into Sweden and sells them to customers on the Swedish market. And this also applies to batteries that are in electrical equipment or vehicles. Note that you can have producer responsibility for several products, e.g. for batteries and at the same time for electrical equipment, vehicles or packaging.

Below are five questions that will help you determine whether your company is a producer. If you answer “Yes” to one of the questions, your company is a producer.

Situation  Producer responsibility
Is your company established in Sweden, imports batteries into Sweden from a country outside the EU and sells the batteries for the first time in Sweden? Yes / No
Is your company established in Sweden, takes in batteries into Sweden from a country within the EU and sells the batteries for the first time in Sweden? Yes / No
Does your company manufacture batteries in Sweden and sell them in Sweden? Yes / No
Does your company sell from abroad directly to end users (consumers) in Sweden? Yes / No
Is your company established in Sweden, is a retailer that sells batteries under its own name or brand in Sweden, and the batteries do not have the manufacturer's name or brand? Yes / No

If you answered "No" to all five questions, your company is not a producer.

As stated above, it is mainly companies or others in Sweden that become producers. The exception is distance sales from companies outside Sweden directly to end consumers in Sweden. In that case, the company outside Sweden needs to appoint an authorised producer representative who is established in Sweden.

Note that there is no longer a minimum threshold for small producers. The producer definition applies regardless of the quantity of batteries that you make available for the first time in Sweden.

 

Multiple producer responsibilities?

Businesses can be covered by multiple producer responsibility (EPR) systems. It can be a combination of producer responsibility for electrical equipment, batteries and packaging. If this applies to your company, you must register under all these EPR systems with the Swedish Environmental Protection Agency.

What does a producer need to do?

The producer is responsible for its batteries when they become waste. This responsibility entails a number of different obligations, see below. The obligations can be divided into those that the producer itself needs to fulfill and those that can be fulfilled by a producer responsibility organization (PRO), if one is appointed. If the producer has appointed a producer representative, that representative is responsible for the producer's obligations.

Must be fulfilled by a producer:

  • Pay for the handling of its waste batteries, including collection, transport and treatment.
  • Pay for compositional surveys for portable batteries and batteries in light vehicles, which are carried out every five years.
  • Pay an annual supervision fee to the Swedish Environmental Protection Agency (EPA).
  • Appoint an authorised producer responsibility organization (PRO) to fulfill obligations on its behalf, or alternatively fulfill the requirements on its own.
  • Provide waste management operators with access to information on safety and security measures for the collection and storage of waste batteries.
  • Upon request, provide waste management operators with free access to information on a specific battery model to enable dismantling.

To be fulfilled by a producer or a producer responsibility organization (PRO), if one is appointed:

  • Register the producer in the Swedish Environmental Protection Agency's (EPA’s) register.
  • Apply for authorisation from the Swedish EPA.
  • Report annually to the Swedish EPA the amount of batteries that the producer initially makes available in Sweden and the amount of waste batteries that have been collected and delivered for treatment.
  • Inform end-users about waste prevention measures and their role in ensuring that waste batteries are collected separately from other waste.

In addition to the obligations mentioned above, different requirements are placed on producers depending on the category of batteries that are made available. The requirements distinguish in particular between portable batteries and batteries for light means of transport on the one hand, and industrial, starter and electric vehicle batteries on the other.

The producers’ financial responsibility

Cost responsibility includes:

  • Waste batteries are collected separately, delivered to authorised treatment facilities and treated at these facilities.
  • Inform end-users and distributors about how waste can be prevented and how waste batteries should be handled.
  • Register with and report to the Swedish Environmental Protection Agency (i.e. the own costs from carrying out these tasks).

Any income generated by the sale of recycled batteries and recycled material shall be deducted from the costs of collecting and handling waste batteries.

Producers who are authorised to fulfil their obligations shall also cooperate with other such producers and producer responsibility organizations (PROs) on the distribution of waste costs (see the sections “Establishing collection systems for waste batteries”).

For portable batteries and batteries for light means of transport, there is also the cost of compositional surveys, which are carried out every five years on mixed municipal waste and WEEE. However, it is the competent authority that must ensure that compositional surveys are carried out, not the producers.

A compositional survey fee must be paid by producers and producer responsibility organisations (PROs) that are authorised on 1 January of the year in which the compositional survey is carried out (i.e. every five years).

The compositional survey fee shall cover the total costs of administering and carrying out a compositional survey.

The costs shall be distributed so that:

  • a producer that individually fulfils obligations relating to extended producer responsibility (EPR) shall pay a share corresponding to the producer's share of the market for portable batteries and batteries for light means of transport in the calendar year before the compositional survey was carried out, measured in weight, and
  • a producer responsibility organisation (PRO) shall pay a share corresponding to the affiliated producers' combined share of the market for portable batteries and batteries for light means of transport in the calendar year before the compositional survey was carried out, measured in weight.

Authorised producer representative

As a producer, you must appoint an authorised representative for extended producer responsibility (EPR) if you sell batteries directly to end users in a country within the European Economic Area (EEA) where you are not established. This applies to both Swedish companies that sell directly to end users in an EEA country as well as foreign companies, both within and outside the EEA, that sell directly to end users in Sweden.

You must appoint the producer representative by means of a written power of attorney. The power of attorney is only valid if the representative has given written approval to you as a producer and if the representative has sufficient resources to be able to perform the tasks specified in the power of attorney.

Appoint a producer responsibility organization

A producer responsibility organization (PRO) can be the same organization that was previously called a collective collection system. PROs are intended to make it easier for producers to take their producer responsibility. PROs fulfill the obligations of producer responsibility on behalf of producers.

PROs normally collect one or more categories of waste batteries, but not all categories. It may therefore be necessary for you as a producer to join several PROs.

To join a PRO, you need to contact one or more such authorised organizations yourself. When you are affiliated, it is the PRO's task to register you in the Swedish Environmental Protection Agency's producer register.

When can you appoint a PRO?

At the moment there are three authorised producer responsibility organizations (PRO's): Batterikretsen, Batteriretur and FoRetur. The Swedish Environmental Protection Agency will update the information on this page if more PRO's are authorized.

Apply for authorisation

A prerequisite for you as a producer to be able to provide batteries on the Swedish market is that you have either appointed an authorised producer responsibility organization (PRO) or are authorised to meet the requirements relating to extended producer responsibility by 1 January 2026 at the latest. A company that meets the definition of producer, and does not want to join a PRO, must therefore themselves apply for authorisation from the Swedish Environmental Protection Agency (EPA).

Requirements for authorisation are mainly regulated in Article 58 of the EU Battery Regulation but also to some extent in the Swedish Regulation with supplementary provisions (2025:813).

The requirements for authorisation are largely the same regardless of whether it is a question of individual compliance (an individual producer) or collective compliance (PRO). However, there are certain differences, e.g. the requirements for a PRO's equal treatment of producers and differentiated fees. The requirements also differ somewhat depending on the battery category.

The Swedish EPA may attach authorisations with certain conditions and shall limit the authorisation to a certain period of time, however, not exceeding ten years. The Swedish EPA may choose to reconsider the conditions for the authorisation, and the authorised producer or PRO may apply for reconsideration to the Swedish EPA.

Read through the guidance on this page and prepare the application well in advance.

Application template

A template for the application is available under the heading "How to apply for authorisation?" on the left. A calculation model for the financial guarantee is available under the heading "Calculation of the size of the financial guarantee".

When the Swedish Environmental Protection Agency (EPA) has received your application, a notification with an application fee will be sent to you via email. Please provide the correct email address for the recipient of this notification in the contact details.

The Swedish EPA will not start processing your application until the application fee has been paid. The application fee is SEK 225,000 for producer responsibility organisations (PROs) and SEK 110,000 for producers.

Please note that there is also an annual supervision fee of SEK 225,000 for authorised PROs and SEK 110,000 for producers authorised to meet the requirements of producer responsibility. The first year this annual fee is due is 2026.

Before submitting an application for authorisation, please familiarise yourself with the Swedish Environmental Protection Agency's (EPA’s) guidance on producer responsibility for batteries and on authorisation, including information on the application and supervision fee.

The Swedish EPA will review the applications. An application can be made by downloading, completing and sending the application form below to the Swedish EPA.

Form (in Swedish): Application for authorisation to meet the requirements regarding producer responsibility for batteries (pdf) 

From the time a submitted application is deemed complete, the Swedish EPA has 12 weeks to decide on authorisation. The agency may request additional information if the application is not considered complete.

Requirements for applying for authorisation

Organizational means is that you as a producer meet the requirements for collection systems in Article 59, 60 or 61 depending on which battery category you provide. Important parts of this are being able to describe:

  • That you have designed a collection system with relevant stakeholders (of those listed in the articles) that enables the free of charge collection of all spent batteries within the category(ies) of batteries for which you are applying for authorisation.
  • In the case of industrial batteries, starter batteries and electric vehicle batteries, the system ensures that all batteries are collected that you as a producer provide and that you can also receive other stakeholders' waste batteries within your category.
  • Whether the requirements for the collection system are met in cooperation with other producers or producer responsibility organizations.
  • Being able to collect waste batteries from all over the country and equip collection sites to safely handle and store waste batteries.
  • That collected waste batteries can be delivered to those who have a permit to carry out waste treatment and meet the requirements of the Battery Regulation (Articles 70 and 73 and Annex XII of the Battery Regulation where applicable)
  • That the collection targets can be achieved (only for portable batteries and batteries for light vehicles).

See more under the collection section on this page.

The applicant needs to be able to prove how the requirements for the collection system are met with relevant documentation already in connection with the application, e.g. agreements with actors who either collect waste or with whom you collaborate to set up collection points.

Financial means is about you as a producer having sufficient funds to cover the costs required to fulfil the producer responsibility requirements, especially the collection and treatment of your waste batteries.

In order to assess the financial means, you may, for example, need to submit the most recent annual report. In addition, a competent authority has the possibility to analyse information in the credit report.

As a producer, you need to be able to describe how the requirement for internal control procedures is met, to ensure:

  • That the data to be collected and reported to the competent authority is of high quality. As a producer, you need to report data to the competent authority annually in accordance with Article 75 of the EU Battery Regulation. You therefore need to describe how you check that this data is correct. If an external party is used for collection, it is required that data from this party is checked in an appropriate manner.
  • That the requirements of the EU Waste Shipment Regulation (2024/1157) are complied with (if all or part of the treatment of your collected waste batteries takes place abroad).

You as a producer needs to describe how you intend to meet the information requirements. More details about the requirements can be found on the page "Information requirements".

According to Article 58(7) of the EU Battery Regulation, you who apply to become an authorised producer for individual compliance must provide a guarantee intended to cover the costs associated with waste management activities that are to be paid if the obligations regarding extended producer responsibility are not fulfilled, including if the activity ceases or in the event of insolvency. The material value from recycling and the value of reused products can be counted towards the cost. This corresponds to the producers' cost responsibility in Article 56(4 a) of the Battery Regulation.

The financial guarantee must be adequate for its purpose. In order for the Swedish EPA to be able to assess whether this requirement is met, the type and size of the guarantee need to be determined. At the time of application, you need to be able to describe how the guarantee requirement is intended to be met. The guarantee must be valid when you intend to begin operations.

The applicant needs to submit as complete a document as possible showing how they intend to meet the guarantee requirement. This should include information on the type of guarantee the applicant intends to provide, a contract or draft contract and, where applicable, contact information for the relevant bank or insurance company.

The producer applying for authorisation needs to submit a proposal for calculating the financial guarantee and supporting documentation in their application. We recommend that you use the Excel forms available via the links in the text on how to calculate the financial guarantee.

The Swedish EPA will review whether the guarantee is adequate for its purpose or not in connection with the examination of the application.

The Swedish EPA may, on its own initiative, reconsider the size of the guarantee if there is reason to assume that the guarantee is no longer adequate for its purpose. The Swedish EPA shall also reconsider the size of the guarantee at the request of an authorised producer, if the request is reasonable.

According to the EU Battery Regulation, a financial guarantee must be able to cover the waste management costs if the obligations regarding extended producer responsibility are not fulfilled, including if the business ceases or in the event of insolvency. The Swedish Environmental Protection Agency has developed the method below to calculate the size of the financial guarantee for producers.

Producers

The calculation of the size of the guarantee includes all batteries that you have provided in the past, minus the cost of batteries that have already been collected or treated. If for various reasons you do not know how many of your batteries have already been collected and treated, it is possible to estimate the cost. In addition, an estimate of the waste cost of the batteries that you plan to provide (even if the actual cost arises later). Due to the uncertainty factor regarding material prices, it is only considered possible to deduct 90% of the positive material value.

We recommend that you use the Excel form available via the link below. The form is filled in with the expected waste management costs per battery category for the specified years. The size of the financial guarantee is the annual average of the total net cost.

Calculation model (in Swedish): Waste costs batteries - for producers (xlsx) 

The competent authority may withdraw the authorisation if any of the following occurs:

  • the collection targets are not met (only portable batteries or batteries for light vehicles) or
  • if the authorised producer does not:
    • complies with the requirements for the collection and treatment of waste batteries or
    • reports information to the competent authority or
    • notifies changes to the conditions of the authorisation
  • if the authorised producer has ceased operations

Establishing a collection system for waste batteries

Collection systems are usually established by a producer responsibility organization (PRO). A producer can choose not to appoint an authorised PRO but must then meet the same requirements themselves. These requirements, further down in this paragraph, therefore only apply to producers who do not appoint a PRO, otherwise it is that organization that must meet the requirements.

Batteries that are built into electrical equipment or vehicles can be collected by a collection system or reception system for electrical equipment or vehicles. However, once the batteries have been removed, the requirements for collecting batteries and handing them over to a producer or PRO apply.

The producer must collect or take back waste batteries regardless of the nature, chemical composition, condition, brand or origin of the batteries, of the battery category that the producer provides in Sweden. This means that you must design a collection system to be able to collect all your waste batteries. In addition to this, you cannot refuse to accept other producers' waste batteries within your battery category if these are provided to you.

However, the producer is only responsible for the costs of collecting the batteries that the producer itself provides on the Swedish market.

The producer must take back waste batteries directly from end users or from take-back and collection systems.

For portable batteries and batteries for light means of transport, collection points shall be established in cooperation with one or more of the following:

  • Distributors
  • Recyclers
  • Stakeholders who remove batteries from electrical equipment or vehicles
  • Municipalities
  • Voluntary collection points

For starter batteries, industrial batteries and electric car batteries, collection points shall be established in cooperation with:

  • Distributors
  • Recyclers
  • Stakeholders who remove batteries from electrical equipment or vehicles
  • Municipalities

A producer who collects its waste batteries itself needs to contact one or more of the stakeholders above to establish collection points to the extent deemed necessary to be able to collect its waste batteries. A producer of, for example, industrial batteries does not need to establish collection points with, for example, municipalities if there is good reason to believe that the waste industrial batteries will not be handed over to municipalities.

Please note that waste batteries may only be collected at collection points established together with a producer or producer responsibility organisation.

The collection covers the whole of Sweden and shall:

  • Be designed taking into account population size and density, expected volume of batteries, accessibility and proximity to end users.
  • Not be limited to areas where the collection and handling of waste batteries is profitable.

The producer shall:

  • Cover the necessary costs of the collection system.
  • Equip the collection system in accordance with applicable safety requirements. This includes using appropriate containers that are adapted to the volume of waste batteries collected and any hazardous properties.
  • Collect waste batteries as often as necessary taking into account storage capacity and any hazardous properties.
  • Ensure that the collected waste batteries are delivered to authorised facilities for treatment.

Producers who are authorised to fulfil their obligations shall cooperate with other such producers and producer responsibility organisations (PROs) on the allocation of waste costs. That is, the cost of collecting and treating battery waste, and the revenue from the sale of recycled material from the category of batteries that has been collected.

The allocation shall be made so that it:

  • corresponds to the producer's or affiliated producers' share of the market for new batteries of the category collected, measured by weight, or
  • is otherwise in reasonable proportion to the producer's or affiliated producers' activities.

Register with the Swedish Environmental Protection Agency

Companies that have producer responsibility for batteries are required to register and report their producer responsibility to the Swedish Environmental Protection Agency (EPA). The registration must be made before you first supply batteries on the Swedish market. You register through the Swedish EPA’s e-service, or if you are affiliated with a producer responsibility organization (PRO), via the producer responsibility organisation. If you have appointed a producer representative, the representative is responsible for the registration.

The application for registration must include the following information:

  • The producer's name, any trademarks that the producer uses in Sweden, address and contact details.
  • Personal or corporate identity number. If this is not available, the tax registration number must be provided. A producer who is not established in Sweden, but sells directly to end users in Sweden, must provide the VAT registration number instead.
  • The battery category(ies) that the producer intends to make available in Sweden.
  • A declaration that the information provided is truthful.

Information on how the producer fulfils its obligations under Article 56 on extended producer responsibility and the collection requirements under Articles 59–61 depending on which battery category the producer provides.

 

Register as a producer in the Swedish EPA’s e-service

If you believe that you are no longer a producer, you need to deregister with the Swedish Environmental Protection Agency (EPA). You may need to report and pay a supervision fee before deregistration can be carried out, depending on when your activity as a producer ceased.

If you are covered by producer responsibility in the future, you must register as a producer again.

If you have been active in the previous and current year, you need to submit a report for both business years before you can deregister. Email information about deregistration to customer service: kundtjanst@naturvardsverket.se 

Companies that have not been active during the current year

If you have been operating in the previous year, you need to submit a report for that year. Reporting is done via the e-service below.

Provide the following information to the Swedish EPA when deregistration:

  • company name,
  • organization number,
  • reason for deregistration,
  • date when the activity as a producer ceased,
  • date when you made your report for the previous year and
  • documentation that proves that you have reported.

Companies that have been active during the current year

If you have been operating in the current year, you need to submit a report for the current year. Reporting is done via the e-service below.

If you have been operating in the current year, a supervision fee needs to be paid. This is scheduled automatically and sent out continuously during the year.

After the report has been submitted and the supervision fee has been paid, you need to submit a deregistration to the Swedish EPA with the following information:

  • company name,
  • organization number,
  • the reason why your company should be deregistered,
  • date when the activity as a producer ceased,
  • date when you made your report for the current year and
  • documentation that proves that you have reported.

Report information to the Swedish Environmental Protection Agency

The first deadline for reporting according to the EU Battery Regulation is not until 31 March 2027 for batteries made available in Sweden in 2026.

Reporting in 2026 for batteries made available in 2025 will be done as in the past, according to the Regulation (2008:834) on producer responsibility for batteries.

The producer is ultimately responsible for ensuring that the reported information is correct. Even if you have agreed with someone else to report on your behalf, you are still responsible for ensuring that this is done and that the information is correct.

Producers are responsible for reporting the amount of batteries that the producer has made available on the Swedish market during the previous year.

A producer is also responsible for reporting the amount of batteries that have been collected and treated, i.e. how the waste has been treated.

This is stated in the provisions of Section 21 of the Regulation (2008:834) on producer responsibility for batteries (see SFS 2025:814).

When you report the amount of electrical equipment with built-in, integrated batteries sold, collected and treated, you state:

  • the total weight of the product including the battery in the report for electrical equipment
  • the weight of the battery in the battery report.

In other words, the amount of integrated batteries must be reported twice.

According to EU Regulation 493/2012, recycling facilities must report the recycling efficiency of the batteries they receive from producers within the EU. The report must be submitted to the Swedish Environmental Protection Agency (EPA) by 30 April for the previous year.

The reporting of the recycling rate from the facilities is in addition to the reporting that the producers do before 31 March.

Who should report?

For batteries recycled in Sweden: The recycling facilities must report the recycling rate to the competent authority (the Swedish EPA). 

For batteries that are fully or partially recycled outside Sweden: The stakeholder that supplies the recycling facility abroad with batteries, i.e. the exporter, is obliged to report to the Swedish EPA.

What should be reported?

The recycling rate per battery type for batteries received at the facility during the previous year from one or more producers, and how that recycling rate has been calculated. However, the facility or exporter does not need to know whether a specific producer's batteries have actually undergone all steps in the recycling process. They must have been received by the facility and not be in intermediate storage.

The information requested is provided in ready-made templates in the annexes to Regulation 493/2012, see link below.

You do not need to report to the Swedish EPA if no waste batteries have been sent to a recycling facility for the year to which the report applies.

Template for reporting and guidance from the EU Commission.

To access the reporting templates, please see the EU Regulation and the guidance from the EU Commission.

EU Regulation No 493/2012, provisions on the calculation of the recycling rate in the recycling processes for waste batteries and accumulators (europa.eu)

How to report

Use the reporting templates and send them to kundtjanst@naturvardsverket.se 

The reports enable the Swedish Environmental Protection Agency (EPA) to review compliance with producer responsibility. The reports also form the basis for the statistics that are produced and forwarded to Eurostat and contribute to the national statistics published by Statistics Sweden. This provides information on the quantities made available for the first time and to what extent we collect and recycle waste batteries in Sweden.

E-service for producer responsibility

Here companies can register as producers and report information to the Swedish EPA. Here the company can also change invoice or contact details or obtain proof of registered producer responsibility.

Questions and answers

The most common reason is that the collection system has not submitted the report to us, but that you as a producer have already reported your data to the collection system. A common misconception is that this is in turn automatically submitted to us at the same time as you submit this information to your collection system. The majority of reports from the collection systems are received in March. This means that the reminder from us has already been sent to all producers in the register, and these producers will also receive a reminder email as there is no report registered for them in our system.

It may also be that you are a producer of both electrical equipment and batteries, and therefore they must be reported separately. This means that we may have only received one of these and you as a producer have received a reminder for the other. The reminder email will indicate which producer responsibility system we have not received the report for.

This means that you need to update your registration, which can be done by clicking on "Batteries" on the home page or via "Producer Responsibility" and "Batteries". On that page there is a button called "Change registration". There you can add or remove battery types. You can only report under the battery types that are in the registration.

Please note that you must notify your collection system of any changes to the product categories you place on the market if you report via one.

If you are unsure about what is covered by your agreements with your collection system, e.g. whether it includes reporting and applies to both electrical equipment and batteries, please contact your collection system in the first instance. The collective collection systems are El-Kretsen, Recipo and Blybatteriretur.

If you are a producer and are registered with us, you need to report even if you did not sell anything the previous year. If you will not continue to sell anything for the current year or collect waste batteries, you can choose to deactivate the registration by contacting the Swedish Environmental Protection Agency's customer service. First, note the information about deregistration further up the page.

If your company has batteries that have been sold during the current year, you can report this in advance via the e-services for producer responsibility.

Data for the amount of battery waste treated should correspond to how the waste has actually been processed, i.e. how much has been recycled, incinerated, disposed of or similar. The data should be based on information from the treatment facilities, either directly or via a waste actor. It is therefore not about how much is sent for recycling, for example, but how much is actually recycled until the waste is finally processed. If 100 tonnes of waste are collected and sent to a recycling facility with a material recycling rate of 50%, you must report 50 tonnes of material recycled and how the remaining 50 tonnes have been treated.

Please note. The amount collected must be reported in the year the waste was collected and treated in the year the waste was treated. This can mean that collected waste is reported in year X and treated waste is reported in year X+1.

All waste that has been treated outside Sweden must be reported as “Transported out of Sweden” and also how it has been treated.

Disposed of means landfill or incineration that does not generate any energy. If the waste has not undergone waste treatment, it should not be reported as treated.

Information requirements

As a producer who is not affiliated with a producer responsibility organization (PRO), you must provide end users and distributors with information on how end-users can contribute to waste prevention and waste battery management for the categories of batteries that you supply on the Swedish market:

  • Information on how end-users can contribute to waste prevention. Including how batteries can be used for as long as possible and how they can be recycled.
  • Information on the role of end-users in the collection of used and waste batteries.
  • Information on available collection points for used and waste batteries.
  • Which facilities for recycling and preparation for recycling are available.
  • Necessary safety instructions for handling waste batteries.
  • Information on what labels and symbols on batteries mean.
  • Information on how the substances contained in batteries affect the environment and human health and the safety of individuals.
  • The importance of reducing littering.

Producers are responsible for making the information available to distributors. However, distributors are responsible for how the information is subsequently made available.

The information shall be made available by distributors:

  • Regularly from the time the batteries are made available on the Swedish market.
  • Permanently, easily accessible and visible at both points of sale and online platforms.
  • In Swedish

The costs of producer responsibility covered by the producer shall be reported separately to the end-user at the point of sale of a new battery.

As a producer, who is not affiliated with a producer responsibility organisation, you shall carry out information campaigns or offer incentives to prevent waste and encourage the separate collection of waste batteries.

You as a producer shall also provide distributors, operators collecting waste batteries and waste management operators with access to information on safety and protection measures for the storage and collection of waste batteries.

Furthermore, as a producer, you shall provide waste management operators, upon request, with free access to information on a specific battery model to enable dismantling. The information shall be provided free of charge and electronically. This information shall include various safety and protection measures. If necessary for treatment, it must also be stated which components and materials are included and where any hazardous substances are located in the battery. This information can be in Swedish or English.

Definitions

Any natural or legal person dealing on a professional basis with 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.

The basic functional unit in a battery, composed of electrodes, electrolyte, container, terminals and, if applicable, separators, and containing the active materials the reaction of which generates electrical energy.

Any set of battery cells that are connected together or encapsulated within an outer casing to protect the cells against external impact, and which is meant to be used either alone or in combination with other modules.

Any set of battery cells or modules that are connected together or encapsulated within an outer casing, to form a complete unit which is not meant to be split up or opened by the end-user.

Any operation carried out on waste batteries after they have been handed over to a facility for sorting, preparation for re-use, preparation for repurposing, preparation for recycling or for recycling.

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:

  •  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.
  • 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.
  • 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
  • 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.