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Producer responsibility for batteries

Batterier

Waste management operators

Last reviewed: 26 September 2025

The information on this page will help you determine whether you are a waste management operator and explain your responsibilities if so.

The purpose of producer responsibility for batteries is to prevent batteries from becoming waste and to make the best possible use of the batteries when they are no longer usable. The role of the waste management operator is to help producers fulfil their obligations by collecting or treating waste batteries in accordance with the requirements set out in the legislation.

Target group

Companies or others who have been selected by the producer or producer responsibility organisation to collect or treat waste batteries. The page is also aimed at those who intend to export waste batteries. Operators who treat waste batteries for recycling should also read the information on the page for recycling operators.

Good to know

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

News

From 18 August 2025, a new battery regulation will apply at EU level, which means, among other things: changed rules regarding producer responsibility and waste management.

Important changes (but not all changes) are:

  • New definitions, including producer.
  • New categories of batteries, including the categories of electric car batteries and batteries for light means of transport (electric scooters and electric bicycles).
  • The role of producer responsibility organization is introduced, for the collective fulfillment of the obligations regarding extended producer responsibility. Producer responsibility organizations will have greater responsibility than the organizations that are currently responsible for collective collection systems.
  • Both producer responsibility organizations and producers who do not appoint a producer responsibility organization, but choose to fulfill obligations regarding extended producer responsibility themselves, need to be approved by the Swedish Environmental Protection Agency.
  • Only waste operators selected by the producer or producer responsibility organization may collect or treat battery waste.
  • All operators who collect waste batteries must hand them over to the producer or producer responsibility organization, or a waste operator selected by the producer or producer responsibility organization.
  • Specific provisions on battery recycling.
  • Waste management operators that recycle batteries will be responsible for achieving the recycling targets and reporting the recycling to the Swedish Environmental Protection Agency.
  • Tougher requirements regarding the export of battery waste, especially if you want the treatment to count towards the recycling targets.
  • New requirements for treatment and storage.
  • Increased requirements for information for end users, waste management operators and recyclers.
  • Requirements for distributors that 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 certain battery metals.

Batteries covered - three exceptions

Producer responsibility covers all batteries, regardless of design, chemistry or area of use, with very few exceptions. This means, for example, that batteries that are 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 exemptions 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.

Note, for example, that a battery that weighs 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 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
  • Batteries for light means of transport
  • Industrial batteries
  • Starter batteries
  • Electric vehicle batteries

Is your company a waste management operator?

Waste management operators in the Battery Regulation are companies and others who:

  • Professionally collect or treat waste batteries.
  • Selected by the producer or producer responsibility organization to collect or treat waste batteries.

This means that only waste management operators selected by a producer or producer responsibility organisation may collect waste batteries.

Companies carrying out material recycling in an approved facility are also considered a material recyclers.

Several important concepts are explained at the end of the page under Definitions. Note, for example, that there is a difference between preparation for material recycling and material recycling.

How are waste management operators selected?

In order for you to be able to collect or treat waste batteries, you as a waste management operator need to have been selected by a producer or producer responsibility organisation.

The selection of the waste management operator must be made on non-discriminatory grounds based on transparent award criteria. The selection procedure must not place a disproportionate burden on small and medium-sized enterprises.

What do transporters of waste batteries need to do?

Treatment of waste batteries may be carried out outside Sweden and the EU provided that the waste batteries are transported in accordance with the requirements of Regulations (EC) No 1013/2006 and (EC) No 1418/2007.

Exports of waste batteries for treatment outside the Union can only count towards the recycling targets if documentation is provided showing that the treatment took place under conditions equivalent to those required by the Battery Regulation. This documentation must come from the competent authority of destination and also demonstrate compliance with other Union law on the protection of health and the environment.

Used batteries or waste?

It is particularly important to distinguish between the transport of used batteries and waste batteries. Only with certain exceptions, as specified in point 2 of Annex XIV to the Battery Regulation, is it required that the person intending to transport or transporting used batteries be able to present the following:

  • A copy of the invoice and the contract confirming the transfer of ownership of the batteries. This shall indicate that the equipment is intended for direct reuse and that the used batteries are fully functional.
  • A copy of the results as evidence of the assessment or testing carried out and the report containing all documentation in accordance with point 3 of Annex XIV to the Battery Regulation.
  • A declaration that none of the materials or equipment included in the consignment is waste as defined in Article 3(1) of Directive 2008/98/EC.
  • Adequate protection against damage during transport, loading and unloading, in particular by adequate packaging and appropriate stacking of the load.
  • A relevant transport document.
  • A declaration of liability from the person responsible.

The competent authorities of the Member States may inspect and monitor shipments of used batteries suspected of being waste batteries. The person holding the batteries shall be able to demonstrate that the batteries are not to be considered waste and are not waste.

The competent authority may consider the batteries to be waste if it cannot be demonstrated that they should be considered used or if the protection against damage during transport, loading and unloading is not adequate. The transport shall then be considered illegal and shall be dealt with in accordance with Articles 24 and 25 of Regulation (EC) No 1013/2006. The costs of analysis, inspection and storage of the batteries may be charged to the producer, third parties acting on behalf of the producers or others organising the transport if the competent authority considers that the transport contains used batteries which are waste.

Setting up collection systems for waste batteries

Collection systems are usually set up by a producer responsibility organisation. A producer may choose not to appoint an approved producer responsibility organisation but must then meet the same requirements.

Batteries incorporated into electrical equipment or vehicles may be collected by a collection system for electrical equipment or vehicles. When the batteries are removed the collection requirements for batteries apply and they need to be handed over to a producer or producer responsibility organization. 

The producer or producer responsibility organization 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 the producer or producer responsibility organization must design a collection system to be able to collect all of the producers' waste batteries. In addition, as a producer or producer responsibility organization, you cannot refuse to accept other producers' waste batteries within your battery category if these are handed over to them. However, producers are only responsible for the costs of collecting the batteries that they themselves provide on the Swedish market.

The producer or producer responsibility organization 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, the collection system shall be established in cooperation with:

  • Distributors
  • Recyclers
  • Actors who remove batteries from electrical equipment or vehicles
  • Municipalities
  • Voluntary collection sites

For starter batteries, industrial batteries and electric vehicle batteries, the collection system shall be established in cooperation with:

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

The collection covers all 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 for the collection system.
  • Equip the collection system in accordance with applicable safety requirements. This includes using appropriate containers that are appropriate for 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 waste batteries collected are delivered to approved facilities for treatment.

What do waste treatment operators need to do?

Collected waste batteries must not be disposed of or incinerated. This includes batteries collected while still in an end-of-life appliance, end-of-life light means of transport or end-of-life vehicle.

Companies or others treating waste batteries must:

  • Handle the waste in areas with impermeable surfaces, appropriate weatherproof covering and with appropriate containers.
  • Take special precautions and safety measures to protect against exposure to excessive heat, water and physical damage.
  • Carry out the treatment in accordance with the requirements of best available techniques.
  • Remove all liquids and acids during treatment.
  • Separate mercury and cadmium into identifiable streams that are managed responsibly and disposed of in a manner that is safe for people and the environment.
  • Avoid mixing them with waste from conductive or combustible materials.
  • Store spent lithium-based batteries in their normal installation orientation, in a well-ventilated area and covered with high-voltage rubber insulation.
  • Provide storage facilities for spent lithium-based batteries with a warning.

What do end-of-life vehicle and electronic waste processors need to do?

Companies and others operating facilities for the treatment of end-of-life vehicles or electrical and electronic waste (WEEE) must hand over batteries resulting from the treatment to battery producers, designated producer responsibility organisations or designated waste management operators in accordance with the Battery Regulation. Records must be kept of the handover transactions that take place.

If batteries are collected while still in an end-of-life appliance or end-of-life vehicle, they must be removed.

What do recyclers need to do?

Companies or others who operate a facility approved for the recycling of waste batteries must ensure that all batteries made available to the facility undergo recycling.

Recyclers must ensure that recycling achieves the recycling rate and resource recovery targets.

Recyclers must also report data to the Swedish Environmental Protection Agency annually. The details of how the recycling rate is calculated and reported and the form used is covered by secondary legislation (delegated act) developed by the European Commission.

By 31 December 2025, recycling must achieve at least the following recycling rate targets (entire battery):

  • 75% of the average weight of lead-acid batteries.
  • 65% of the average weight of lithium-based batteries.
  • 80% of the average weight of nickel-cadmium batteries.
  • 50% of the average weight of other waste batteries.

By 31 December 2027, all recycling shall achieve at least the following resource recovery targets (certain substances):

  • 90% for cobalt.
  • 90% for copper.
  • 90% for lead.
  • 50% for lithium.
  • 90% for nickel.

By 31 December 2030, recycling shall achieve at least the following material recovery rate targets (entire battery):

  • 80% of the average weight of lead-acid batteries.
  • 70% of the average weight of lithium-based batteries.

By 31 December 2031, all recycling shall achieve at least the following resource recovery targets (certain substances):

  • 95% for cobalt.
  • 95% for copper.
  • 95% for lead.
  • 80% for lithium.
  • 95% for nickel.

Report data to the Swedish Environmental Protection Agency (EPA)

Reporting to the Swedish EPA according to the EU Battery Regulation will not take place until 31 March 2027 for batteries supplied in Sweden in 2026. The reporting shall be calculated and reported according to a delegated act which can be found under the heading “Legislation” further up on this page.

The reporting that recycling facilities and exporters must do according to Regulation 493/2012 also applies in 2026 for batteries treated in 2025.

The producers' reporting in 2026 for batteries supplied in 2025 will take place as before according to Regulation (2008:834) on producer responsibility for batteries.

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). This applies to the batteries that they received in 2022 for recycling.

For batteries that are fully or partially recycled outside Sweden: The actor who 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 given in ready-made templates in the annexes to Regulation 493/2012, see link below.

You do not need to report to the Swedish Environmental Protection Agency 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

For more information and 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 to review compliance with producer responsibilities. 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 placed on the market and the extent to which we collect and recycle waste batteries in Sweden.

Definitions

Any natural or legal person dealing on a professional basis with the separate collection or treatment of waste batteries.

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.

The ratio, expressed as a percentage, obtained by dividing the mass of output fractions accounting for recycling by the mass of the waste batteries’ input fraction, in relation to a recycling process.

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.