Swedish Battery Act Requires an Authorised Representative

New EPR Requirements

Following the entry into force of the new EU Battery RegULation, the updated EPR requirements by the Swedish Environmental Protection Agency are as follows:

(1) Joining an Authorised PRO

Producers must appoint a producer responsibility organisation (PRO) authorised by the authorities, or apply for authorisation to manage EPR requirements independently. This authorisation requirement shall enter into force on 1 January 2026.

(2) New Definition of Producers and Battery Categories

In accordance with the new EU Battery Regulation, the Swedish authorities have clarified the definitions of batteries and producers, and abolished the exemption for small producers.

(3) Authorised Representative:

Producers established outside Sweden that sell batteries, battery-containing products and vehicles directly to end-users in Sweden shall appoint an authorised representative through written authorisation (the registration under the previous Swedish Battery Act did not require an authorised representative).

Other Information

About Producer Responsibility Organisations (PROs)

PROs fulfil declaration and recycling obligations on behalf of producers. A PRO typically recycles one or more categories of waste batteries, but not all categories. Therefore, you may need to join one or more PROs.

About the Definition of a Producer

In most cases, the company or other entity that first places batteries on the Swedish market shall be deemed the producer of such batteries.

Unsure whether you qualify as a producer? You may refer to the scenarios below for determination.

If the answer to any of the above is "Yes", you are consideRED a producer under the definition of the Swedish Battery Act and are required to fulfil battery EPR obligations.

New Battery Categories

In line with the requirements of the new EU Battery Regulation, the Swedish authorities have classified batteries into 5 categories, adding new categories for electric vehicle batteries and light means of transport (electric bicycles and e-scooters) batteries. In addition, the definitions of battery categories have been slightly revised.

Details are as follows:

①　Portable batteries: weighing no more than 5 kg

②　Light means of transport batteries: including electric bicycles and e-scooters

③　Industrial batteries: designed exclusively for industrial use (regardless of weight)

④　Starter batteries: not limited to batteries in motor vehicles

⑤　Electric vehicle batteries

What Do I Need to Do as a Seller?

For Sellers Already Registered Under the Swedish Battery Act

Sellers are required to contact their EPR compliance service provider to confirm registration information (including authorised representative and PRO details, etc.). Users who have updated their authorised representative and PRO information will be notified accordingly.

If you have not completed the update, please stay tuned and request your EPR service provider to notify you immediately upon completion of the update. JJR LAB will also continue to monitor the new official requirements in Sweden and promptly inform sellers of new compliance needs and compliance progress.

For Sellers Not Yet Registered Under the Swedish Battery Act

The new EU Battery Regulation officially entered into force on 18 August 2025. Sellers are required to contact their EPR compliance service provider to complete registration and all compliance procedures in accordance with the official Swedish EPR requirements as soon as possible.

JJR LAB has assisted numerous clients in achieving Swedish EPR compliance and obtaining registration certificates.