Selling batteries B2B into Sweden is not an exemption

Selling batteries B2B into Sweden does not mean you avoid producer responsibility here.

Under the EU Battery Regulation, what matters is not whether your customer is a business or a consumer. What matters is whether the Swedish buyer resells the batteries or uses them itself, and who brings them into the country.

→ You sell to a Swedish wholesaler, reseller or importer: the Swedish buyer is the producer. No authorised representative needed on your side.

→ You sell to a Swedish manufacturer that builds the batteries into its own products: same thing, the buyer is the producer.

→ You sell directly to Swedish consumers through a web shop or marketplace: you are the producer, and you need an authorised representative in Sweden.

→ You sell directly to a Swedish company that uses the batteries itself, and you handle the delivery: you are also the producer. Professional users count as end-users.

The last case is the one most often missed. A German or Polish supplier delivering industrial batteries to a Swedish factory can easily assume it is “just B2B”.

Since 1 January 2026 a producer must also be affiliated with an approved producer responsibility organisation before placing batteries on the Swedish market. Getting this wrong is not a paperwork detail.

If you are unsure which case applies to you, look at your delivery terms first. They often decide it.

At STRUKT we act as authorised representative in Sweden for packaging, electrical equipment and batteries, independent of the Swedish producer responsibility organisations. Questions: contact@strukt.se or +46 707 61 73 46.

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Terms to check before joining a Swedish PRO