Swedish solar industry association Svensk Solenergi said it and battery producer responsibility organization (PRO) Batterikretsen have sent a joint request to the Swedish Environmental Protection Agency (Naturvårdsverket), asking it to petition the government to task transmission system operator Svenska kraftnät with checking producer-responsibility compliance when battery storage systems prequalify for ancillary services.
Producer responsibility is intended to secure financing for the future collection and recycling of batteries and should be shared fairly among all companies that place products on the market, said Svensk Solenergi. It added that compliance is difficult to supervise in a fast-growing industry with many new players, complex supply chains and numerous, widely dispersed installations.
According to the association, prequalification for Svenska kraftnät’s ancillary services is a checkpoint that in principle all commercial battery storage systems pass through. A check at that stage would give Naturvårdsverket an effective enforcement tool against companies that place battery systems on the market without paying the required environmental fee, it said.
Svensk Solenergi said that because ancillary service markets are a key revenue source for most battery storage systems, such a check could in practice make it impossible for systems participating in those markets to avoid producer responsibility.
The association said Svenska kraftnät had previously told it that it lacks the mandate to carry out such checks, but that there would be no practical obstacles if it were given one. It added that implementation of the European Union’s forthcoming network code on demand response offers an opportunity, as the national qualification process is due to be rebuilt in the coming years, allowing the check to be built in from the start.
Rule changes
Producer-responsibility provisions under the EU Batteries Regulation took effect on Aug. 18, 2025, and cover industrial batteries, which include stationary storage. Under Swedish rules, producers must register with Naturvårdsverket and either join an approved PRO or be individually approved before supplying batteries. Naturvårdsverket has approved three such organizations: Batterikretsen, Batteriretur Sverige and FoRetur.
Svensk Solenergi has previously said Sweden’s ancillary services markets, particularly frequency containment reserve (FCR), have driven a storage-first trend, with developers installing batteries to earn frequency regulation and arbitrage revenue before adding solar. Recent projects include the 70 MW/160 MWh Ånge battery, which entered commercial operation this year.
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