http://o54hon2e2vj6c7m3aqqu6uyece65by3vgoxxhlqlsvkmacw6a7m7kiad.onion/en/help/the-new-electronic-communications-act-lek-sweden
This suggests that a VPN service is also not to be considered as an electronic communications service since, according to the previous positions, the service does not, wholly or mainly, have control, either physical or contractual, over the signal transmission that enables the service to be used.