May 26, Spin-off of Husqvarna Professional Outdoor Products, Inc., and Husqvarna Outdoor Products Inc., to AB Electrolux

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1 4900 Key Tower 127 Public Square Cleveland, OH Office: Fax: Electrolux Holdings, Inc Emerald Parkway, S.W. Suite 250 P.O. Box Cleveland, Ohio Re: Spin-off of Husqvarna Professional Outdoor Products, Inc., and Husqvarna Outdoor Products Inc., to AB Electrolux Ladies and Gentlemen: You have asked for our opinion (the Opinion ) with respect to certain of the U.S. federal income tax consequences of a spin-off transaction (the Spin-off ) that will begin when Electrolux Home Products, Inc., a Delaware corporation ( EHP ), contributes all of the assets of its Outdoor Products Business, as such is defined in the Request for Rulings, to Husqvarna Outdoor Products Inc., a newly created Delaware corporation ( HOP ), in exchange for all of the outstanding stock of HOP. All of the outstanding common stock of EHP is owned by Electrolux Holdings, Inc., a Delaware corporation ( EHI ), and all of the outstanding stock of EHI is owned by AB Electrolux, a Sweden corporation ( ABE ) whose stock is publicly traded on the Stockholm stock exchange. Pursuant to a common plan, shortly after EHP s transfer of the assets of its Outdoor Products Business to HOP, EHP will distribute 100 percent of the outstanding HOP stock to EHI (the First Distribution ). Immediately after the First Distribution and pursuant to a common plan, EHI will distribute to ABE all of the outstanding stock of HOP and of Husqvarna Professional Outdoor Products, Inc., an Ohio corporation ( HPOP ) all of the outstanding stock of which will owned by EHI immediately before such distribution, to ABE (the Second Distribution ). HPOP is also in the Outdoor Products Business. After the Second Distribution, ABE intends to contribute all of the stock of HOP and HPOP that it received in the Second Distribution, plus the stock of other corporations that conduct the Outdoor Products Business in countries outside the United States as well as certain other assets that are part of its worldwide Outdoor Products Business outside the United States, to Husqvarna AB, a Sweden corporation ( HAB ) all of the outstanding stock of which is owned by ABE. After the contribution of stock and assets to HAB, the Spin-off will conclude with ABE s distribution of all of the stock of HAB pro rata to all of the shareholders of ABE (the External Distribution ). (The First Distribution, Second Distribution, and External Distribution will be referred to as the Constituent Transactions. ) We have worked with you in obtaining a private letter ruling (the Private Letter Ruling ) from the Internal Revenue Service ( IRS ) that the Spin-off transaction will result in no taxable CINCINNATI CLEVELAND COLUMBUS HOUSTON LOS ANGELES MIAMI NEW YORK PALO ALTO PHOENIX SAN FRANCISCO TALLAHASSEE TAMPA TYSONS CORNER WASHINGTON DC WEST PALM BEACH CARACAS RIO DE JANEIRO SANTO DOMINGO BRATISLAVA BRUSSELS BUDAPEST FRANKFURT LONDON MOSCOW PRAGUE WARSAW BEIJING HONG KONG SHANGHAI TOKYO ASSOCIATED OFFICES: BUCHAREST BUENOS AIRES DUBLIN KYIV MILAN SANTIAGO

2 Page 2 income, gain, or loss, for U.S. federal income tax purposes, to EHP, EHI, ABE, or the ABE shareholders. However, pursuant to its regular policy, the IRS reserved ruling on two of the legal issues that are necessary to the final conclusion that the Spin-off will not result in any U.S. federal taxable income, gain, or loss to EHP, EHI, ABE, or the ABE shareholders. The first such reserved issue is whether the Spin-off is motivated by a substantial non-federal-tax corporate business purpose that satisfies the corporate business purpose requirement prescribed in Section (b) of the U.S. Treasury Regulations ( Treasury Regulations ) (the Business Purpose Requirement ). The second reserved issue is whether the Spin-off is used principally as a device for the distribution of the earnings and profits of any of the corporations that participated in the First Distribution, the Second Distribution, or the External Distribution, as described in Section 355(a)(1)(B) of the Internal Revenue Code of 1986, as amended ( Code ), and Section (d) of the Treasury Regulations (the Device Requirement ). You have requested the Opinion with regard to whether the Spin-off will satisfy the Business Purpose Requirement and the Device Requirement. Statement of Facts The facts we regard as relevant to the Opinion include those set forth in the first two paragraphs of this letter and further detailed in the Request for Rulings submitted to the IRS on February 1, 2005, and dated January 31, 2005, (the Request for Rulings ) and the information submitted to the IRS in support of the Request for Rulings on April 1, 2005, April 3, 2005, April 28, 2005, and June 8, 2005, all of which are incorporated herein by reference. In addition, we regard as relevant to the Opinion, and treat as incorporated in this statement of facts by reference, those facts set forth in the factual assumptions and representations identified below. We have identified these facts in the course of our extensive discussions with representatives of ABE, EHI, and EHP in the course of assisting those companies in securing the Private Letter Ruling and in advising those companies with respect to various issues relating to the Spin-off. Documents Examined In connection with the rendering of the Opinion, we have examined and relied upon the following: 1. The Private Letter Ruling issued by the IRS with respect to the Spin-off; 2. The Request for Rulings, as well as the other materials submitted to the IRS on April 1, 2005, April 3, 2005, April 28, 2005, and June 8, 2005, for the purpose of obtaining the Private Letter Ruling;

3 Page 3 3. The prospectus that ABE issued to its shareholders in connection with the External Distribution; 4. The Representation Certificate, dated as of the date hereof, of ABE, EHI, and EHP; 5. The Master Separation Agreement between ABE and HAB, dated September 9, 2005; 6. The Tax Sharing and Indemnity Agreement between ABE, EHI, EHP, HAB, HPOP, and HOP, dated as of April 5, 2006; and 7. Such other documents, records, and matters of law as we have deemed necessary or appropriate in connection with rendering the Opinion. In our review and examination of the foregoing, we have assumed the genuineness of all signatures, the authenticity of all documents submitted to us as originals, the conformity to authentic original documents of all documents submitted to us as certified, conformed or photostatic copies thereof, the legal capacity of all natural persons, and the due execution and delivery of all documents by the signatories thereto. We have further assumed that the execution and delivery of any of the foregoing have been duly authorized by all necessary corporate actions in order to make the foregoing valid and legally binding obligations of the parties, enforceable in accordance with their terms, except as enforcement thereof may be limited by bankruptcy, insolvency, reorganization, moratorium, or other similar laws whether state, federal, or foreign affecting the enforcement of creditors' rights or remedies in general from time to time in effect and the exercise by courts of equity powers or their application of principles of public policy. Factual Assumptions In rendering the Opinion, we have made, in addition to the assumptions referenced in the section entitled Documents Examined, the following assumptions as to factual matters. 1. The Representation Certificate of ABE, EHI, and EHP, as referenced in the section entitled Documents Examined, is executed and delivered to us prior to the Spin-off in the form that we have heretofore tendered it; 2. The representations as to factual matters contained herein and in the Representation Certificate are all true, correct, and complete in all material respects as of the effective date of each of the Constituent Transactions and

4 Page 4 thereafter and no actions have been taken before the Spin-off (or will be taken during or after the Spin-off) that are inconsistent with such representations; 3. Any representation or statement made in any of the documents referred to herein to the best of the knowledge of any person or party or otherwise similarly qualified is true and correct as if made without such qualification; 4. All statements, descriptions and representations contained in any of the documents referred to herein or otherwise made to us are true, correct, and complete in all material respects as of the effective date of each of the Constituent Transactions and thereafter and no actions have been taken before the any of such distributions (or will be taken thereafter) that are inconsistent therewith; 5. The Spin-off and all transactions related thereto will be consummated in accordance with the terms and conditions of the applicable documents (without any waiver, breach or amendment of any provision thereof), and there are no material documents other than those referenced herein, in the Representation Certificate, or in the Request for Rulings; and 6. All transactions in any way related to the Spin-off will be reported by all relevant parties on their respective U.S. federal income tax returns in a manner consistent with the Opinion. In the course of our extensive discussions with representatives of ABE, EHI, and EHP in connection with the preparation of the Request for Rulings and other documents submitted in the process of obtaining the Private Letter Ruling and in numerous other discussions we have had with such representatives with respect to the various transactions that comprise the Spin-off, we have determined that each of the foregoing factual assumptions is reasonable. Representations 1. All representations and statements of fact included in the Request for Rulings, as well as any exhibits thereto, that was filed with the IRS on behalf of ABE, EHI, and EHP (the Distributing Corporations ) are true, correct, and complete and may be relied on by Squire, Sanders & Dempsey L.L.P. ( SS&D ) for purposes of the Opinion. 2. All representations and statements of fact included in the Private Letter Ruling that the IRS issued to the Distributing Corporations on June 27, 2005, are true, correct, and complete, and may be relied on by SS&D for purposes of the Opinion.

5 Page 5 3. All representations and statements of fact included in the correspondence submitted to the IRS on April 1, 2005, April 3, 2005, and April 28, 2005, including any exhibits thereto, in support of the Request for Rulings are true, correct, and complete, and may be relied on by SS&D for purposes of the Opinion. 4. All representations and statements of fact included in both items of correspondence submitted to the IRS on June 8, 2005, including any exhibits thereto, in support of the Request for Rulings are true, correct, and complete, and may be relied on by SS&D for purposes of the Opinion. 5. The business purpose for the Spin-off is as stated at pp. 8, 32, and 41 of the Request for Rulings. The Spin-off is substantially motivated by such business purpose. 6. There is no plan or intention that any officer of ABE will also be an officer of HAB, and there will in fact be no overlap in the officers of ABE and HAB for at least two years following the Spin-off. There is no plan or intention that more than one person who is a director of ABE will also be a director of HAB, and there will in fact be no additional overlap in the directors of ABE and HAB for at least two years following the Spin-off. 7. There is and will be no transaction that has occurred after the filing of the Request for Rulings or that will occur in connection with the Spin-off in which ABE will receive any consideration from HAB other than stock of HAB or the assumption of ABE debt by HAB, and in any event such consideration will be received only in a transaction in which no gain or loss would be recognized for U.S. federal income tax purposes. 8. To the best of the knowledge of the management of ABE, there is no plan or intention by any shareholder of ABE to sell, exchange, transfer by gift, or otherwise dispose of any of its stock in either ABE or HAB in connection with the Spin-off. 9. There is no plan or intention by either ABE or HAB, directly or through any subsidiary corporation or any other related party, to purchase any of the stock of any Distributing Corporation or any stock of HPOP, HOP, or HAB (each a Controlled Corporation and collectively the Controlled Corporations ) outstanding after the Spin-off. 10. HAB has no plan or intention to sell or otherwise dispose of any of the stock of HPOP or HOP. ABE has no plan or intention to sell or otherwise dispose of any of the stock of EHI or to cause EHI to sell or otherwise dispose of any of the stock of EHP. EHI has no plan or intention to sell or otherwise dispose of any of the stock of EHP.

6 Page There is no plan or intention to liquidate any of the Distributing Corporations or any of the Controlled Corporations, to merge any of such corporations with any other corporation, or to sell or otherwise dispose of the assets of any of the Distributing Corporations or Controlled Corporations after the Spin-off or after any of the Constituent Transactions, except in the ordinary course of business. 12. The managements of ABE, EHI, and EHP believe that the amount of cash plus the value of investment assets and the value of any other assets held by each of the Distributing and Controlled Corporations that are not directly used in either the Outdoor Products Business or the Indoor Products Business, as each is defined in the Request for Rulings, does not exceed the reasonable needs of each such corporation for working capital for its respective business. 13. The individuals who have executed the Representation Certificate are authorized to make all the representations set forth therein on behalf of ABE, EHI, and EHP, respectively. Each capitalized term used above and not otherwise defined shall have the meaning assigned thereto in the Representation Certificate. In the course of our extensive discussions with representatives of ABE, EHI, and EHP in connection with the preparation of the Request for Rulings and other documents submitted in the process of obtaining the Private Letter Ruling and in numerous other discussions we have had with such representatives with respect to the Constituent Transactions, we have determined that each of the foregoing factual representations is reasonable. 1. The Business Purpose Requirement Relating Law to Facts Both in the Request for Rulings and in the Representation Certificate, ABE has represented that it is undertaking the Spin-off because its senior management has determined that the company s two fundamental businesses the Indoor Products Business and the Outdoor Products Business have reached a critical point in their respective markets requiring the implementation of very different strategic business plans. ABE s senior management has concluded that the success of each of those plans will require the undivided attention and commitment of the management team. As a result, senior management is concerned that the successful implementation of each of these strategic plans may be compromised if the management team is distracted by fulfilling the needs of the other. After extensive discussions with representatives of ABE with regard to this business purpose, we have concluded that this representation is reasonable and accurate. The Spinoff is the only non-taxable transaction that will allow separate senior management teams to develop and execute the distinctive strategic plan that each of the two businesses requires, without being

7 Page 7 distracted by the predictable complexities that will be encountered in executing the different strategic plan of the other business. In this regard, the circumstances of the Spin-off are remarkably similar to the facts addressed in Rev. Rul , C.B. 77, where the distributing corporation conducted both a software business and a paper products business. The software business was believed to present the better prospects for growth, but the paper products business demanded management attention because of its continuous need to attain increased efficiencies in productivity. The ruling states that the managers of each of the businesses believed that the disproportionate attention that senior management devoted to the other business prevented their business from receiving the management resources required for its full development. The statements in Rev. Rul with respect to the software business could well be made with regard to ABE s Outdoor Products Business, and the statements in the ruling with regard to the paper products business could well be made with respect to the Indoor Products Business. The ruling states that after the spin-off, no officer will serve both Distributing and Controlled. However, two of Distributing s eight directors will also serve on Controlled six-person board. In the present case, there will be no overlap between the officers of ABE and the officers of HAB after the Spin-off, and it is represented that only one person will serve as a director of both HAB and ABE. This overlap in the directors of the two corporations constitutes only a small minority of each board, as the IRS found immaterial in Rev. Rul The only potential difference between the facts of the present case and the facts in Rev. Rul is that there are two shareholders each with approximately 5 percent by value of all of ABE s stock (taking into account both outstanding classes of common stock) who will also be stockholders with the same percentage holding by value of HAB stock, whereas the facts of the Rev. Rul did not reveal whether there was any overlap in major shareholders between Distributing and Controlled. Nevertheless, nothing in Rev. Rul suggests that such overlap in major shareholders should be material when the overwhelming majority of the shareholders of both corporations will be a widely dispersed public group and when the managements of the two companies will have no overlap. Moreover, in Rev. Rul , C.B. 79, the IRS considered a similar fit and focus fact pattern where Distributing had a shareholder who owned six percent of its stock. In that ruling, the IRS, with very little commentary, dismissed the significance of such a large shareholder simply by noting that such a shareholder does not actively participate in the management or operations of Distributing or Controlled. On the facts presented in the Request for Rulings, none of the large ABE shareholders serves as an officer of ABE or will serve as an officer of HAB. Indeed, as noted in the Request for Rulings, one of those large shareholders is not even a natural person but rather is itself a publicly traded investment company. It is not presently contemplated that either of the two large ABE shareholders will serve on the board of directors of either corporation. However, even if one or both of such shareholders were at some point in the future to serve on the board of one or both of ABE and HAB, that by

8 Page 8 itself should not constitute active participation in the management or operations of the company. In discounting the significance of a small overlap in board members on the facts of Rev. Rul , the IRS implicitly acknowledged that such minority board membership did not without more constitute active participation in the management or operations of the corporation. As noted above, there is no current plan or expectation that there will be any overlap in the management teams of ABE and HAB that will undertake to develop, refine, and execute their respective strategic plans. Accordingly, we conclude that the Spin-off is substantially motivated by the business purpose described above and that such business purpose satisfies the requirements of the fit and focus business purpose that the IRS has previously acknowledged in published revenue rulings is a sufficient business purpose to satisfy the Business Purpose Requirement. 2. The Device Requirement The Treasury Regulations approach the device issue by cataloging a series of device and non-device factors, but then indicate that the device issue must be determined by all of the facts and circumstances, including, but not limited to, the presence of device and non-device factors. Of the various device factors that are listed, the only one that is present in respect of the Spin-off is that each of the distributions comprising the Spin-off will be pro rata. On the other hand, virtually every spin-off transaction as contrasted with split-offs and split-ups is pro rata by its very nature. Therefore, while it is correct that a pro rata distribution has the potential of being used as device, it is inherently difficult to use this factor as a means of distinguishing putative non-device spin-off transactions from spin-off transactions having substantial potential to be used as a device. Thus, it should be significant that none of the other device factors set forth in the Treasury Regulations is fairly presented on the facts of the Spin-off. One of the three other device factors referenced in the Treasury Regulations is a subsequent sale or exchange of the stock of the distributing corporation or the controlled corporation. ABE has represented that it is unaware of any plan or intention on the part of any shareholder to dispose of any significant amount of the stock of ABE or HAB after the Spin-off. Thus, any dispositions of the publicly traded stock of HAB or ABE would be based on the independent investment decisions of the thousands of public shareholders, which have not been a significant factor in the planning of the Spin-off. In addition, although ABE is planning to dispose of the stock of HOP and HPOP after the Second Distribution, that transfer will come in the form of a contribution of the stock to HAB in a reorganization transaction in which gain or loss will not be recognized for U.S. federal income tax purposes. Such a transfer is expressly excepted under the regulation relating to post-distribution dispositions of stock. Section (d)(2)(iii)(E) of the Treasury Regulations. Accordingly, this device factor will not be present in the Spin-off.

9 Page 9 The third device factor referenced in the Treasury Regulations is the presence in either the distributing corporation or the controlled corporation of a substantial amount of assets that are not being used in the five-year active trade or business. As is noted in the Request for Rulings, the various corporations that are directly involved in the Spin-off have a relatively small amount of assets that are not being used in one of the five-year active trades or businesses. Although virtually all of the corporations, of course, have significant amounts of working capital, there is no indication that the amounts of such working capital are unduly large and exceed the reasonable and expected needs of the business, particularly in the face of the substantial strategic plans that management has concluded are required by each of the businesses and that are at the core of the business purpose for the Spin-off. Thus, this device factor is not present in the Spin-off. The Treasury Regulations do not expressly indicate that the reverse of this device factor i.e., the fact that the great majority of the assets of the corporations are active trade or business assets -- should be viewed as a non-device factor (as opposed to just the absence of a potential device factor). However, the IRS, in Rev. Rul , C.B. 182, has indicated that the fact that neither distributing nor controlled held substantial investment assets was a fact indicative of the absence of a device. The same is true on the facts of the Spin-off. The final device factor described in the Treasury Regulations is the fact that either the distributing corporation or the controlled corporation is substantially engaged in a so-called secondary business whose principal function is to provide support for the active business of the other corporation. That device factor is not presented on the facts of the Spin-off. Both the Indoor Products Business and the Outdoor Products Business are principally engaged in the manufacture of products that are sold to the consuming public, either directly or through an independent dealer network. Neither of these businesses engages to any significant degree, if at all, in the production of products or services, the buyer of which is the other business. To a very limited degree, it is expected that the corporations conducting the Indoor Products Business may temporarily provide certain administrative services to the corporations conducting the Outdoor Products Business and, if so, that they will be fairly compensated for those services. However, it is expected that that arrangement will continue for only a short time after the conclusion of the Spin-off almost certainly not to exceed one year. Although this, again, represents only the absence of a device factor, Rev. Rul teaches that the nature, kind, and amount of the assets held by the distributing or controlled corporation can serve to indicate that [a] pro rata distribution...is not a device. The first non-device factor prescribed in the Treasury Regulations is the presence of a substantial corporate level business purpose of the transaction. As is discussed above and in the Request for Rulings and as EHI, EHP, and ABE have represented to us, senior management s concern about the needs for each of the businesses to expeditiously execute distinctive and complex strategic business plans is both sincere and immediate. The same is true for their concern that the success of each of those strategic plans will turn to a substantial degree on management s ability to

10 Page 10 maintain an exclusive focus on each of those plans. The competition between the two businesses for scarce management resources is already significant and is expected to increase as the strategic plans are implemented. The regulation states that the evidence of non-device that this factor presents is stronger as the importance of the purpose to achieving success in the business grows, as the need for the transaction is prompted by factors outside the control of the distributing corporation, and as the conditions prompting the transaction have greater immediacy. Section (d)(3)(ii) of the Treasury Regulations. In this case, market forces beyond the control of ABE have led senior management to conclude that the immediate and successful implementation of these strategic plans is highly important to the long- and short-term success of both businesses. Thus, this business purpose should be viewed as providing significant evidence of non-device on the facts underlying the Spin-off. Accordingly, there are at least three principal reasons to conclude that the Spin-off will not be used principally as a device. First, only the most generic of the regulatory device factors a pro rata spin-off is present on these facts. The very broad and generic quality of this factor should serve to make it only weak evidence of a device, unless supported by other facts and circumstances. Second, each of the other regulatory device factors is absent on these facts, which Rev. Rul suggests can be viewed as indicative of the absence of a device. Third, and most importantly, the business purpose motivating the Spin-off has very substantial and immediate impact on the ability of the two businesses to successfully confront the major challenges presented by their respective markets. For these reasons, we conclude that the Spin-off will not be used principally as a device for the distribution of the earnings and profits of any of the corporations that participate in any of the Constituent Transactions that comprise the Spin-off. Limitations on Opinion The following limitations apply with respect to the Opinion: 1. The Opinion is based upon the provisions of the Code, the Treasury Regulations promulgated thereunder (including proposed Treasury Regulations), and published interpretations thereof by the IRS and those courts having jurisdiction over such matters, in each case as in effect as of the date hereof, all of which are subject to change either prospectively or retrospectively. No opinion is rendered with respect to the effect, if any, of any pending or future legislation or administrative regulation or ruling or court decision that may have a bearing on any of the foregoing. We disclaim any undertaking to advise you of any subsequent changes in applicable law, regulations, or interpretations thereof. The Opinion is not the equivalent of a ruling from, and is not binding on, the IRS, and there can be no assurance that the IRS or the courts will agree with the conclusions expressed herein.

11 Page We have not been asked to render an opinion with respect to any federal tax matters except those set forth below, nor have we been asked to render an opinion with respect to any foreign, state or local tax consequences of the Spin-off. Accordingly, the Opinion should not be construed as applying in any manner to any tax aspect of the Spin-off, other than as set forth below. 3. All factual assumptions set forth above are material to all opinions herein rendered and have been relied upon by us in rendering all such opinions. Any material inaccuracy in any one or more of the assumed facts may adversely affect all or some of the conclusions stated in such opinion. 4. The Opinion is being furnished to EHI and is intended solely for the benefit of EHI, EHP, and ABE in connection with the Spin-off, and may not be used or relied upon by any other person, furnished to any other person for any purpose, or included or referenced in any filing made with any governmental or regulatory authority without our prior written consent. Notwithstanding the preceding sentence, we hereby consent to the reference to the Opinion in the prospectus that ABE distributes to its shareholders in connection with the planned External Distribution. To that extent, the Opinion was written to support the promotion or marketing of the Spin-Off. Each shareholder should seek advice based on such shareholder s particular circumstances from an independent tax advisor. Opinion Based upon and subject to the foregoing, it is our opinion 1) that the Spin-off will be treated as motivated by a substantial corporate business purpose sufficient to satisfy the Business Purpose Requirement, and 2) that none of the three Constituent Transactions comprising the Spin-off, either separately or together, will be regarded as having been used principally as a device for the distribution of the earnings and profits of any of the corporations participating in such distributions and thus that the Spin-off will satisfy the Device Requirement. Respectfully submitted,