COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022 Country Report - SWEDEN Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance
Date: 2022-09-08
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Sweden, application of EU law, biodiversity, circular economy, climate change policy, environmental law, governance, pollution control measures, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.9.2022  SWD(2022) 272 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022      Country Report - SWEDEN             Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance       {COM(2022) 438 final} - {SWD(2022) 252 final} - {SWD(2022) 253 final} - {SWD(2022) 254 final} - {SWD(2022) 255 final} - {SWD(2022) 256 final} - {SWD(2022) 257 final} - {SWD(2022) 258 final} - {SWD(2022) 259 final} - {SWD(2022) 260 final} - {SWD(2022) 261 final} - {SWD(2022) 262 final} - {SWD(2022) 263 final} - {SWD(2022) 264 final} - {SWD(2022) 265 final} - {SWD(2022) 266 final} - {SWD(2022) 267 final} - {SWD(2022) 268 final} - {SWD(2022) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
Sweden | 1 

This  report  has  been  written  by  the  staff  of  the  Directorate-General  for  Environment,  European  Commission. 
Any comments are welcome to the following e-mail address: ENV-EIR@ec.europa.eu  

More information on the European Union is available on the internet (http://europa.eu). 

Photographs:  

For reproduction or use of these photos, permission must be sought directly from the copyright holder. 

©European Union, 2022 

Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Sweden | 2 

Table of Contents 

EXECUTIVE SUMMARY ........................................................................................................................................... 3 

PART I: THEMATIC AREAS ...................................................................................................................................... 4 

1. 

2. 

3. 

4. 

CIRCULAR ECONOMY AND WASTE MANAGEMENT ........................................................................................................ 4 
Measures towards a circular economy ................................................................................................................ 4 
Waste management ............................................................................................................................................. 6 
BIODIVERSITY AND NATURAL CAPITAL ........................................................................................................................ 8 
Nature protection and restoration ....................................................................................................................... 8 
Marine ecosystems............................................................................................................................................. 14 
Ecosystem assessment and accounting ............................................................................................................. 15 
ZERO POLLUTION ................................................................................................................................................ 17 
Clean air ............................................................................................................................................................. 17 
Industrial emissions ............................................................................................................................................ 18 
Major industrial accidents prevention – SEVESO ............................................................................................... 20 
Noise .................................................................................................................................................................. 21 
Water quality and management ........................................................................................................................ 22 
Chemicals ........................................................................................................................................................... 25 
CLIMATE ACTION ................................................................................................................................................ 27 
Key national climate policies and strategies ...................................................................................................... 27 
Effort sharing ..................................................................................................................................................... 28 
Key sectoral developments ................................................................................................................................. 29 
Use of revenues from the auctioning of EU ETS allowances .............................................................................. 30 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS .............................................................................. 31 

5. FINANCING ............................................................................................................................................................. 31 
Environmental investment needs in the European Union. ................................................................................. 31 
EU environmental funding 2014-2020 ............................................................................................................... 32 
EU environmental funding 2021-2027 ............................................................................................................... 34 
National expenditure on environmental protection ........................................................................................... 36 
Green budget tools ............................................................................................................................................. 37 
Overall financing compared to the needs .......................................................................................................... 39 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 40 
Information, public participation and access to justice...................................................................................... 40 
Compliance assurance ........................................................................................................................................ 41 
Effectiveness of environmental administrations ................................................................................................ 43 
Reforms through the Commission’s Technical Support Instrument (TSI) ........................................................... 44 
TAIEX EIR peer to peer Projects .......................................................................................................................... 44 

 Environmental Implementation Review 2022 – Sweden 

 
 
 
 
 
Sweden | 3 

Executive summary 

On waste management, Sweden is not considered at risk 
of  failing  to  meet  EU  waste  recycling  targets.  However, 
Sweden’s  recycling  rate  for  municipal  waste  stagnated 
over  the  last  decade  and  its  circular  (secondary)  use  of 
material  is  well  below  the  EU  average.  In  particular, 
action  is  needed  to  reduce  incineration  (with  energy 
recovery)  of  municipal  waste,  which  remains  the 
dominant form of waste treatment. 

Sweden’s  performance  with  regard  to  eco-innovation  is 
outstanding.  The  country  has  a  highly  developed  eco-
innovation  ecosystem,    which  is  strongly  incentivised  by 
government policy and benefits from the relatively large 
number of domestic cleantech investors. 

EU financing continues to provide important support for 
environmental implementation. Sweden is due to receive 
1.92 billion from the cohesion policy (ERDF and ESF) and 
EUR  1.06  billion  from  the  EAFRD  in  2021-2027.  The 
investment 
country’s  total  environmental  protection 
accounted  for  0.53%  of 
in  2014-2020  (EU 
average:  0.7%). Overall environmental investment needs 
in the coming period are estimated to be at the level of 
at  least  0.61%  of  Sweden’s  GDP  annually,  suggesting  a 
potential environmental investment gap of over 0.08% of 
GDP  compared  to  baseline  financing 
levels,  to  be 
addressed  by  focusing  on  the  country’s  environmental 
implementation priorities. 

its  GDP 

The main challenges identified in past EIRs with regard to 
implementation  of  EU  environmental  policy  and  law  by 
Sweden were:  

 

improving  the  still  unfavourable  conservation  status 
of all grassland habitats and many of their associated 
species and many forest types  

  halting biodiversity loss  
  making  additional  efforts  to  reach  the  emission 
reduction commitments for 2020-2029 and the years 
after 2030. 

Regarding  nature  conservation,  the  share  of  habitats  in 
bad or poor conservation status has increased to 77.42%. 
Moreover,  conservation  statuses  are  uneven  across 
groups: out of the 33 biogeographical assessments of the 
16  EU  forest  habitat  types  protected  under  the  EU 
nature directives in Sweden, only 6.06% show favourable 
conservation  status.  The  situation  of  forested  areas 
protected  under  the  nature  directives  is  severe  as  more 
than half of assessments show a bad conservation status. 
The  wolf  hunting  regime  has  been  subject  to  some 
amendments,  but  remains  a  controversial  issue,  and  its 
compatibility with the Habitats Directive is the subject of 
an infringement procedure.  

As  regards  air  quality,  emissions  of  key  air  pollutants 
have  decreased  significantly  in  Sweden  in  recent  years. 
However, exceedances of PM10 limit values are still being 
found,  which  shows  that  further  effort  is  needed  in  this 
regard.  Sweden  projects  to  reach  emission  reduction 
commitments  for  most  air  pollutants  covered  by  the 
Directive  for  2020-2029  and  for  SO2,  NMVOC  and  PM2.5 
for  2030  onwards.  However,  the  projections  do  not 
demonstrate  compliance  with  the  emission  reduction 
commitment for NOX for 2030 onwards or the 2020-2029 
and  post-2030  reduction  commitments  for  ammonia 
(NH3).  

Environmental Implementation Review 2022 – Sweden 

 
 
 
 
 
 
 
 
 
 
Sweden | 4 

Part I: Thematic areas 

1. Circular economy and waste management  

Figure 1: Circular material use rate (%), 2010-20202  

Measures towards a circular economy  

The new Circular Economy Action Plan adopted in March 
2020 is one of the main building blocks of the European 
Green Deal. The EU’s transition to a circular economy will 
reduce  pressure  on  natural  resources  and  will  create 
sustainable  growth  and  jobs.  It  is  also  a  prerequisite  to 
achieve  the  EU’s  2050  climate  neutrality  target  and  to 
halt  biodiversity 
loss.  The  Action  Plan  announces 
initiatives  along  the  entire  life  cycle  of  products,  aiming 
to reduce the EU's consumption footprint and to double 
the EU's circular material use rate by 2030. It targets how 
products  are  designed,  promotes  circular  economy 
processes,  encourages  sustainable  consumption,  and 
aims to ensure that waste is prevented and the resources 
used are kept in the EU economy for as long as possible. 

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  to  minimise 
negative 
impacts  on  the  environment  and  reduce 
dependency on volatile raw  material  markets. As  shown 
in  Figure  2,  with  EUR  1.87  generated  per  kg  of  material 
consumed  in  2020,  resource  productivity  in  Sweden  is 
slightly below the EU average of EUR 2.09 per kg. 

Figure 2: Resource productivity 2010-20203 

The circular material use, also known as circularity rate, is 
defined as the ratio of the circular use of materials to the 
overall material use. The overall material use is measured 
by  summing  up  the  aggregate  domestic  material 
consumption (DMC) and the circular use of materials. The 
circular  material  use  rate  is  a  good  indicator  of  an 
economy’s circularity, as it includes all the materials that 
are  fed  back  into  our  economy.  Large  differences  in  the 
circularity  rate  exist  between  countries.  To  help  achieve 
the  goal  in  the  EU  circular  economy  action  plan  goal  of 
doubling  the  EU  circular  material  use  rate  by  2030, 
ambitious  measures  targeting  the  whole  product  life 
cycle are needed at Member-State level. Such  measures 
range  from  sustainable  product  design  that  makes  it 
possible to increase durability, reparability, upgradability 
and recyclability of products, to other measures, like: (i) 
‘remanufacturing’1; 
in 
production  processes;  (iii)  recycling;  (iv)  boosting  eco-
innovation; and (v) increasing the uptake of green public 
procurement. 

increasing  the  circularity 

(ii) 

The  circular  (secondary)  use  of  material  in  Sweden  was 
7.1% in 2016 and also 7.1% in 2019, compared to the EU 
average of  12.8%. There is  therefore room and need for 
improvement in this regard (figure 1). 

1 A standardized industrial process that takes place within industrial or 
factory  settings,  in  which  cores  are  restored  to  original  as-new 
condition and performance or better. 

2 Eurostat, Circular Economy Monitoring Framework.  

3 Eurostat, Resource productivity 

Environmental Implementation Review 2022 – Sweden 

 
 
 
                                                                 
 
 
                                                                 
 
Circular economy strategies  

Figure 3: Eco-innovation performance, 2010-20195 

Sweden  5 

The  Commission  encourages  Member  States  to  adopt 
and 
implement  national/regional  circular  economy 
strategies covering the whole life cycle of products. This 
is  because  such  strategies  are  one  of  the  most  effective 
ways to progress towards a more circular economy. Since 
the  launch  of  the  online  Circular  Economy  Stakeholder 
Platform in 20174, national, regional and local authorities 
have  used  the  platform  to  share  their  strategies  and 
roadmaps.  

The Swedish circular economy strategy ‘Circular Economy 
-  Strategy  for  the  transition  in  Sweden’  was  adopted  in 
November 2020. The overall objective is the transition to 
a  circular  economy  which  contributes  to  achieving  the 
environmental  and  climate  objectives,  as  well  as  the 
Sustainable Development Goals in the 2030 Agenda.  

In January 2021, the country  adopted a  new  action  plan 
as  a  follow-up  to  the  2020  Strategy.  The  action  plan 
presents  more  than  100  different  activities  along  the 
entire  lifecycle  of  products,  but  it  seems  to  lack  a 
concrete timeline for implementing each deliverable. The 
plan 
identifies  certain  sectors  as  priorities:  plastics, 
textiles,  renewable  and  bio-based  material,  food,  the 
construction and property sector (including building and 
demolition  waste)  and  innovation-critical  materials  and 
minerals.  In  addition,  the  Swedish  government  has  the 
intention  to  publish  another  action  plan,  focused  solely 
on plastics. 

Eco-innovation 

A  successful  transition  to  a  circular  economy  requires 
social  and  technological  innovation.  This  is  because  the 
full potential of the circular economy can only be reached 
when  it  is  implemented  across  all  value  chains.  Eco-
innovation is an important enabling factor for the circular 
economy.  New  approaches  to  product  design  and  new 
business  models  can  help  produce  systemic  circularity 
innovations, creating new business opportunities. 

In 2021, Sweden ranked  5th on the 2021 Eco-innovation 
Index, with a total score of 142, making it a leader in eco-
innovation.  In  addition,  Sweden  performs  above  the  EU 
average  for  three  out  of  five  components  of  the  Eco-
innovation  index  of  2021:  eco-innovation  inputs,  eco-
innovation  activities  and  eco-innovation  outputs.  On 
resource  efficiency  outcomes  and 
socio-economic 
outcomes,  the  country’s  performance  is  below  the  EU 
average (see Figure 3). 

Green public procurement (GPP) 

Public  procurement  accounts  for  a  large  proportion  of 
European 
authorities’ 
consumption,  with  public 
purchasing power representing  14% of EU GDP. This can 
help  drive  the  demand  for  sustainable  products  that 
meet  reparability  and  recyclability  standards.  To  date, 
reporting to monitor the uptake of GPP is voluntary. 

introduced.  The  National  Agency 

A  National  strategy  for  green  public  procurement  is  in 
force in Sweden, under the National public procurement 
strategy  of  2017.  Under  objective  6  of  the  strategy, 
environmentally  responsible  public  procurement  has 
for  Public 
been 
library”  containing 
Procurement  offers  a  “criteria 
recommendations 
social 
and 
requirements  to  be  used  when  purchasing  goods, 
services  and  works.  There  are 
levels  of 
environmental  criteria:  basic,  advanced  and  spearhead. 
The criteria are available within 8 product groups.  

environmental 

three 

on 

There  is  no  general  monitoring  of  the  percentage  of 
public  procurement  procedures 
incorporating  green 
criteria  out  of  the  whole  volume  of  procurement  at 
national  level.  However,  the  National  Agency  for  Public 
Procurement  has  carried  out  a  minor  study  and  showed 
that 90 percent of tender documents analysed contained 
some  form  of  environmental  criterion,  either  criteria 
from  the  National  Agency  for  Public  Procurement  or 
criteria developed by the contracting authority.  

4  Circular Economy Stakeholder Platform 

5  European  Commission  -  Directorate-General  for  Environment  (DG 
ENV), Eco-innovation Observatory, Eco-innovation index. 

 Environmental Implementation Review 2022 – Sweden 

 
                                                                 
 
 
 
                                                                 
Sweden  6 

resource  efficiency  and 

Preventing products and materials from becoming waste 
for  as  long  as  possible  is  the  most  efficient  way  to 
improve 
the 
environmental  impact  of  waste.  Waste  prevention  and 
reuse  are  the  most  preferred  options  and  are  therefore 
at  the  top  of  the  waste  hierarchy.  The  amount  of 
municipal  waste  generated  is  a  good  indicator  of  the 
effectiveness of waste-prevention measures.  

reduce 

to 

After  a  downward  trend,  municipal  waste  generation  in 
Sweden  has  started  to  increase  in  recent  years.  It 
reached  449 kg/year/inhabitant  in  2019  and  remains 
close  to  the  EU  average  (502 kg/year/inhabitant),  as 
shown in Figure 4. This indicates that Sweden’s economic 
growth is not yet decoupled from its generation of waste. 

Figure 4: Municipal waste by treatment in Sweden, 
2010-202010 

EU Ecolabel and the Eco Management and Audit 
Scheme (EMAS) 

The number of EU Ecolabel products and EMAS-licensed6 
organisations in a given country provides some indication 
of  the  extent  to  which  the  private  sector  and  national 
stakeholders  in  that  country  are  actively  engaged  in  the 
transition  to  a  circular  economy.  It  also  shows  how 
supporting 
committed  public  authorities  are 
instruments designed to promote the circular economy.  

to 

As of September 2021, Sweden had 5 521 products out of 
83 590, and 41 licenses out of 2 057 registered in the EU 
Ecolabel  scheme,  showing  a  good  take-up  of  products 
and  licences7.  Moreover,  12  organisations  and  23  sites 
from  Sweden  are  currently  registered  in  EMAS8.  In 
Sweden, however, the Nordic Swan, a similar ecolabel, is 
more  known  and  widespread.  Since  the  last  report  in 
2019,  there  have  been  2 121  new  product  registrations 
and  2  new  license  registrations  under  the  EU  Ecolabel, 
while the number of organisations registered in EMAS fell 
by 5.  

As  Sweden’s  circular  material  use  rate  is  well  below  the 
EU average, a priority action on this is proposed.  

2022 priority action 

  Adopt measures to increase the circular  material use 

rate. 

Waste management 

Turning waste into a resource is supported by: 
(i)  fully 
implementating  EU  waste  legislation,  which 
includes  the  waste  hierarchy,  the  need  to  ensure 
separate collection of waste, the landfill diversion targets 
etc.; 
(ii) reducing waste generation and waste  generation per 
capita in absolute terms;  
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
and  phasing  out  landfilling  of  recyclable  or  recoverable 
waste. 

This  section  focuses  on  the  management  of  municipal 
waste9,  for  which  EU  law  sets  mandatory  recycling 
targets. 

Figure  4  also  shows  municipal  waste  by  treatment,  in 
terms  of  kilos  per  capita.  Incineration  including  energy 
recovery  accounts  for  52%  and  remains  the  dominant 
form  of  waste  treatment  in  Sweden,  while  landfilling 
accounts for less than 1%.  

The  recycling  rate  for  municipal  waste 
in  Sweden 
stagnated over the last decade. Sweden used to be ahead 
of the EU average until 2016, with the gap systematically 
narrowing.  Since  2017,  however,  Sweden  has  been 
scoring below the EU average (46.6% vs. 47.7% in 2019). 
Figure 5 shows that Sweden needs to step up investment 
in  recycling  to  meet  the  EU  2020  and  2025  recycling 
targets. 

6  EMAS  is  the  European  Commission’s  Eco-Management  and  Audit 
Scheme, a programme to encourage organisations to behave in a more 
environmentally sustainable way. 
7 European Commission, Ecolabel Facts and Figures. 
8  As  of  May  2018.  European  Commission,  Eco-Management  and  Audit 
Scheme. 
9 Municipal waste consists of (a) mixed waste and separately collected 
waste  from  households,  including  paper  and  cardboard,  glass,  metals, 
plastics,  bio-waste,  wood,  textiles,  packaging,  waste  electrical  and 

electronic  equipment,  waste  batteries  and  accumulators,  and  bulky 
waste, 
including  mattresses  and  furniture;  (b)  mixed  waste  and 
separately  collected  waste  from  other  sources,  where  such  waste  is 
similar in nature and composition to waste from households. (Directive 
2008/98/EC, Art. 3 2b). 
10  Eurostat, Municipal waste by waste operation, April 2022. 

 Environmental Implementation Review 2022 – Sweden 

 
                                                                 
 
 
                                                                                                        
 
Figure 5: Recycling rate of municipal waste, 2010-202011 

Sweden  7 

non-toxic  waste  management,  in  accordance  with  the 
waste hierarchy. 

In 2020, Sweden amended its revised waste management 
(WMP).  The  assessment  by  the  Commission 
plan 
confirmed  that  the  WMP  meets  the  requirements  of 
Article 28 of the revised Framework Directive on Waste. 

Sweden  has  not  signed  or  ratified  the  Hong  Kong 
and 
the 
International 
Environmentally Sound Recycling of Ships. 

Convention 

Safe 

for 

Given  limited  progress  since  the  2019  EIR,  as    municipal 
waste  generation  continued  to  increase,  and  in  light  of 
the  Early  Warning  Report  2022,  the  priority  actions  are 
repeated. 

2022 priority actions  

 

new 
to 

economic 
Introduce 
instruments, 
the  waste 
hierarchy,  i.e.  promote  prevention,  and  make  reuse 
and recycling more economically attractive. 

policies, 
implement 

including 
further 

  Shift  reusable  and  recyclable  waste  away  from 

incineration. 

The  Commission’s  Early  Warning  report12  did  not  list 
Sweden as one of the countries at risk of missing the EU 
2020  target  of  recycling  50%  of  municipal  waste.    The 
Commission  is  currently  finalising  its  analysis  of  the 
progress  on  the  recommendations  from  the  2018  Early 
Warning  Reports  as  a  well  as  an  analysis  of  progress 
towards achieving the 2025 waste recycling targets. This 
report  will  be  presented  at  the  end  of  2022  and  will 
assess progress made to date. 

Implementation of the 2018 waste legislative package 

Sweden  has  notified  its  transposition  of  the  2018  waste 
package13 to the Commission. A conformity assessment is 
now ongoing. 

for 

are 

Waste  management  plans  and  waste  prevention 
sound 
instrumental 
programmes 
implementation of the EU waste legislation. They set out 
key  provisions  and  investments  to  ensure  compliance 
with  existing  and  new  legal  requirements  (e.g.  waste 
preventiion,  separate  collection for a  number of  specific 
waste  streams,  recycling  and  landfill  targets).  Revised 
plans and programmes were due on 5 July 2020.  

a 

In  2018,  Sweden  approved  its  national  waste  plan  and 
for  2018-2023.  The 
waste  prevention  programme 
document  provides  an  overview  of 
targets, 
the 
instruments  and  measures  introduced  in  Sweden  to 
prevent  waste  and  realise  more  resource-efficient  and 

11  Eurostat, Recycling rate of municipal rate, April 2022.  
12  European  Commission,  Report  on  the  implementation  of  waste 
legislation, including the early warning report for Member States at risk 
of missing the 2020 preparation for re-use/recycling target on municipal 
waste, SWD(2018)422 accompanying COM(2018)656. 
13  Directive  (EU)  2018/851,  Directive  (EU)  2018/852,  Directive  (EU) 
2018/850  and  Directive  (EU)  2018/849  amend  the  previous  waste 
legislation and set more ambitious recycling targets for the period up to 
2035. 

 Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
 
 
2. Biodiversity and natural capital 

Sweden  8 

The 2030 EU biodiversity strategy adopted in May 2020 
aims to put the EU’s biodiversity on a path to recovery 
and  sets  out  new  targets  and  governance  mechanisms 
to achieve healthy and resilient ecosystems.  
In particular, the strategy sets out ambitious targets to: 
(i) protect a minimum of 30% of the EU’s land area and 
30% of its sea area and integrate ecological corridors, as 
part of a true trans-European nature network;  
(ii) strictly protect at least a third of the EU’s protected 
areas,  including  all  remaining  EU  primary  and  old-
growth forests;  
(iii)  effectively  manage  all  protected  areas,  defining 
clear  conservation  objectives  and  measures,  and 
monitoring them appropriately.  
The strategy also sets out an EU nature restoration plan 
–  a  series  of  concrete  commitments  and  actions  to 
restore  degraded  ecosystems  across  the  EU  by  2030, 
and  manage  them  sustainably,  addressing  the  key 
drivers of biodiversity loss. 

The Habitats and the Birds Directives are key legislative 
tools  to  deliver  on  the  strategy’s  targets  and  are  the 
cornerstone of European legislation aimed at conserving 
the EU’s wildlife14.  

There  is  no  Swedish  strategy  for  reaching  favourable 
conservation  status  of  habitats  and  species  per  se. 
Instead, biodiversity is integrated into the broad system 
that  specifies  the  overall  goal  guiding  Sweden’s 
environmental  policy,  which  was  adopted  by  the 
country’s  parliament  at  the  turn  of  the  century  and 
updated since then15. 

Swedish  nature  conservation  follows  three  general 
themes:  (i)  protection  and  management  of  nature;  (ii) 
species protection; and (iii) sustainable use. The Bill  on 
biodiversity  and  ecosystem  services  (2014)  constitutes 
Sweden’s  overall 
for  biodiversity  and 
ecosystem services for the period up to 2020. 

strategy 

The  overarching  goal  of  this  policy,  the  ‘generational 
goal’, is to hand over to the next generation a society in 
which  the  major  environmental  problems  have  been 
solved,  without  increasing  environmental  and  health 
problems outside Sweden’s borders. 

is  broken  down 

It 
into  16  environmental  quality 
objectives  (EQOs)  covering  different  areas,  including  in 
particular  an  EQO  focusing  on  ‘a  rich  diversity  of  plant 
and animal life’. Six other EQOs are particularly relevant 

14  These  should  be  reinforced  by  the  Nature  Restoration  Law, 
according to the new EU Biodiversity Strategy. 
15 Naturvårdsverket, environmental objectives 

to  biodiversity  and  the  implementation  of  the  EU 
Nature Directives.  

Nature protection and restoration  

Natura  200016  –  the  largest  coordinated  network  of 
protected areas in the world  – is the key instrument to 
achieve the Birds and Habitats Directives’ objectives.  

to  ensure 

long-term 
These  objectives  are 
protection,  conservation  and  survival  of  Europe’s  most 
valuable  and  threatened  species  and  habitats  and  the 
ecosystems  they  underpin.  Key  milestones  towards 
meeting the objectives of the Directives are: 

the 

(i) 
(ii) 
(iii) 

setting up a coherent Natura 2000 network; 
classifying Special Protection Areas (SPA); 
designating  Sites  of  Community  Importance 
(SCI) as Special Areas of Conservation (SAC)17;  

setting  conservation  objectives  and  measures  for  all 
Natura 2000 sites.  

Setting up a coherent network of Natura 2000 sites 

Sweden  hosts  89  habitat  types18  and  163  species19 
covered  by  the  Habitats  Directive.  The  country  also 
hosts populations of 86 bird taxa listed in Annex I of the 
Birds Directive20. 

As  shown  in  Figure  7,  by  2021  12.3%  of  Sweden’s 
national  land  area  of  was  covered  by  Natura  2000  (EU 
average  18.5%),  with  Special  Protection  Areas  (SPAs) 
classified  under  the  Birds  directive  covering  5.9%  (EU 
average  12.8%)  and  Sites  of  Community  Importance 
(SCIs)  under  the  Habitats  Directive  covering  12.2%  (EU 
average 14.2%) of the Swedish territory. 

The  latest  assessment  of  the  Natura  2000  network 

16  Natura  2000  comprises  Sites  of  Community  Importance  (SCIs) 
designated  pursuant  to  the  Habitats  Directive  as  well  as  Special 
Protection  Areas  (SPAs)  classified  pursuant  to  the  Birds  Directive; 
coverage figures do not add up because some SCIs and SPAs overlap. 
Special  Areas  of  Conservation  (SACs)  means  an  SCI  designated  by 
Member States. 
17  Sites  of  Community  Importance  (SCIs)  are  designated  pursuant  to 
the  Habitats  Directive  whereas  Special  Protection  Areas  (SPAs)  are 
designated  pursuant  to  the  Birds  Directive;  coverage  figures  do  not 
add  up  because  some  SCIs  and  SPAs  overlap.  Special  Areas  of 
Conservation (SACs) are SCIs designated by Member States. 
18 EEA, Article 17 dashboard, Annex I total, 2019. 
19  EEA, Article  17  dashboard,  Annex  II  &  Annex  IV  excluding  those  in 
Annex  II  &  Annex  V  excluding  those  in  Annex  II,  2019.  This  counting 
only takes into account species and habitats for which assessment of 
conservation status was requested. 
20  EEA, Article  12  dashboard,  Annex  I,  2020. This counting  only  takes 
into account birds taxa for which information was requested. 

Environmental Implementation Review 2022 – Sweden 

 
                                                                 
                                                                 
Sweden  9 

Figure 7: Natura 2000 terrestrial protected area, 202124 

shows that there are insufficiencies in designation. The 
related  open 
in 
infringement  procedure 
particular  that  Sweden  has  still  to  complete  the 
designation of its network of SPAs at sea. 

indicates 

Considering  both  Natura  2000  and  other  nationally 
designated  protected  areas,  Sweden  legally  protects 
14.10%  of  its  terrestrial  areas21  (EU-27  average  26.4%) 
and 15.5% of its marine areas (EU-27 average 10.7%)22. 
Figure  6  shows  the  2020  situation  at  EU  level  for 
terrestrial  and  marine  protected  area  coverage 
in 
meeting the biodiversity strategy 2030 target. 

Figure 6: Marine & terrestrial protected area coverage, 
202123 

Designating  Special  Areas  of  Conservation  (SACs)  and 
setting conservation objectives and measures 

Sweden  is  subject  to  an  infringement  due  to  the 
list  of  proposed  Sites  of 
insufficiency  of  (i)  the 
Community  Importance  (pSCIs) 
it  has  sent  to  the 
Commission  in  accordance  with  Article  4(1)  of  the 
Habitats  Directive,  and  (ii)  the  Special  Protection  Areas 
(SPAs) it has classified under  Article 4(1) and (2) of the 
Birds Directive. 

Progress 
conservation status for species and habitats 

in  maintaining  or  restoring 

favourable 

To measure the performance of Member States, Articles 
17 of the Habitats Directive and 12 of the Birds Directive 
require  reporting  on  progress  towards  maintaining  or 
restoring  the  favourable  conservation  status  of  species 
and habitats. 

According  to  Sweden’s  report  on  the  conservation 
status  of  habitats  and  species  covered  by  the  Habitats 
Directive  for  2013-2018,  the  share  of  assessments  of 
favourable  conservation  statuses  has  been  relatively 
stable  since  the  last  reporting  period.  The  share  of 
habitats  in  good  conservation  status  has  decreased  by 
3.09  pps  and  accounted  for  22.58%  in  2018  compared 
to  the  25.67%  reported  under  the  previous  reporting 
period (2007-2012).  

As  for  protected  species,  the  share  of  assessments  in 
good  conservation  status  in  2018  has  increased  by  1.9 
pps and accounted for 47.45% compared to the 45.55% 
reported  under  the  previous  reporting  period  (2007-
2012).  

However,  conservation  statuses  are  uneven  across 

24 EEA, Natura 2000 Barometer, February 2022. 

21 EEA, share of country designated as terrestrial protected area.    
22  EEA, Protected Areas, terrestrial protected area percentage (2021) 
and marine protected area percentage (2019), March 2022. 
23  EU  Biodiversity  Strategy  Dashboard,  indicators  A1.1.1  and  A1.2.1, 
February 2022. 

Environmental Implementation Review 2022 – Sweden 

 
 
 
 
                                                                 
 
                                                                 
 
groups: of the 33 biogeographical assessments of the 16 
EU  forest  habitat  types  protected  under  the  EU  nature 
directives  in  Sweden,  only  6.06%  (two  habitat  types  in 
the Alpine region) have favourable conservation status, 
while all the others have unfavourable status25.  

At the same time, the share  of habitats in bad  or poor 
conservation status has increased to 77.42% (see Figure 
8), while the share of assessments for species in bad or 
poor  conservation  status  has  (slightly)  decreased  to 
51.46% (see Feigure 9). The main pressures are  related 
industrial  and  urban 
to  agriculture  and  forestry, 
including 
land  use, 
in 
pollution  and 
abandonment of agricultural land. Invasive alien species 
are assessed as an increasing threat to biodiversity.    

changes 

As  regards  birds,  close  to  58%  of  the  breeding  species 
showed  population  trends  that  were  increasing  in  the 
short  term  or  stable  (for  wintering  species  this  figure 
was close to 55%), while 1/3 have bad status. There are 
also  indicators  showing  that  trends  for  bird  species 
which  are  dependent  on  forests  are  going  down  in 
Sweden, with bird species linked to forests that have a 
more complex structure being more affected26. 

Figure 8:  Assessments on conservation status for 
habitats for the 2007-2012 and 2013-2018 reporting 
periods27 

av 

Svensk 

Övervakning 

Fågeltaxering, 

25 State of Nature Report. EEA 2021. 
26 
fåglarnas 
populationsutveckling  (Monitoring  the  population  development  of 
birds),  Årsrapporterna  för  2018  and  2021  (Annual  Reports  for  2018 
and 2021)  
;  
27  EEA,  Conservation  status  and  trends  of  habitats  and  species, 
December  2021.  Please  note when  comparing  the  figures  shown  for 
2007-2012  and 2013-2018  these  may  also  be  affected by  changes of 
methods or due to better data availability. 

Sweden  10 

Figure 9: Assessments on conservation status for 
species for the 2007-2012 and 2013-2018 reporting 
periods28 

At sea, not all Natura 2000 sites are effectively managed 
yet  and  not  every  significant  disturbance  of  highly 
sensitive species is prevented. 

Sweden  is  subject  to  an  infringement  for  the  licenced 
hunting of wolves. 

The  LIFE  programme  has  been  widely  used  in  Sweden 
for nature purposes. Two recent example projects are: 

 

 

for  LIFE  –  ECOSysTem  based 

Ecostreams 
REstoration And Management of boreal riverS 
LIFE  RestoRED  –  Restoration  of  EU  Redlisted 
Annex I habitats, dependent on grazing or hay 
cutting in Natura 2000 sites in Sweden 

  GRIP  on  LIFE  –  Restoration  of  waters  in  forest 

habitats. 

Bringing nature back to agricultural land and restoring 
soil ecosystems  

Agricultural land 

The biodiversity strategy works alongside the new farm 
to fork strategy and the new common agricultural policy 
(CAP)  to  support  and  achieve  the  transition  to  fully 
sustainable  agriculture.  The  biodiversity  and  farm  to 
fork strategies have set four important targets for 2030: 
-  50% reduction in the overall use of – and risk from – 
chemical pesticides; 
-  50%  reduction 
pesticides; 
-  50%  reduction  in  losses  of  nutrients  from  fertilisers 

in  the  use  of  more  hazardous 

28  EEA,  Conservation  status  and  trends  of  habitats  and  species, 
December  2021.  Please  note when  comparing  the  figures  shown  for 
2007-2012  and 2013-2018  these  may  also  be  affected by  changes of 
methods or due to better data availability. 

Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
 
                                                                 
while  ensuring  there  is  no  deterioration  of  soil  fertility 
(which  will  result  in  20%  reduction  in  the  use  of 
fertilisers); 
- bring back at least 10% of agricultural area under high-
diversity landscape features  and increasing areas under 
organic farming to at least 25%.  

The soil quality of arable land is generally satisfactory in 
Sweden, with relatively good and stable organic matter 
content and no significant soil erosion. The presence of 
cadmium in agricultural soil in some regions, due to high 
geological  level,  somewhat  affects  the  crop  choices  in 
those areas. 

Sweden  11 

With an estimated 20.43% of its agricultural area under 
organic farming, Sweden ranks 3rd amoung EU Member 
States and is well above the EU average of 9.07% (2020 
data, Eurostat). 

Figure 10 shows 2021 situation and distance, at the EU 
level,  from  meeting  the  2030  biodiversity  strategy 
target for area under organic farming.  

Figure  10:  Share  of  total  utilised  agricultural  area 
occupied by organic farming per Member State29 

Swedish  agriculture  can  play  an  important  role  in 
achieving  the  new  climate  and  environmental  goals 
established  by  the  European  Green  Deal:  Sweden 
manages  a  very  valuable  carbon  sink  at  EU  level,  with 
significant  forest  cover  (the  second  highest  forested 
area  as  a  percentage  of  national  land  area  in  the  EU) 
and very carbon-rich soils. 

low,  energy  consumption  by 

from  agriculture  are 
Greenhouse  gas  emissions 
the 
comparatively 
agricultural  and  forestry  sectors 
is  below  the  EU 
average, and the use per hectare (ha) of fossil energy is 
the  lowest  in  the  EU.  Almost  half  of  the  energy 
produced  in  Sweden  comes  from  renewable  sources, 
with  forestry  as  the  most  important  source.  Due  to 
ammonia emissions from agriculture, Sweden is at high 
risk  of  non-compliance  with  its  ammonia  emission 
reduction  commitments  for  both  2020-2029  and  for 
2030 and beyond. 

29 Eurostat, online data code: SDG_02_40, February 2022. 

Soil ecosystems 

Soil  is  a  finite  and  extremely  fragile  resource  and  it  is 
increasingly degrading in the EU.  
The  new  EU  soil  strategy,  adopted  on  17  November 
2021,  stresses  the  importance  of  soil  protection,  of 
sustainable soil management and of restoring degraded 
soils,  to  achieve  the  Green  Deal  objectives  as  well  as 
land degradation neutrality by 2030. This entails: 
(i) preventing further soil degradation; 
(ii)  making  sustainable  soil  management  the  new 
normal; 
(iii) taking action for ecosystem restoration. 

One  factor  of  degradation  is  the  area  of  soil  that  is 
sealed  or  atificialised30.  The  land  taken  (land  ‘taken’ 
means  land  that  is  sealed  or  artificialised)  per  year  in 
2012-2018 (see Figure 11) can be seen as a measure of 
one  significant  pressure  on  nature  and  biodiversity  – 
land use change. This also constitutes an environmental 
pressure on people living in urbanised areas.  

Sweden  ranks  below  the  EU  average31  as  regards  net 
land take, with 26.9m2/km2 (EU-27 average 83.8m2/km2, 
Eurostat 2018). 

30 Artificial  land cover  is defined as the total of roofed built-up areas 
(including  buildings  and  greenhouses),  artificial  non-built-up  areas 
(including  sealed  features,  such  as  yards,  farmyards,  cemeteries,  car 
parking areas etc. and linear features, such as streets, roads, railways, 
runways,  bridges)  and  other  artificial  areas  (including  bridges  and 
viaducts,  mobile  homes,  solar  panels,  power  plants,  electrical 
substations, pipelines, water sewage plants, and open dump sites). 
31 Land take  in Europe — European Environment Agency (europa.eu) 
fig 6 

Environmental Implementation Review 2022 – Sweden 

 
 
 
                                                                 
 
                                                                 
Figure 11: Land take and re-cultivation in EU27 
(m2/km2), 2012-201832 

Sweden  12 

primary forests37. Most of this area consists of formally 
protected  areas or is exempted from  harvesting.  either 
by law or on a voluntary basis. 

Figure  12:    Conservation  status  of  forests  protected 
under  the  Habitats  Directive  in  EU  Member  States, 
2013-2018 (% assessments)38 

However,  Sweden  has  not  yet  committed  to  set  land 
degradation neutrality targets under the UN Convention 
on Combating Desertification33.  

Forests and timber 

The EU forest strategy for 2030, adopted in July 2021, is 
a part of the ‘Fit for 55’ Package. The strategy promotes 
the many services that forests provide. Its key objective 
is  to  ensure  healthy,  diverse  and  resilient  EU  forests, 
strengthened 
significantly 
which 
biodiversity and climate ambitions. 
Forests are important carbon sinks and conserving them 
is vital if the EU is to achieve climate neutrality by 2050.  

contribute 

to 

Out  of  the  27%  of  EU  forest  area  protected  under  the 
Habitats  Directive,  less  than  15%  of  assessments  have 
favourable  conservation  status 34.  Bad  conservation 
status increased from 27% to 31% in the EU, compared 
to 2015.  

In  Sweden,  forests  cover  71.52%  of  the  country’s 
territory35.  The  situation  of  forest  habitats  protected 
under the Habitats Directive is particularly worrying, as 
more  than  half  of  the  assessed  protected  forests  have 
bad  status36.  2 249 000  ha  in  Sweden  are  covered  by 

(EUTR)39 
The  European  Union  Timber  Regulation 
prohibits  the  placing  on  the  EU  market  of  illegally 
harvested  timber.  In  accordance  with  this  Regulation, 
EU  Member  States’  competent  authorities  must 
conduct  regular  checks  on  operators  and  traders,  and 
apply  penalties 
the 
amendment  of Article 20 of the Regulation, as of 2019 
the reporting frequency has been changed from every 2 
years to annually, and it covers the calendar year. 

for  non-compliance.  With 

In March 2017 – February 201940, Sweden carried out 6 
checks on domestic timber operators. It also carried out 
60 checks on operators importing timber. It is estimated 
that Sweden had 880 operators placing domestic timber 
types  and  4 473  operators  placing  imported  timber 
types onto the EU market over the reporting period. 

forest 

deforestation 

A  proposal  for  the  Regulation  on  the  making  available 
on  the  EU  market  and  export  of  products  associated 
degradation 
and 
with 
(Deforestation  Regulation)  was  adopted  on  17 
November 2021, following a request from the Council in 
2019  to  table  a  legislative  proposal  to  address  the 
resolution 
problem  and  a  European  Parliament 
recommending that the Commission come forward with 
an  EU  legal  framework  to  halt  and  reverse  EU-driven 

32 EEA, Land take in Europe, December 2021. 
33  The LDN Target Setting Programme | UNCCD 
34  EEA, State of Nature in the EU 
35 EEA, Forest information system for Europe 
36 COM SWD (2021) 652 

37  European  Commission,  JRC,  Mapping  and  assessment  of  primary 
and old-growth forests in Europe, p. 13. 
38 EEA, Conservation status and trend in conservation status by habitat 
group - forests, January 2022. 
39 Regulation (EU) No 995/2010 of the European Parliament and of the 
Council of 20 October 2010. 
40 COM/2020/629 final 

Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
 
                                                                 
Sweden  13 

global  deforestation.  This  Regulation  will  repeal  and 
replace  the  EU  Timber  Regulation,  as  the  new 
Deforestation  Regulation  will  essentially  integrate  and 
improve the existing system for checking the legality of 
traded timber. 

Invasive alien species (IAS) 

of  the  66  species  on  the  Union-concern  list,  16  have 
been  observed  in  the  environment  in  Sweden.  The 
spread can be checked in Figure 13. 

Figure 13: Number of invasive alien species of EU 
concern, based on available georeferenced 
information for Sweden, 2021  

in 

and 

land 

changes 

IAS  are  a  key  cause  of  biodiversity  loss  in  the  EU, 
(alongside 
use, 
sea 
overexploitation, climate change and pollution).  
Besides  inflicting  major  damage  to  nature  and  the 
economy,  many  IAS  also  facilitate  the  outbreak  and 
spread of infectious diseases, posing a threat to humans 
and wildlife.  
The  implementation  of  the  EU    Invasive  Alien  Species 
legislation  must  be 
Regulation  and  other  relevant 
stepped up.  
The  biodiversity  strategy  for  2030  aims  to  manage 
recognised  IAS  and  decrease  the  number  of  ‘red  list’ 
species they threaten by 50%. 

The core of the Regulation (EU) 1143/2014 on Invasive 
Alien Species (the IAS Regulation41) is the list of invasive 
alien species of Union concern.  

The  total  number  of  IAS  of  Union  concern  is  currently 
66,  of  which:  30  are  animal  species;  36  are  plant 
species;  41  are  primarily  terrestrial  species;  23  are 
primarily  freshwater  species;  1  is  a  brackish-water 
species; and 1 is a marine species. 

increased  awareness  of  the  problem 

According  to  a  2021  report42  on  the  review  of  the 
application of the IAS Regulation, its implementation is 
already  starting  to  deliver  on  its  objectives  such  as  a 
coherent framework for addressing these species at EU 
level  and 
in 
general.  At  the  same  time,  the  report  identified  some 
challenges  and  areas  for  improvement.  Given  that  the 
deadlines  for  implementing  the  various  obligations  of 
the IAS Regulation applied gradually between July 2016 
and  July  2019,  it  is  premature  to  draw  conclusions  on 
several aspects of its implementation. 

A 2021 report43 on the baseline distribution shows that 

41  Regulation  (EU)  No  1143/2014  of  the  European  Parliament  and  of 
the Council of 22 October 2014 on the prevention and management of 
the introduction and spread of invasive alien species 
42  Report  from  the  Commission  to  the  European  Parliament  and  the 
Council  on  the  review  of  the  application  of  Regulation  (EU)  No 
1143/2014  of  the  European  Parliament  and  of  the  Council  of  22 
October 2014 on the prevention and management of the introduction 
and spread of invasive alien species, COM(2021) 628 final, 13.10.2021. 

43  Cardoso  A.C.,  Tsiamis  K.,  Deriu  I.,  D'  Amico  F.,  Gervasini  E.,  EU 
Regulation 1143/2014:  assessment  of  invasive  alien species of  Union 
concern  distribution,  Member  States  reports  vs  JRC  baselines,  EUR 
30689 EN,  2021, ISBN 978-92-76-37420-6, doi:10.2760/11150.   

 2022 priority actions  

 

It  is  crucial  to  make  progress  in  the  short  term  in 
effective management, in particular of marine areas, 
and in demonstrating the effectiveness of measures 
in progress throughout the Natura 2000 network. It 
is also necessary to ensure that EU law requirements 
regarding  the  strict  protection  of  species  and 
derogations  from  them  are  fully  implemented  and 
enforced. 

  Where  conservation  statuses  are  not  favourable, 
large  scale action has to be implemented, including 
in  coastal 
restoration:  drivers  of  degradation 
habitats,  dunes  habitats,  grasslands  and  forests, 
which  are 
the  poorest 
the  habitats  with 
conservation  statuses 
in  Sweden,  have  to  be 
adressed. 

  Reversing  the  degradation  processes  at  work  in 
forest habitats and species and removing the drivers 
of  forest  biodiversity  loss  are  key  to  meeting  the 
objectives  of  the  Nature  Directives  and  the  target 
under  the  EU  BDS  for  2030.  This  requires  involving 
the forestry sector in management practices that are 
compatible  with  species  preservation  as  well  as  in 
identifying  and  preserving  areas  of  high  ecological 
value for the Natura 2000 network. 

Environmental Implementation Review 2022 – Sweden 

 
                                                                 
 
 
Marine ecosystems 

The  EU  Biodiversity  Strategy 
for  2030  aims  to 
substantially  reduce  the  negative  impacts  on  sensitive 
species  and  habitats  in  marine  ecosystems  and  to 
achieve good environmental status as well as eliminate 
or 
incidental  catches  of  protected, 
endangered, threatened and sensitive species to a level 
that allows species recovery and conservation[1]. 

reduce 

the 

The  Marine  Strategy  Framework  Directive  (MSFD) 44 
requires Member States to achieve good environmental 
status  (GES)  for  their  marine  waters.  To  that  end, 
Member  States  must  draw  up  marine  strategies  for 
their marine waters, and cooperate with Member States 
sharing  the  same  marine  region  or  subregion.  These 
marine  strategies  comprise  different  steps  to  be 
developed and implemented over 6-year cycles. 

(Article  9),  and  to  provide  an 

The MSFD also required Member States to draw up – by 
15 October 2018 – a set of GES characteristics for each 
descriptor 
initial 
assessment  of  their  marine  waters  (Article  8).  The 
Commission will then assess whether this constitutes an 
appropriate framework to meet the requirements of the 
Directive. 

good 

assessed 

Commission 

2018 
Sweden’s 
The 
for  each  of  MSFD’s  11 
determinations  of  GES 
descriptors45  and determined their level of adequacy in 
relation  to  the  Commission  GES  Decision46.  A  good  or 
very 
the  national 
indicates 
determinations  of  GES  are  well  aligned  with  the 
requirements  of  the  Decision,  i.e.  that  they  provide 
qualitative  and  quantitative  national  environmental 
objectives  to  be  achieved  for  their  marine  waters  (see 
Figure 14).   

score 

that 

Sweden  14 

Figure 14: Level of adequacy of GES determination by 
Sweden (ANS and BAL regions) with criteria set under 
the Commission GES Decision – Article 9 (2018 
reporting exercise)47 

Sweden has two marine sub-regions: 

In  ANS-NE  Atlantic:  Greater  North  Sea,  7  out  of  11 
determinations  of  GES  were  assessed  as  good  or  very 
good.  The  national  determination  of  GES  by  Sweden  is 
consistent  with  requirements  set  under  the  GES 
decision for 7 out of 11 descriptors. 

In  BAL-Baltic  Sea,  6  out  of  11  determinations  of  GES 
were  assessed  as  good  or  very  good.  The  national 
determination  of  GES  by  Sweden  is  consistent  with 
requirements set under the GES decision for 6 out of 11 
descriptors. 

The  MSFD  also  requires  Member  States  to  make  an 
assessment of the current environmental status of their 
marine  waters  in  relation  to  the  determined  GES.  A 
good or very good score indicates that a Member State 
their  marine 
has  good 
environment in accordance with requirements set out in 
the Commission GES Decision. 

capabilities 

to  assess 

[1]  The  EU  Common  Fisheries  Policy  (CFP)  aims  to  contribute  to  the 
achievement  of  the  objectives  of  the  environmental  legislation  for 
marine ecosystems. 
44 Marine Strategy Framework Directive 2008/56/EC  
45 Annex I of Directive 2008/56/EC. 
46  Commission  Decision  (EU)  2017/848  laying  down  criteria  and 
methodological  standards  on  good  environmental  status  of  marine 
waters  and  specifications  and  standardised  methods  for  monitoring 
and assessment, and repealing Decision 2010/477/EU. 

47  Assessment  carried  out  by  the  European  Commission  of  the  data 
reported by the Member States, January 2022. Please note that only 
two sub-sections of descriptor D1 are displayed (D1-M Mammals and 
D1-B Birds). For the analysis, these two sub-sections were considered 
as a whole after averaging them. 

Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
 
                                                                 
Figure 15: Level of adequacy of national assessment of 
Sweden’s marine environment (ANS and BAL regions) 
with criteria set under the Commission GES Decision – 
Article 8 (2018 reporting exercise)48 

In  the  marine  sub-region  ANS-NE  Atlantic:  Greater 
North Sea, 7 descriptors out of 11 were scored as good 
or  very  good.  Sweden’s  assessment  of 
its  marine 
environment  is  consistent  with requirements  set  under 
for  7  out  of  11 
the  Commission  GES  Decision 
descriptors. 

In  the  marine  sub-region  BAL-Baltic  Sea,  7  descriptors 
out of 11  were scored as good or very good. Sweden’s 
assessment of its marine environment is consistent with 
requirements  set  under  the  Commission  GES  Decision 
for 7 out of 11 descriptors. 

For the ANS-NE Atlantic region, Sweden is missing data 
for D11 Energy, including underwater noise. 

is  subject 

Sweden 
infringement 
procedure  relating  to  the  protection  of  harbour 
porpoise from fishing activities. 

to  an  ongoing 

the  MSFD 49,  while 

As  highlighted  in  the  Commission’s  report  on  the 
implementation  of 
regional 
cooperation  has  improved  since  the  adoption  of  the 
MSFD,  more  cooperation 
is  needed  to  attain  full 
regional coherence of the marine strategies, as required 
by the Directive. 

48  Assessment  carried  out  by  the  European  Commission  of  the  data 
reported by the Member States, January 2022. Please note that only 
two sub-sections of descriptor D1 are displayed (D1-M Mammals and 
D1-B Birds). For the analysis, these two sub-sections were considered 
as a whole after averaging them.  
49 COM(2020)259 

Sweden  15 

Furthermore, in March 2022, the European Commission 
published a  Communication  with recommendations for 
Member States. The Commission assessment  highlights 
that  Member  States  need  to  step  up  their  efforts  to 
determine  good  environmental  status  and  use  of 
criteria  and  methodological  standards  according  to  the 
Commission  GES  Decision.  The  above  onsiderations 
form the basis for the 2022 priority actions. 

2022 priority actions 

 

 

Ensure  regional  cooperation  with  Member  States 
that share the same marine (sub)region to address 
predominant pressures. 
Implement  the  recommendations  made  by  the 
in  the  Staff  Working  Document50 
Commission 
accompanying the Communication51, in response to 
recommendations  by  Member  States  and  regions 
on the 2018 updated reports for Articles 8, 9 and 10 
of the MSFD. 

Ecosystem assessment and accounting  

The  EU  biodiversity  strategy  for  2030  calls  on  Member 
States  to  better  integrate  biodiversity  considerations 
into  public  and  business  decision-making  at  all  levels 
and  to  develop  natural-capital  accounting.  The  EU 
needs  a  better  performing  biodiversity  observation 
network and more consistent reporting on the condition 
of ecosystems.  

ecosystem 

incorporate 

services 
Sweden  will 
assessments  within  its  regional  action  plans  for  green 
infrastructure.  The  country 
the 
government  bill:  ‘A  Swedish  strategy  for  biodiversity 
and ecosystem services’.   

implementing 

is 

Sweden has ongoing projects  for communicating about 
ecosystem  services  and  a  research  programme  ‘The 
value of ecosystem services’. All projects aim for one  of 
the  milestone  targets  adopted  as  part  of  Sweden’s 
system of environmental objectives. The importance of 
biodiversity and the value of ecosystem services should, 
since  2018,  be  generally  known  and  integrated  into 
economic  positions,  political  considerations  and  other 
decisions in society, where it is relevant and reasonable 
to do so.  

Sweden  has  not  provided  updated  information  and 
therefore no progress has been recorded since January 
2016  (see  Figure  16).  This  assessment  is  based  on  27 

50 SWD(2022)1392. 
51  COM(2022)550. 

Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
                                                                 
Sweden  16 

implementation  questions  and  updated  every  six 
months.  

Figure 16: ESMERALDA MAES Barometer, January 2016 
2021 52
– 

March 

Progress  on  ecosystem  accounting  implementation  is 
assessed  at  national  level,  based  on  13  questions  (see 
Figure 17). 

Figure 17: Ecosystem accounting Barometer, 
September 202153 

2022 priority actions 

 

Continue  supporting  the  mapping  and  assessment 
of  ecosystems  and  their  services,  and  ecosystem 
accounting  development, 
through  appropriate 
indicators 
integrating  ecosystem  extent, 
for 
condition  and  services  (including  some  monetary 
values) into national accounts; continue supporting 
the  development  of  national  business  and 
biodiversity  platforms, 
including  natural-capital 
accounting  systems  to  monitor  and  value  the 
impact of business on biodiversity. 

52 European Commission, Joint Research Centre, Publication Office, EU 
Ecosystem  assessment:  summary  for  policymakers,  page  80,  May 
2021. 
53  MAIA  Portal,  Mapping  and  assessment  for  Integrated  Ecosystem 
Accounting (EU Horizon 2020 project), 2022. MAIA uses the System of 
Environmental  Economic  Accounting  –  Experimental  Ecosystem 
Accounting (SEEA-EEA) as the methodological basis for the ecosystem 
accounting. The SEEA EA is an integrated an comprehensive statistical 
framework  that  is  based  on  five  core  accounts:  ecosystem  extent, 
condition, services and monetary ecosystem asset. 

Environmental Implementation Review 2022 – Sweden 

 
 
 
                                                                 
Sweden  17 

3. Zero pollution  

Clean air 

its 

EU  clean-air  policy  and  legislation  need  to  significantly 
improve air quality in the EU, moving the EU closer to the 
quality recommended by the WHO and curbing emissions 
of key air pollutants.  
Air  pollution  and 
impacts  on  ecosystems  and 
biodiversity  should  be  further  reduced  with  the  long-
term  aim  of  not  exceeding  critical  loads  and  levels.  This 
requires  strengthening  efforts  to  reach  full  compliance 
with EU clean-air legislation and defining strategic targets 
and actions for 2030 and beyond.  
The  relevant  2030  zero-pollution  action  plan  targets  are 
to reduce the health impacts of air pollution by 55% and 
to reduce the EU ecosystems threatened by air pollution 
by 25% compared to 2005. 

The EU has developed a comprehensive set of air quality 
legislation,  which 
sets  health-based  air  quality 
standards54  and  emissions  reduction  commitments55  by 
Member State for a number of air pollutants.  

for  most  air  pollutants  covered  by  the  Directive  for  the 
period  2020  to  2029  and  for  SO2,  NMVOC  and  PM2.5  for 
2030  onwards.  However, 
the  projections  do  not 
demonstrate  that  Sweden  will  reach  the  emissions 
reduction commitment for NOX for 2030 onwards or the 
commitments  for  ammonia  for  2020-2029  or  2030 
onwards.  Latest  inventory  data  submitted  by  Sweden, 
before  to  review  by  the  Commission,  indicate  that,  in 
2020 Sweden is in compliance with the  commitments for 
NOx,  NMVOC,  SO2  and  PM2.5,  but  not    the   commitment 
for NH3. 

Sweden  submitted  its  National  Air  Pollution  Control 
Programme on 1 April 2019. 

Figure 18: Emission trends of main pollutants/ GDP 
2005-2019 in Sweden62 

Air quality in Sweden continues to give cause for concern. 
The  latest  available  annual  estimates  by  the  European 
Environment  Agency56  point  to  about  2  800  premature 
deaths  (or  26  400  years  of  life  lost  (YLL))  attributable  to 
fine  particulate  matter  concentrations57  220  premature 
deaths  (2  200  YLL)  to  ozone  concentrations58  and  less 
to  nitrogen  dioxide 
than  1 
concentrations59 60.  

than  5  YLL) 

(less 

Emissions  of  key  air  pollutants  have  decreased 
significantly  in  Sweden  in  recent    years,  while  GDP 
growth  has  continued  (see  Figure  18).  According  to  the 
latest projections as submitted under Article 10(2) of the 
Directive  on  National  Emission  reduction  Commitments 
(NECD) 61, Sweden projects to reach  those commitments 

54 European Commission, 2016. Air Quality Standards. 
55 Reduction of national emissions of atmospheric pollutants. 
56  European  Environment  Agency,  Air  Quality  in  Europe  –2021  report. 
in  this  report  as  regards  the  underpinning 
Please  see  details 
methodology, p.106. 
57  Particulate  matter  (PM)  is  a  mixture  of  aerosol  particles  (solid  and 
liquid) covering a wide range of sizes and chemical compositions. PM10 
refers to particles with a diameter of 10 micrometers and less. 
58 Low-level ozone is produced by photochemical action on pollution. 
59  NOx  is  emitted  during  fuel  combustion e.g. from  industrial  facilities 
and  the  road  transport  sector.  NOx  is  a  group  of  gases  comprising 
nitrogen monoxide (NO) and nitrogen dioxide (NO2). 
60  Please  note  that  these  figures  refer  to  the  impacts  of  individual 
pollutants, and to avoid double-counting cannot be added up to derive 
a sum. 
61  Directive 2016/2284/EU. 

62 EEA. 

Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
 
 
 
 
                                                                                                        
 
 
Figure 19: PM2.5 and NOx emissions by sector in 
Sweden, 201963 

For 2020, exceedances above the limit values established 
by  the  Ambient  Air  Quality  Directive  were  registered  for 
carbon monoxide (CO) in one air quality zone and in one 
zone  for  particulate  matter  (PM10).  Furthermore,  for 
several  air  quality  zones  the  target  values  regarding 
ozone concentration have not been met 64. 

Persistent  breaches  of  air  quality  requirements,  which 
have  severe  negative  effects  on  health  and  the 
environment,  are  being  followed  up  by  the  European 
Commission through infringement procedures (mainly for 
PM10  and  NO2  exceedances)  covering  all  Member  States 
concerned,  including  Sweden  for  exceedances  of  PM10 
limit values. The aim is that appropriate measures are put 
in place to bring all zones into compliance.  

63 EEA. 
64  EEA, Eionet Central Data Repository 

Sweden  18 

In  2019  Sweden  received  priority  actions  calling  for 
action  to  (i)  reduce  main  emission  sources  and  (ii) 
accelerate  reductions  in  particulate  matter  (PM2.5  and 
PM10)  emission  and  concentration.  The  first  action  is 
repeated  below, as progress has been limited. Regarding 
the  second  one,  there  has  been  some  progress,  but 
efforts  must  continue,  as  exceedances  of  PM10  limit 
values are still being found.  

2022 priority actions  

 

In  the  context  of  the  National  Air  Pollution  Control 
Programme (NAPCP), take action to reduce emissions 
from the main sources mentioned above. 

  Ensure  full  compliance  with  EU  air  quality  standards 
and  maintain  downward  emissions  trends  for  air 
pollutants, to reduce adverse air pollution impacts on 
health  and  the  economy,  with  a  view  to  reaching 
WHO guideline values in the future. 

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to:  
(i) protect air, water and soil;  
(ii) prevent and manage waste;  
(iii) improve energy and resource efficiency;  
(iv) clean up contaminated  
sites.  
To achieve this, the EU takes an integrated approach to 
the prevention and control of routine and accidental 
industrial emissions. The cornerstone of the policy is the 
Industrial Emissions Directive65 (IED). The Commission 
tabled a proposal  in April  202266. The revision seeks to 
improve the Directive’s contribution to the zero-pollution 
objective, as well as its consistency with climate, energy 
and circular-economy policies  

The  overview  of  industrial  activities  regulated  by  IED 
below  is  based  on  data  reported  to  the  EU  Registry 
(2018)67. 

In  Sweden,  around  1 220  industrial  installations  are 
required  to  have  a  permit  based  on  the  IED.  This 

65  Directive  2010/75/EU  covers  industrial  activities  carried  out  above 
certain thresholds. It covers the energy industry, metal production, the 
mineral and chemical industry, waste management, and a wide range of 
industrial  and  agricultural  sectors  (e.g.  intensive  rearing  of  pigs  and 
poultry, pulp and paper production, painting and cleaning). 
66  European  Commission,  proposal  for  a  revision  of  the  Industrial 
Emissions Directive, 4 April 2022. The revision of the IED is performed in 
parallel to the revision of Regulation (EC) No 166/2006 on the European 
Pollutant Release and Transfer Register (E-PRTR). 
67 EEA, European Industrial Emissions Portal. 

 Environmental Implementation Review 2022 – Sweden 

 
 
 
                                                                 
                                                                 
represents  an  increase  of  almost  200  installations  since 
2015,  mainly  in  the  waste  management  sector  and  the 
intensive rearing of poultry and pigs.  The distribution of 
installations is shown in the Figure 20. 

Figure 21: Emissions to air from IED sectors and rest of 
national total air emissions in Sweden, 201869 

Sweden  19 

industrial  sectors 

in  Sweden  with  most 

The 
IED 
installations  in  2018  are  the  waste  management  sector 
(29%),  followed  by  intensive  rearing  of  poultry  and  pigs 
(24%) and the energy sector (9%). 

Figure 20: Number of IED industrial installations per 
sector in Sweden, 201868 

The  environmental  burdens  for  industrial  emissions  to 
water mainly result from the production of chemicals for 
heavy  metals,  nitrogen,  phosphorous  and  total  organic 
carbon.  The  breakdown,  based  on  E-PRTR  data, 
is 
presented in Figure 22.  

Figure 22: Relative releases to water from industry in 
Sweden, 201870  

The  industrial  sectors 
identified  as  contributing  the 
largest  burden  to  the  environment  for  emissions  to  air 
were  the  energy  –  power  sector  for  arsenic  (As), 
cadmium  (Cd),  mercury  (Hg)  and  zinc  (Zn);  manure 
management  for  ammonia  (NH3);  pulp  and  paper 
industry for nickel (Ni), nitrogen oxides (NOx), particulate 
matter (PM 2.5) and sulphur oxides (SOx); solvent use for 
non  methane  volatile  organic  compounds  (NMVOC); 
metal  production  for  chromium  (Cr),  copper  (Cu)  and 
lead  (Pb);  and  waste  management  for  dioxins.  The 
breakdown is shown in Figure 21. 

68 EEA, EU Registry, European Industrial Emissions Portal (data retrieved 
on 3 November 2021). 

The  EU  approach  taken  to  enforcement  under  the  IED 
creates  strong  rights  for  citizens  to  have  access  to 
relevant  information  and  participate  in  the  permitting 
process. This empowers citizens and NGOs to ensure that 
permits  are  appropriately  granted  and  their  conditions 
complied with.  

As  part  of  environmental 
inspection,  competent 
authorities  undertake  site  visits  to  IED  installations  to 

69  EEA,  LRTAP,  Air  pollutant  emissions  data  viewer  (Gothenburg 
Protocol, LRTAP Convention) 1990-2019 (data retrieved on 3 November 
2021). 
70  EEA,  E-PRTR,  European  Industrial  Emissions  Portal.The  heavy  metals 
are  presented  as  a  weighted  sum  of  eco  toxicity  and  human  toxicity 
factors  to  illustrate  both  the  ecological  and  human  impact  (based  on 
USEtox) (data retrieved on 3 November 2021). 

 Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
 
 
                                                                 
information. 
take  samples  and  to  gather  necessary 
According  to  Article  23(4)  of  the  IED,  site  visits  must  be 
carried out between once a year and once every 3 years, 
depending  on  the  environmental  risks  posed  by  the 
installations. In 2018, Sweden undertook 1 590 site visits, 
most  of  them  to  installations  in  the  waste  management 
sector  (31%), followed by intensive rearing of poultry or 
pigs  (16%)  and  the  energy  sector  (10%),  as  shown  in 
Figure 23 

Figure 23: Number of inspections in IED installations in 
Sweden in 201871 

The  development  of  Best  Available  Techniques  (BAT) 
Reference  Documents  (BREFs)  and  BAT  conclusions 
ensures  good  collaboration  with  stakeholders  and 
enables  a  better  implementation  of  the  IED72.  Since  the 
last EIR report, the Commission adopted BAT conclusions 
for  i)  waste  incineration,  ii)  the  food,  drink  and  milk 
industries  and 
iii)  surface  treatment  using  organic 
solvents including wood and wood products preservation 
with chemicals. 

The  Commission  relies  on  the  efforts  of  national 
competent  authorities  to  implement  the  legally  binding 
BAT  conclusions  and  associated  BAT  emission  levels  in 
environmental permits. This should result in considerable 
and continuous reductions in pollution.  

In  2019,  Sweden  received  priority  actions  to  review 
permits  and  strengthen  control  and  enforcement  to 
ensure compliance with newly adopted BAT conclusions. 
These actions have been followed up by the Commission 
through the reporting by Sweden to the EU Registry and 
the  Commission  is  currently  verifying  with  Sweden  the 
reported information about the permits granted for each 
installation in the scope of the IED. 

71 EEA, EU Registry, European Industrial Emissions Portal (data retrieved 
on 3 November 2021). 
72 European Commission BAT reference documents 

Sweden  20 

Major industrial accidents prevention – 
SEVESO 

The  main  objectives  of  EU  policy  on  major  industrial 
accident prevention are to: 
(i)  control  major  accident  hazards  involving  dangerous 
substances, especially chemicals; 
(ii)  limit  the  consequences  of  such  accidents  for  human 
health and the environment; 
(iii)  continuously  improve  prevention,  preparedness  and 
response to major accidents. 
The cornerstone of the policy is the Directive 2012/18/EU 
(the Seveso-III Directive)73. 

The  overview  below  of  industrial  plants  regulated  by 
Seveso-III Directive (hereafter ‘Seveso establishments’), is 
based on data  reported to the eSPIRS database (2018)74 
and  the  Sweden  report  on  the  implementation  of  the 
Seveso-III Directive for 2015-201875. 

In  Sweden,  of    the  388  Seveso  establishments,  184  are 
categorised as lower-tier establishments (LTE) and 204 as 
upper-tier establishments (UTE)  – based on the quantity 
of hazardous substances likely to be present. The UTE are 
subject to more stringent requirements. The evolution in 
the  number  of  Seveso  establishments  is  presented  in 
Figure 24.  

Figure 24: Number of Seveso establishments in Sweden, 
2011, 2014 and 201876 

According to Sweden, the External Emergency Plan (EEP) 
is required for 204 UTE. In 2018, 198 UTE had an EEP and 
169  of  these  EEP  had  been  tested  over  the  last  3  years. 
The summary is shown in Figure 25. Drawing up  EEPs is 
essential  to  allow  proper  preparation  and  effective 
implementation  of  the  necessary  action  to  protect  the 
environment and the population  in the event of a major 
industrial accident occurring at an establishment. 

73  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances 
74 European Commission, Seveso Plants Information Retrieval System. 
75 As provided for by Article 21(2) of the Seveso-III Directive 
76 European Commission, Assessment and summary of Member States’ 
Implementing  Decision  2014/896/EU 
implementation  reports  for 
(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 

 Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
 
 
                                                                 
Figure 25: Situation regarding EEP in Sweden, 201877 

2022 priority actions 

Sweden  21 

The  information  to  the  public  referred  to  in  annex  V  of 
the Seveso-III Directive – especially about how the public 
concerned will be warned in case of a major accident; the 
appropriate  behaviour  in  the  event  of  a  major  accident; 
and  the  date  of  the  last  site  visit  –  are  permanently 
available  for  100%  of  the  Seveso  establishments  in 
Sweden.  

The  share  of  UTE  for  which  information  on  safety 
measures  and  requisite  behaviours  were  actively  made 
available to the public over the last  years are presented 
in Figure 26.  

Figure 26: Share of UTE for which information on safety 
measures and requisite behaviours were actively made 
available to the public in Sweden, 2011, 2014 and 201878 

  Strengthen  control  and  enforcement  to  ensure 
compliance  with  Seveso-III  Directive  provisions, 
especially on EEP. 

Noise 

The  Environmental  Noise  Directive79  provides  for  a 
common  approach  to  avoid,  prevent,  and  reduce  the 
harmful  effects  of  exposure  to  environmental  noise 
although  it  does  not  set  noise  limits  as  such.  Its  main 
in  this  respect  are  noise  mapping  and 
instruments 
planning.  A  key  target  under  the  2030  zero-pollution 
action  plan  is  to  reduce  by  30%  the  share  of  people 
disturbed by transport noise compared to 2017. 

Excessive noise from aircraft, railways and roads is one of 
the  main  causes  of  environmental  health‐related  issues 
in  the  EU.  It  produces  ischaemic  heart  disease,  stroke, 
interrupted  sleep,  cognitive  impairment  and  stress80.  In 
Sweden,  the  number  of  people  exposed  to  noise 
increased  by  9%  between  2012  and  2017.  Based  on  a 
limited  set  of  data81,  environmental  noise  in  Sweden  is 
estimated  to  cause  at  least  160  premature  deaths  and 
600  hospital  admissions  annually82.  Moreover,  some 
90 000 people suffer from disturbed sleep.  

On the basis of the latest full set of information that has 
been  analysed,  noise  mapping  of  agglomerations,  roads 
and railways is complete.  

In  the  2019  EIR,  Sweden  received  a  priority  action  to 
complete  noise  action  plans,  and  there  has  been 
substantial  progress  as  detailed  above.  Therefore,  no 
priority action is proposed for 2022. 

77 European Commission, Assessment and summary of Member States’ 
implementation  reports  for 
Implementing  Decision  2014/896/EU 
(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 
78 European Commission, Assessment and summary of Member States’ 
Implementing  Decision  2014/896/EU 
implementation  reports  for 
(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 

79 Directive 2002/49/EC 
80 WHO 2018, Environmental Noise Guidelines for the European Region 
81  For  further  information:  European  Environment  Agency,  Noise  Fact 
Sheets 2021. 
82  These  figures  are  an  estimation  by  the  European  Environmental 
Agency  based on  : (i) the  data  reported  by  Member  States  on  noise 
exposure  covered  by  Directive  2002/49/EC; (ii) ETC/ATNI,  2021,  Noise 
indicators under the Environmental Noise Directive 2021: Methodology 
for  estimating  missing  data, ETC/ATNI  Report  No  2021/06,  European 
Industrial 
Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Pollution; (iii) the methodology 
impact 
calculations, ETC/ACM,  2018,  Implications  of  environmental  noise  on 
health  and  wellbeing  in  Europe,  Eionet  Report  ETC/ACM  No  2018/10, 
European Topic Centre on Air Pollution and Climate Change Mitigation. 

health 

for 

 Environmental Implementation Review 2022 – Sweden 

 
 
 
 
 
 
 
 
                                                                 
 
 
                                                                 
Sweden  22 

Progress  is  quite  similar  in  the  different  river  basin 
districts  (RBDs).  It  was  estimated  that  for  50%  of 
measures,  the  objectives  would  be  met  in  2021.  Four 
measures  have  not  yet  started,  but  new  legislation  will 
enable the start of at least two of these measures. There 
are, however, no prospective indicator gaps reported for 
2027. Identified indicator gaps for key type measure  are 
expected to be fully closed by 2027. 

Based  on  the  2nd  RBMPs  reporting  and  data  published 
202089,  in  Sweden  36.8%  of  all  surface  water  bodies90 
reach  good  ecological  status  and  100%  have  poor 
chemical status. For groundwaters, 2.3% failed to achieve 
good  chemical  status  and  0.3.%  are  in  poor quantitative 
status. 

Figure  27  illustrates  the proportion  of  surface  water 
bodies  in  Sweden  and  other  European  countries  that 
failed to achieve good ecological status. 

Figure 27: Proportion of surface water bodies (rivers, 
lakes, transitional and coastal waters) in less than good 
ecological status per River Basin District91 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal  and  fresh  waters 
(including  surface  and  ground  waters)  be  significantly 
reduced.  Achieving,  maintaining  or  enhancing  good 
status  of  water  bodies  as  defined  by  the  Water 
Framework Directive  will ensure that EU citizens benefit 
from good quality and safe drinking and bathing water. It 
will  further  ensure  that  the  nutrient  cycle  (nitrogen  and 
phosphorus)  is  managed  in  a  more  sustainable  and 
resource-efficient way. 

Water Framework Directive 

The  Water  Framework  Directive  83  is  the  cornerstone  of 
the  EU  water  policy  in  the  21st  century.  The  Water 
Framework  Directive  and 
  other  water-related 
legislation84  set  the  framework  for  sustainable  and 
integrated water management, which aims at a high level 
of  protection  of  water  resources,  prevention  of  further 
deterioration and restoration to good status. 

By March 2022, Member States have to report the third 
generation  of  their  river  basin  management  plans 
(RBMPs) under the WFD. The Commission will assess the 
reported status and  progress, checking how the findings 
identified in the assessment of the second RBMPs 85 have 
been  addressed.  Sweden  has  not  yet  reported  its    3rd  
generation of RBMPs86. 

which 

report 87, 

In  December  2021  the  Commission  published  the  6th 
Implementation 
assesses 
implementation  of  the  Water  Framework  and  Floods 
directives.  It  includes  an  interim  assessment  of  progress 
on i) the implementation of the programmes of measures 
and  ii)    monitoring  the  ‘new’  priority  substances.  The 
assessment  report  for  Sweden 88  showed  that  the 
effectiveness  of  the  measures  and  their  contribution  to 
achieving  the  objectives  of  the  Water  Framework 
Directive  in  2021  have  shown  positive  progress  overall. 

83 The Water Framework Directive (2000/60/EC). 
84  This 
includes  the  Groundwater  Directive  (2006/118/EC),  the 
Environmental  Quality  Standards  Directive  (2008/105/EC),  the  Floods 
Directive  (2007/60/EC),  the  Bathing  Water  Directive  (2006/7/EC),  the 
Urban  Waste  Water  Treatment  Directive  (91/271/EEC),  the  new 
Drinking  Water  Directive  (2020/2184/EC),  the  Nitrates  Directive 
(91/676/EEC),  the  Marine  Strategy  Framework  Directive  (2008/56/EC) 
and the Industrial Emissions Directive (2010/75/EU). 
85  Detailed  information  can  be  found  in  the  5th  Report  from  the 
Commission on the implementation of the Water Framework Directive 
and the Floods Directive, as well as in the 2019 EIR. 
86 Based on information provided in April 2022 by Swedish authorities. 
87 See the 6th Implementation Report of the WFD and FD. 
88  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Member  States’  progress  in  Programmes  of  Measures 
during  the  second  planning  cycle  of  the  Water  Framework  Directive. 
Member State: Sweden, 2022. 

Figure  28  presents  the  percentage  of  surface  water 
bodies in Sweden and other European countries failing to 
the 
achieve  good  chemical  status.  For  Sweden, 
percentage  is  100%,  if  one  includes  water  bodies  failing 
due 
to  substances  behaving  as  ubiquitous  PBTs 
(persistent,  bio-accumulative,  toxic).  Without  uPBTs,  1% 
of surface water bodies are failing good chemical status. 

89 WISE Freshwater (europa.eu) 
90 Rivers, lakes, transitional, coastal, territorial 
91 EEA, 2021. 

 Environmental Implementation Review 2022 – Sweden 

 
                                                                 
 
 
                                                                 
 
Figure 28: Percentage of surface water bodies not 
achieving good chemical status92 

Figure 29: Water abstraction per sector in Sweden94  

Sweden  23 

Under  the  IED  framework,  it  should  be  stressed  that 
Sweden  showed  a  significant  decrease  over  the  last 
decade (20.2%) in releases to water of heavy metals like 
Cd, Hg, Ni, PL and (5.8%) in total organic carbon (TOC)93. 

Total  water  abstracted  annually  (corresponding  to  2019 
in Sweden  from  surface  and  groundwater 
baseline) 
sources is 2827.48 hm3  (EEA,  2022).  The  percentage  for 
water  abstraction  per  sector  is  1.89%  for  agriculture, 
27.84%  for  public  water  supply,  2.57%  for  electricity 
for 
cooling,  44.04% 
manufacturing  cooling  and  1.98% 
for  mining  and 
quarrying,  as  illustrated 
in  Figure  29.  Sweden  uses 
different  registers  to  record  water  abstractions.  Small 
abstractions do not require permits in Sweden, although 
prior  notification  to  the  competent  authority  is  needed 
for this. 

for  manufacturing,  21.68% 

92 EEA, December 2019.  
93 EEA, June 2021 

In  Sweden,  the  water  exploitation  index  plus  (WEI+)95  is 
0.69%,  which  is  significantly  lower  than  the  20%  that  is 
generally  considered  to  be  an 
indication  of  water 
scarcity. 

Figure  30  presents  the  WEI+  index  in  Sweden  and  other 
European countries. Sweden is ranked 21st (from high to 
low index) at EU level in terms of WEI+ . 

Figure 30 : Water exploitation index plus (WEI+) inside 
EU, 201796 

Sweden    boosts  water  investments  by  giving  grants  for 
investments  that  minimize  microplastics  and  other 
emerging  pollutants  (pharmaceuticals)  via  stormwater. 
Moreover,  in  2020  a  memo  document 97  was  published 
by the Swedish water authorities as a supportive tool for 
municipal decision-makers providing good arguments for 
more  water  measures  and  sharing  examples  of  how 
much  benefit  these  measures  have  for  water  and  how 
much value can be produced. 

Floods Directive 

As mentioned above, in December 2021 the Commission 

94European  Environment  Agency,  Water  abstraction  by  source  and 
economic sector in Europe, 2022.  
95 The Water Exploitation Index plus (WEI+) is a measure of total fresh 
water  use  as  a  percentage  of  the  renewable  fresh  water  resources 
(groundwater and surface water) at a given time and place. It quantifies 
how  much  water  is  abstracted  and  how  much  water  is  returned  after 
use to the environment. 
96 EEA, Water exploitation Index Plus, 2022.  
97 Nyttan med bättre vatten | Vattenmyndigheterna 

 Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
 
 
                                                                 
published the 6th Implementation Report. It includes the 
review  and  update  of  the  preliminary 
flood  risk 
assessments during the second cycle (2016-2021). 

The  assessment  report 98  showed  that  the  Preliminary 
Flood  Risk  Assessment  (PFRA)  contains  most  of  the 
relevant information in an understandable and accessible 
form.  The report  includes information on how the types 
of  flooding  included  and  the  maps  are  different  in  the 
second  cycle  compared  to  the  first  one.  The  report 
explains  the  new  data  and  information  that  have  been 
included,  in particular  new  and  improved  elevation  data 
and  the  inclusion  of  climate  change  considerations  in 
flood calculations. The assessment identified some areas 
for  further  improvement  related  to  the  assessment  of 
pluvial  floods  and  the  consideration  of 
long-term 
developments, alongside climate change. 

Sweden has reported its second generation of Flood Risk 
Management  Plans  (FRMPs)  under  the  Floods  Directive. 
The European Commission will  assess progress since the 
adoption  of  the  first  Flood  Risk  Management  Plans  and 
publish a new report, as done in 2019.  

Sweden  and  Finland  have  good  cooperation    on  flood 
management. Sweden has carried out a joint project and 
flood mapping with Finland on a shared Area of Potential 
Significant  Flood  Risk  (APSFR)  within  the  international 
River  Basin  District  RBD  SE1TO  sharing  the  River  Torne 
with Finland. 

Drinking Water Directive 

On  the  Drinking  Water  Directive,  no  new  assessment  of 
the  quality  of  Drinking  Water  is  available  since  the  EIR 
2019.  The  quality  of  drinking  water  in  Sweden  has  not 
been indicated as an area of concern. 

The recast Directive 2020/2184 entered into force on 12 
January 2021, Member States have until 12 January 2023 
to  transpose  it  into  their  national  legal  system.  Sweden 
will  have  to  comply  with  these  reviewed  quality 
standards. 

Bathing Water Directive 

Regarding  the  Bathing  Water  Directive,  it  should  be 
highlighted that in 2020, out of the 445 Swedish bathing 
waters,   79.3%  were  of  excellent  quality 99  (Figure  31). 
The evolution is shown in Figure 32.  

Sweden  24 

Figure 31: Bathing water quality in Europe in the 2020 
season100 

Figure 32: Sweden, bathing water quality 2017-2020101 

Nitrates Directive 

The latest Commission Report on the implementation of 
the Nitrates Directive102, referring to 2016-2019103, warns 
that  nitrates  are  still  causing  harmful  pollution  to  water 
in the EU. Excessive nitrates in water are harmful to both 
human health and ecosystems, causing oxygen depletion 
and  eutrophication.  Where  national  authorities  and 
farmers  have  cleaned  up  waters,  it  has  had  a  positive 
impact on drinking water supply and biodiversity, and on 
sectors  such  as  fisheries  and  tourism  that  depend  on 
them.  Nevertheless,  excessive  fertilisation  remains  a 
problem in many parts of the EU. 

98  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Second  Cycle  Preliminary  Flood  Risk  Assessments  and 
Identification  of  Areas  of  Potential  Significant  Flood  Risk  under  the 
Floods Directive : Member State : Sweden, 2022 
99 EEA, Bathing Water Quality in 2020, 2022. 

100 EEA, Bathing Water Quality in 2020, 2022 
101 EEA, European Bathing Water Quality in 2017, 2018, 2019, 2020. 
102 Implementation of the Nitrates Directive in the EU 
103 European Commission, implementation report 2016-2019. 

 Environmental Implementation Review 2022 – Sweden 

 
                                                                 
 
 
 
                                                                 
Sweden has a low livestock density and  a low surplus of 
nitrogen  and  phosphorus.  There  is  a  well-developed 
network of monitoring stations. The groundwater quality 
is  generally  very  good,  but  there  are  a  number  of 
eutrophication. 
stations 
monitoring 
Eutrophication  affects 
inside  Nitrate 
Vulnerable Zones (NVZ) and coastal waters. 

showing 
inland  waters 

The action programme was revised in 2022. 

Urban Waste Water Treatment Directive 

Sweden has over the years encountered some difficulties 
in meeting its obligations under the Urban Waste Water 
Treatment  Directive  (UWWTD).  According  to  the  last 
available data 104, the overall compliance rate  in Sweden 
is  97%,  which  is  higher  than  the  EU  average  of  76%  in 
2018.  

Regarding  the  amount  of  urban  wastewater  which  still 
needs  to  be  collected  or  treated  according  to  the 
requirements of the UWWTD, further efforts are needed 
to  provide  biological  treatment  for  an  additional  0.10 
million  p.e  of  urban  waste  water  (0.8%)  and  biological 
treatment  with  nitrogen  and/or  phosphorus  removal  to 
additional 0.34 million p.e. of urban waste water (3.0%). 

Figure  33:  The  proportion  of  urban  waste  water  that 
meets  all  requirements  of  the  UWWTD  (collection, 
biological treatment, biological treatment with nitrogen 
and/or  phosphorus  removal)  in  compliant  urban  areas 
of the UWWTD (‘compliance rate’), 2018 105 

On  2  September  2021,  the  Court  of  Justice  of  the 
European  Union  found  Sweden  in  breach  of  the  Urban 
several 
Waste  Water  Treatment 
agglomerations.  The  Commission  expects  Sweden  to 
notify  the  measures  that  it  will  take  to  comply  with  the 
ruling.  

respect  of 

in 

2022 priority actions 

  Assess new physical modifications of water bodies in 
line  with  Article  4(7)  of  the  Water  Framework 

104 WISE –  Country profiles on urban waste water treatment - Sweden   
105 European Commission, WISE Freshwater, 2021. 

Sweden  25 

Directive.  In  these  assessments  alternative  options 
and  adequate  mitigation  measures  have  to  be 
considered. 

  Reinforce  action  programme  to  better  address 
eutrophication  issues  for  inland  waters  and  marine 
waters. 

  Complete  the  implementation  of  the  Urban  Waste 
Water Treatment  Directive for all agglomerations, by 
building up the necessary infrastructure. 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects  on  human  health  and  the  environment. 
In 
October 2020,  the  Commission published  its  chemicals 
‘Towards  a  Toxic-Free 
strategy  for  sustainability  – 
Environment’106,  which  led  to  some  systemic  changes  in 
EU chemicals legislation. The strategy  is part  of the EU’s 
zero-pollution  ambition  –  a  key  commitment  of  the 
European Green Deal. 

legislation 107 provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 
for  businesses 
ensures  stability  and  predictability 
operating within the single market.  

Since 2007, the Commission has gathered information on 
the  enforcement  the  Regulation  on  the  Registration, 
Evaluation,  Authorisation  and  Restriction  of  Chemicals 
(‘the  REACH  Regulation’)  and 
the  Regulation  on 
Classification, Labelling and Packaging (‘CLP Regulation’).  

In  December  2020,  the  Commission  assessed  the 
Member  States  reports  on  the  implementation  and 
enforcement  of  these  Regulations108,  in  line  with  REACH 
Article  117(1)  and  CLP  Article  46(2).  According  to  the 
latest  available  data,  national  enforcement  structures 
have  not  changed  much.  However,  it  is  apparent  from 
this  report  that  there  are  still  many  disparities  in  the 
implementation  of  the  REACH  and  CLP  regulations  and 
notably  in  the  area  of  the  law  enforcement.  Recorded 
compliance levels seem to be quite stable over time, but 
with  a  slight  worsening  trend,  which  is  likely  due  to  i) 
in 
enforcement  authorities  being  more  effective 
detecting noncompliant products/companies and ii) more 
non-compliant  products  being  put  on  the  EU  market.  In 
August  2021,  the  Commission  published  a  measurable 
assessment of the enforcement109 of these two main EU 

106 COM(2020) 667 final 
107 REACH: OJ L 396, 30.12.2006, p.1. -  CLP: OJ L 252, 31.12.2006, p.1 
108 European Commission, Final report_REACH-CLP MS reporting 2020. 
109  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators. 

 Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
 
                                                                 
Regulations  on  chemicals  using  a  set  of  indicators  on 
different aspects of enforcement.   

the  total  number  of  REACH  and  CLP  controls  should  be 
noted 113. 

Sweden  26 

Figure 34: Percentage % of non-compliance cases out of 
the total number of REACH and CLP controls during 
2019 per Member State and compared to the EU 
average114 

Responsibility  for  checking  compliance  with  REACH  in 
Sweden lies with the following authorities110:  

 
 
 
 

Swedish Chemicals Agency 
Swedish Work Environment Authority 
Swedish National County Boards 
Swedish Municipal Authorities 

Sweden  has  deviced  and 
implemented  enforcement 
strategies  for  both  REACH  and  CLP111  on  a  risk-based 
approach – companies are selected in those areas where 
there is potential for improvement:  

 

 

 

companies  that  import/manufacture  products 
which contain substances of high concern;  
companies that have high-volume products with 
a wide circulation;  
products  containing  hazardous  substances  and 
used by sensitive groups, such as children;  

  when new regulations come into force;  
  where  there  is  knowledge  of  poor  compliance 

with existing regulations etc.  

is  based  on  a  product  register 
Enforcement  action 
containing  information  on  chemicals  manufactured  or 
imported  to  Sweden.  For  articles,  companies  are 
monitored 
customs, 
advertising, the internet etc 

associations, 

through 

trade 

As  a  rule,  all  infringements  of  REACH  are  classed  as 
serious  or  very  serious  environmental  administrative 
offences.  If  the  infringement  is  sufficiently  serious,  the 
impose  further 
competent  authority  may  decide  to 
penalties  in  addition  to  a  fine.  That  authority  may  also, 
where  necessary,  order  the  provisional  seizure  of  assets 
and documents.  

2022 priority actions 

  Upgrade 

implementation 

enforcement 
administrative capacities to enable zero tolerance for 
non-compliances. 

and 

carried 

In  Sweden  9  000  -  9  500  man-hours  annually  are 
allocated  to  REACH  and  7  700  man-hours  to  CLP 
enforcement112,  not  including    the  work  done  by  staff 
members  of  the  300  national  and  the  290  municipal 
authorities.  More  than  3  000  REACH  and  CLP  controls 
were 
period 
(2019).   Although  the  actual 
level  of  expertise  has 
increased  since  the  last  reporting  round,  it  is  still  not 
sufficient for some specific tasks under REACH, namely in 
relation  to  risk  management  and  some  specific  areas  of 
concern such as nanomaterials and endocrine disruptors. 
The  significant  percentage  of  non-compliance  cases  in 

reporting 

out 

the 

in 

110  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators 
111 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 76. 
112 European Commission, Final Report, on the operationof REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 75. 

113  Final  report_REACH-CLP  MS  reporting_2020.pdf  (europa.eu),  p.  87-
88 
114 European Commission, Final Report, on the operation of REACH and 
CLP, pp.87-88, 2022. 

 Environmental Implementation Review 2022 – Sweden 

 
                                                                 
 
 
                                                                 
 
Sweden  27 

4. Climate Action

to 

(NDC) 

law  also 

In  line  with  the  Paris  Agreement  and  as  part  of  the 
European Green Deal, the European Climate Law sets the 
EU  target  of  reaching  climate  neutrality  by  2050  and 
reducing  greenhouse  gas  (GHG)  emissions  by  55%  by 
2030  compared  to  1990.  The 
limits  the 
contribution  that  carbon  removals  can  make  towards 
emission  reductions 
in  2030  to  ensure  a  sufficient 
mitigation effort.  
The  EU  and  its  Member  States  submitted  updated 
Nationally  Determined  Contribution 
the 
UNFCCC in December 2020.  
The  EU  is  working  across  all  sectors  and  policies  to  cut 
GHG  emissions  and  make  the  transition  to  a  climate-
neutral  and  sustainable  economy,  as  well  as  addressing 
the unavoidable consequences of climate change.  
EU  climate  legislation  incentivises  emissions  reductions 
from power generation, industry, transport, the maritime 
sector and fluorinated gases (F-gases) used in products.  
For  road  transport,  EU  legislation  requires  the  GHG 
intensity  of  vehicle  fuels  to  be  cut  by  6%  by  2020 
compared  to  2010115  and  sets  binding  GHG  emission 
standards for different vehicle categories116.  
Under the F-gas Regulation, the EU’s F-gas emissions will 
be cut by two thirds by 2030 compared with 2014 levels. 
From  2021,  emissions  and  removals  of  GHGs  from 
LULUCF have been included in the EU emission-reduction 
efforts.  
The  EU  adaptation  policy  is  an  integral  part  of  the 
European  Green  Deal.  From  2021,  Member  States  are 
required 
their  national  adaptation 
policies117,  as  the  EU  Climate  Law  recognises  adaptation 
as a key component of the long-term global response to 
climate change. Member States will be required to adopt 
national  strategies,  and  the  EU  will  regularly  assess 
progress  as  part  of  its  overall  governance  on  climate 
action. The updated EU adaptation strategy, published in 
February  2021,  sets  out  how  the  EU  can  adapt  to  the 
unavoidable  impacts  of  climate  change  and  become 
climate resilient by 2050. 

report  on 

to 

Key national climate policies and strategies 

Sweden  has  combined  sustained  economic  growth  with 
successful  efforts  to  reduce  greenhouse  gas  (GHG) 

emissions  over  a  longer  period.  It  is  among  the  EU 
Member  States  with  the  lowest  GHG  emissions  per 
capita. Its national GHG  emission reduction targets aims 
at a reduction in non-ETS emissions (from sectors outside 
the EU’s emissions trading system)118 by 2030 of at least 
63%  compared  to  1990  levels.  This  translates  to  a  59% 
reduction  compared  to  2005  (of  which  8  percentage 
points may be reached with  ‘complementary measures’, 
(these    may  include  bio-CCS119,  an  increased  LULUCF120-
sink and verified emission rights produced and purchased 
from outside Sweden). This target is more ambitious than 
its  current  EU  commitments  under  the  Effort  Sharing 
Regulation,  which  require  Sweden  to  cut  emissions  by 
40%  in  2030  compared  to  2005  levels.  According  to  a 
decision in the Swedish parliament in 2017, Sweden must 
reach  carbon  neutrality  by  2045.  The  national  carbon 
neutrality  target  is  formulated  as  a  reduction  in  total 
emissions,  excluding  LULUCF,  of  by  85%.  The  remaining 
emissions should be offset by the use of   complementary 
measures. The climate law that was also adopted in 2017 
requires  current  and  future  governments  to  pursue 
policies  based  on  national  climate  objectives.  The  law 
contains  elements 
is 
integrated into budget  planning as well as policy follow-
up. The Swedish Climate Policy Council - an independent 
expert  body  –  assesses  whether  the  overall  policy 
decided  by  the  government  is  in  line  with  the  climate 
objectives. 

that  ensure  climate  action 

Sweden  has  an  integrated  National  Energy  and  Climate 
Plan  (NECP)  for  2021-2030,  which  builds  on  long-term 
energy  and  climate  plans  and  roadmaps  and  is  also 
for 
consistent  with  Sweden’s  Long-term  Strategy 
Reducing  Greenhouse  Gas  Emissions.   To  achieve  carbon 
neutrality  by  2045,  the  government  has  recognised  the 
need for further measures. Its climate policy action plan, 
published  in  December  2019,  presents  132  measures 
across  different  sectors.  The  focus  is  on  reducing  GHG 
emissions  from  the  transport  sector.  More  broadly,  the 
government  is  continuing  its  policy  of  significant  pricing 
of  emissions,  to  reduce  them  while  at  the  same  time 
considering  a  shift  from  labour  and  corporate  taxes 
towards environmental taxes.  

The  National  Strategy  for  Climate  Change  Adaptation 
includes  Sweden’s  climate  change  adaptation  goals, 

115  The Fuel  Quality  Directive (Directive 98/70/EC)  sets  strict  quality 
requirements  for  fuels  used  in  road  transport  in  the  EU  to  protect 
human health and the environment, and to make road travel across the 
EU safer. 
116 Directive 98/70/EC. 
117 Article 29 of Regulation (EU) 2018/1999. 

118  Sectors currently  outside  of  the  European  Emission Trading  System 
(ETS) 
include  buildings,  road  and  domestic  maritime  transport, 
agriculture, waste and small industries, and F-gases. 
119 carbon capture and storage 
120 land use, land-use change and forestry 

 Environmental Implementation Review 2022 – Sweden 

 
                                                                 
                                                                 
Sweden  28 

Figure 36: Emissions and targets under the Effort 
Sharing Decision / Effort Sharing Regulation in Sweden, 
2020 and 2030 as percentage change from 2005 

guiding  principles,  organisation  and  distribution  of 
responsibilities,  monitoring,  financing  principles  and 
knowledge-boosting initiatives. The strategy is evaluated 
in  5-year  cycles  and  will  next  be  updated  in  2023, 
supported by an Expert Council on Adaptation, which the 
Government 
government’s 
nominated. 
Ordinance  on  Agencies’  Climate  Change  Adaptation 
(2019)  regulates  the  work  done  on  climate  change 
adaptation  by  32  agencies  and  all  county  administrative 
boards.  

The 

has 

Between 1990 and 2020, economy-wide greenhouse gas 
emissions  in  Sweden  decreased  by  35%.  It  is  among  the 
EU  Member  States  with  the  lowest  GHG  emissions  per 
capita (see Figure 35). 

Figure 35: Total greenhouse gas emissions (incl. 
international aviation) in Sweden, 1990-2020 

Figure 37: Emissions, annual emission allocations (AEAs) 
and accumulated surplus/ deficit of AEAs under the 
Effort Sharing Decision in Sweden, 2013-2020  

Effort sharing 

For emissions not covered by the EU’s emissions trading 
system  (ETS),  Member  States  have  binding  national 
targets under the EU’s Effort Sharing legislation. Sweden 
has a target of reducing greenhouse gas emissions in the 
non-ETS  sectors  (buildings,  road  and  domestic  maritime 
transport, agriculture, waste and small industries) by 17% 
by 2020 and 40% by 2030, compared to 2005 levels (see 
Figure  36).  The  country’s  emissions  in  2019  from  these 
sectors  were  well  below  its  2020  target.  Sweden  has 
decided not to sell or bank its surplus of annual emissions 
allocations 
its 
overachievement of the EU climate target. 

contributing 

(AEAs), 

thus 

to 

In its National Energy and Climate Plan, Sweden projects 
to achieve reductions in line with its current EU target for 
2030 (see Figure 37). 

 Environmental Implementation Review 2022 – Sweden 

 
 
 
 
 
 
 
 
 
 
 
 
Key sectoral developments 

In  road  transport,  the  GHG  intensity  of  vehicle  fuels  in 
Sweden  decreased  by  18.6%,  meaning  that  Sweden 
substantially overachieved the current EU-wide reduction 
obligation  of  6%  by  2020.  There  are  several  types  of 
action  that  Member  States  can  take  in  this  regard,  for 
example,  i)  further  expanding  the  use  of  electricity  in 
road  transport  ii)  supporting  the  use  of  biofuels,  and 
advanced  biofuels  in  particular,  iii)  incentivising  the 
development and deployment of renewable fuels of non-
biological  origin  and  iv)  reducing  upstream  emissions 
before refining processes. 

in  Sweden. 

In  2019  road  transport  represented  28%  of  the  total 
greenhouse  gas  emissions 
Improving 
Sweden’s  transport  infrastructure  and  making  it  climate 
friendly  is  a  key  challenge.  Emissions  have  decreased  by 
24%  compared  to  2005.  The  national  objective  is  to 
decrease  emissions  from  domestic  transport  (except 
aviation)  by  at  least  70%  by  2030  from  2010  levels. 
Recent initiatives for long-term investment have focused 
on  making  transport  sustainable  by  upgrading  the 
different  transport  modes,  in  particular  railways.  In  July 
2018,  a  greenhouse  gas  emissions  reduction  obligation 
for petrol and diesel, in conjunction with fuel tax reforms, 
called  the  Fuel  Change,  was  implemented.  The  emission 
reduction  obligation  establishes  an  obligation  on  petrol 
and diesel suppliers to reduce carbon dioxide emissions, 
increasing  blending  with  sustainable 
by  gradually 
biofuels.  The  reduction  obligation  scheme  makes  an 
important contribution to phasing out  fossil fuels in road 
transport.  Since  2021,  Sweden  also  has  an  emissions 
reduction obligation for aviation. 

A  number  of  measures  have  been  adopted  to    support 
charging infrastructure for electric vehicles in rural areas. 
The government has introduced a new climate bonus for 
electric  lorries  and  electric  working  machines,  merged  it 
with  the  existing  electric  bus  bonus  and  boosted  the 
funding by SEK 20 million for 2020, bringing it to SEK 120 
million.  In  addition,  the  eco-bonus  system,  designed  to 
promote  a  shift  in  goods  transport  from  road  to  ship,  is 
being prolonged, with SEK 50 million per year until 2022. 
Sweden’s  maritime  transport  sector  is  also  preparing 
to end the use of fossil fuels domestically by 2045, in line 
with the national climate objectives. 

To  further  reduce  emissions  from  buildings,  energy 
efficiency investments are needed, as the building sector 
has  a  role  to  play  in    meeting  energy  efficiency  and 
climate  targets  for  2030  and  beyond.  Sweden  has 
presented  a  comprehensive  set  of  energy  efficiency 
measures  for  the  buildings  sector  in  its  national  long-
term renovation strategy. Implementing this strategy will 
go a long way towards  increasing energy efficiency, but 
more  effort  is  needed  to  reach  EU  energy  efficiency 
targets.  In  addition,  Sweden  plans  to  carry  out  the 

Sweden  29 

renovation  of  its  building  stock  in  stages,  depending  on 
the age of the building. In particular, priority would need 
to  be  given  to  improving  the  energy  efficiency  of  the 
worst  performing  buildings  and  to  reducing  energy 
poverty.   

Emission  from  agriculture  have  not  decreased  and  are 
comparable to their 2005 levels. 

Figure 38 shows GHG emissions by sector. 

Figure 38: Greenhouse gas emissions by sector in 
Sweden121 – historical emissions 1990-2019, projections 
2021-2030122  

Sweden  expects  the  LULUCF  sector  to  continue  to 
contribute  annual  net  removals  in  future.  Projections 
indicate a small decrease in net removals by 2030, under 
existing  measures.  Reported  quantities  under  the  Kyoto 
Protocol  for  the  LULUCF  sector  in  Sweden  show  net 
removals of, -41.4 Mt CO2-eq on average for  2013-2019. 
In this regard, Sweden contributes  12.0% to the  EU27’s 
annual average sink of -344.9 Mt CO2-eq (see Figure 39). 

Figure 39: Reported and accounted emissions and 
removals from LULUCF in Sweden123 

121  The  sectors  in  the  figure  correspond  to  the  following  IPCC  sectors: 
Energy supply: 1A1, 1B and 1C. Energy use in manufacturing industries: 
1A2.  Industrial  processes  and  product  use:  2.  Transport:  1A3.  Other 
energy  use:  1A4,  1A5  and  6.  Agriculture:  3.  Waste:  5.  International 
aviation: 1.D.1.a. 
122 European Environmental Agency, Total GHG trends and projections. 
123  The  differences  between  reported  and  accounted  emissions  from 
LULUCF under the Kyoto Protocol are described in the ‘explanatory note 
on  LULUCF  –  accounted  and  reported  quantities  under  the  Kyoto 
Protocol’. 

 Environmental Implementation Review 2022 – Sweden 

 
 
 
                                                                 
Sweden  30 

Use of revenues from the auctioning of EU ETS 
allowances 

from  auctioning  of  emissions 
The  total  revenues 
allowances  under  the  EU  ETS  over  2013-2020  were  EUR 
834.5 million.  Revenues are not earmarked but example 
projects  have  been  reported  for  at  least  the  minimum 
required spending on energy and climate. 

2022 priority actions 

 
 

 

 

 

road 

require 

transport  will 

Increase the sustainability of the transport sector 
Support  further  renewable  energy  production  as 
decarbonisation  of  industry  and  the  electrification 
of 
significant 
investments  in  new  wind  power  and  renewable 
electricity generation 
Support  investment  in  new  electricity  transmission 
and  distribution  infrastructure,  as  well  as  sector 
integration and energy storage technologies 
Ensure  the  sustainable  use  of  biomass,  as  biomass 
use  is  likely  to  increase.  Biofuels  will  continue  to 
play  an  important  role  for  decarbonisation  and 
electrification,  including  by  serving  the  cause  of 
  and  the  decarbonisation  of 
clean  transport 
industrial processes. 
Support 
renovating buildings 

in  energy  efficiency  by  

investment 

 Environmental Implementation Review 2022 – Sweden 

 
 
 
 
Sweden  31 

Part II: Enabling framework: implementation tools 

5. Financing

Environmental investment needs in the 
European Union. 

Financing  environmental  measures  is  essential  for  their 
success.  Although  most  financing  comes  from  national 
sources, various EU funds contribute significantly, helping 
to close the financing gaps. 
Post-2020,  environmental  measures  will  also  be 
supported  by the EU’s  COVID-19 Recovery  Fund (via  the 
Recovery  and  Resilience  Facility)  and  the 
‘do  no 
significant  harm’’  principle  across  the  EU  budget.  The 
(Glasgow, 
renewed  commitments  made  at  COP26 
October-November 2021), 
Biodiversity 
Convention  COP15  (April-May  2022)124  will  also  be 
reflected in the EU budget.  

and 

the 

Overall environmental investment gaps (EU27)  

The EU’s investment needs for the green transition cover 
a  range  of  interlinked  areas.  The  additional  investment 
needs  over  baselines  (i.e.  the  gap  between  what  is 
needed  and  what  is  forecast  to  be  invested  if  no 
additional  action 
is  taken)  for  climate,  energy  and 
transport were estimated in 2021 to be EUR 390 billion a 
year  (EU27)  125,  with  a  further  EUR  130  billion  a  year  to 
deliver  the  EU’s  core  environmental  objectives126.  The 
costs  of  climate  adaptation  can  also  be  significant,  and 
are  estimated  to  reach  a  total  of  EUR  35-62  billion 
(narrower  scope)  or  EUR  158-518  billion  (wider  scope) 
per  year127.  Those 
the 
implementation objectives to 2020 and to 2030   (except 
for  climate  change  adaptation,  the  costs  of  which  are 
expected to last over a longer time horizon). 

investment  needs 

reflect 

A  preliminary  update  of  the  EU’s  core  environmental 
investment  gap  is  provided  in  Table  1128.  Almost  40%  of 

the  environmental  investment  needs  relate  to  dealing 
with  pollution,  which  accounts  for  nearly  two-thirds  of 
the  total  if  combined  with  water  management.  The 
investment  gap  in  circular  economy  and  waste    is 
estimated  at  EUR  13-28  billion  a  year,    depending  on 
levels of circularity implemented. The annual biodiversity 
financing gap is estimated at around EUR 20 billion.  

Table 1: Estimated breakdown of the EU’s 
environmental investment needs, by environmental 
objective129 

Estimated investment gap (EU-27, 
p.a.)  

Environmental 
objective 

Pollution  prevention 
& control 

Water  management 
& industries 

Circular  economy  & 
waste 

 EUR billion 

 42.8 

 26.6 

 13.0 

Biodiversity 
ecosystems130 

R & D & I and other 

Total 

& 

 21.5 

 6.2 

 110.1 

 % 

 39% 

 24% 

 12% 

 20% 

 6% 

 100% 

Environmental investment needs in Sweden 

There is a  shift  in investment priorities in  most  Member 
States of the EU towards support for climate, energy and 
transport policies, as reflected in national RRPs. 

For  Sweden,  the  following  environmental  investment 
needs have been identified by sector.   

124  The  Convention  on  Biological  Diversity  (cbd.int); Post-2020  Global 
Biodiversity Framework | IUCN. 
125  SWD(2021)  621,  accompanying  proposal  COM(2021)  557  to  amend 
the REDII Directive (EU) 2018/2001. 
126 SWD (2020) 98 final/2 
127 SWD(2018)292 Impact assessment accompanying the LIFE Regulation 
128    With  decreases  due  to  Brexit  and  some  reconciliation  among  the 
objectives.  Source:  DG  ENV  ”Study  supporting  EU  green  investment 
needs  analysis”  (ongoing,  2021-2023)  and  DG  ENV  internal  analysis 
”Environmental  investment  needs  and  financing  in  the  EU’s  green 
transition” July 2020. 

129 European Commission, DG Environment, ”Study supporting EU green 
investment needs analysis” (ongoing, 2021-2023) and DG Environment 
internal analysis ”Environmental Investment needs and financing in the 
EU’s green transition“,  July 2020.  
130  To  meet  the  needs  of  the  2030  Biodiversity  Strategy  (Natura 2000, 
green infrastructure), at least EUR 20 billion a year should be unlocked 
for  nature  (COM/2020/380  final)  while  to  fully  cover  the  strategy 
(including restoration) EUR 30-35 billion may be needed. This indicates 
a  gap  of  EUR  10-20  billion  a  year  compared  to  current  baseline 
expenditure. 

 Environmental Implementation Review 2022 – Sweden 

 
 
 
 
 
                                                                 
 
                                                                 
Pollution prevention & control 

The  EU’s  first  Clean  Air  Outlook131  under  the  clean  air 
programme estimated that the total air pollution control 
costs  for  Sweden  to  reach  NECD  emission  reduction 
requirements (ERRs)132 by 2030 amount to EUR 1.2 billion 
per  year.  This  includes  EUR  742  million  for  capital 
investment  and  assumes  the  2030  climate  and  energy 
targets are met. 

The  second  Clean  Air  Outlook 133 suggests  that  the 
EU would  largely  achieve  the  reductions  in  air  pollutant 
emissions  that  correspond  to  the  obligations  under  the 
NEC  Directive  for  2030,  if:  (i)  all  relevant  legislation 
adopted  up  to  2018  is  implemented  (including  all  air 
pollution and the 2030 climate and energy targets set in 
2018);  and  (ii)  Member  States  also  implemented  the 
in  their  national  air  pollution 
measures  announced 
control programmes. The only exception is for ammonia 
for 15 Member States, including Sweden.   

Water management  

According  to  the  OECD  study  ‘Financing  Water  Supply 
Sanitation and Flood Protection (2020)’134, Sweden relies 
on  a  mix  of  conventional  (e.g.  groundwater  and  fresh 
water)  and  non-conventional  (e.g.  artificial  recharge) 
resources for its water supply.  
EU  funding  has  provided  a  significant  share  of  public 
funding over the past decade135. It is also estimated that 
Sweden will need to invest an additional cumulative EUR 
2.1 billion by 2030 over baselines for drinking water and 
sanitation – corresponding to around EUR  210 million of 
investment  needed  (capital  expenditure)  per  year,  with 
over  90%  of  that  relating  to  wastewater136.  Moreover, 
the  recent  6th  Water  Framework  Directive  and  Floods 
the 
Directive 

Implementation 

Report137 

and 

131 International Institute for Applied Systems Analysis (IIASA), Progress 
towards  the  achievement  of  the  EU's  air  quality  and  emissions 
objectives, 2018 
132  Covering  the  reductions  of  and  the  emission  ceilings  for  5 
atmospheric  pollutants,  SOx,  NOx,  PM2.5,  NH3  and  VOC  by  2030, 
compared  to  2005.  Source:  Progress  towards  the  achievement  of  the 
EU’s  air  quality  and  emissions  objectives,  IIASA  2018.  (page  29). 
Requirements are based Directive (EU) 2016/2284 
133  COM(2021)  3  final.  International  Institute  for  Applied  Systems 
Analysis  (IIASA),  Support  to  the  development  of  the  Second  Clean  Air 
Outlook, 2020 and Annex 
134  OECD,  Financing  Water  Supply,  Sanitation  and  Flood  Protection: 
Challenges and Options, 2020 
135  OECD,  Financing  Water  Supply,  Sanitation  and  Flood  Protection: 
Challenges and Options, 2020 
136  OECD,  Sweden  -  Country  fact  sheet  -  Financing  Water  Supply, 
Sanitation 
Protection 
https://www.oecd.org/environment/resources/latestdocuments/2/  
137  European  Commission,  Water  Framework  Directive  and  Floods 
Directive Implementation Reports. 

Flood 

and 

Sweden  32 

financial/economic  study138  accompanying  it,  are  also  a 
relevant source of information in this regard.  

Waste & circular economy 

According  to  a  Commission  study139,  to  meet  the 
recycling  targets  for  municipal  waste  and  packaging 
waste,  Sweden  still  needs  to   invest  an  additional  EUR 
313 million over baselines (around 44.7 million per year) 
in  2021-2027 
in  collection,  recycling  reprocessors, 
biowaste  treatment  and  waste  sorting  facilities,  and 
waste  registry  digitalisation.   This  does  not 
include 
investment  necessary  for  other  key  waste  streams 
(plastics, textile, furniture) or to prompt a higher uptake 
of circularity and waste prevention across the economy .  

Biodiversity & ecosystems 

The  recently  submitted  priority  action  framework  (PAF) 
for Sweden shows that nature protection costs (including 
Natura 2000) in 2021-27 are EUR 5.44 billion – or around 
EUR 777.3 million per year (including EUR 240 million of 
annual  one-off  costs)140.  This  does  not  cover  additional 
costs  for  implementing  the  2030  biodiversity  strategy, 
including  costs  relating  to  increased  protection  and 
restoration.  

EU environmental funding 2014-2020 

The  multiannual  financial  framework  (MFF)  for  2014-
2020  allocated  almost  EUR  960  billion  (in  commitments, 
2011 prices)141 for the EU to spend over this period. That 
commitment  to  green  transition  included  a  20%  climate 
spending  target.  It  also  included  funding  opportunities 
for  the  environment,  in  particular,  under  the  European 
Structural  and  Investment  (ESI)  Funds142.  The  2014-2020 
budget  was  subsequently  topped  up  with  over  EUR 50 
billion (current prices) from REACT-EU for cohesion policy 
action against coronavirus (COVID-19)143.  

138  European  Commission,  Directorate-General 
for  Environment, 
Economic  data  related  to  the  implementation  of  the  WFD  and  the  FD 
and the financing of measures, Final report. Publications Office, 2021. 

139 European Commision, Study on investment needs in the waste sector 
and  on  the  financing  of  municipal  waste  management  in  Member 
States, 2019. 
140  The  N2K  Group,  Strengthening  investments  in  Natura  2000  and 
improving  synergies  with  EU  funding 
instruments  report  to  the 
European Commission, 2021 
141 Council Regulation (EU, Euratom) No 1311/2013. 
142  The  European  Structural  and  Investment  (ESI)  Funds  include  the 
European  Regional  Development  Fund  (ERDF),  the  Cohesion  Fund (CF) 
which Sweden does not recei, the European Social Fund (ESF) with the 
Youth  Employment  Initiative  (YEI),  the  European  Agricultural  Fund  for 
Rural  Development  (EAFRD)  and  the  European  Maritime  and  Fisheries 
Fund (EMFF).   
143 Regulation (EU) 2020/2221. 

 Environmental Implementation Review 2022 – Sweden 

 
                                                                 
 
                                                                 
Sweden received EUR 4.54 billion from the ESI Funds over 
2014-2020 to invest in job creation and a sustainable and 
healthy  European  economy  and  environment.  The 
planned  direct  environmental  investment  amounted  to 
EUR  94.9  million,  with  further  99.3  million  identified  as 
indirect  environmental  investment  value,  totalling  EUR 
194.2 million (Table 2). Figure 40 provides an overview of 
(planned) individual ESI Funds earmarked  specifically  for 
Sweden  (EU  amounts,  without  national  amounts)  for 
2014-2020 
investments 
contained.   

environmental 

and 

the 

Figure 40: 2014-2020 ESI Funds allocated to Sweden, 
including environmental investment144  

Policy 

Funds 

(COWI, 

2017), Regulation 

144  European  Commission,  DG  Environment  -  Data  analysis,  DG 
Environment  analysis  based  on  ESI Funds Open  Data  Portal 
(cohesiondata.ec.europa.eu), Integration  of  environmental  concerns  in 
Cohesion 
(EU)  No 
1303/2013,Regulation  (EU)  2021/1060 and Implementing  Regulation 
for  data:  December  2021. 
(EU)  No  215/2014. Cut-off  date 
Environmental  investment  here  is  captured  via  the  combined  use of 
intervention 
(EU)  No 
1303/2013 and Regulation (EU) 2021/1060,  allowing for a more precise 
identification and valuation of relevant environmental investment. N.B. 
I 
indirect  environmental 
environmental 
(EU)  2021/1060 (as 
opposed to full value).  

fields  and  coefficients  under  Regulation 

is  valued  using  the  Annex 

from Regulation 

coefficients 

investment 

Sweden  33 

Table 2: Direct and indirect environmental investments 
under the ESI Funds in Sweden 2014-2020145 

Instrument 

Under Cohesion policy (ERDF) 
Direct environmental investments 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 
sustainable transport 
business development, R&I 

Under EAFRD/rural development 
Direct environmental investments 
climate and risk management 
Indirect environmental investments 
renewable energy 

Under EMFF 
Direct environmental investments 
environment  protection  &  resource 
efficiency 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

Allocations  
for the environment  
(EUR million) 

96.9 
1.3 
1.3 
95.5 
1.3 
32.0 
24.3 
38.0 

13.7 
9.9 
9.9 
3.8 
3.8 

83.6 
83.6 
83.6 

194.2 
94.9 
99.3 

supplemented  by  other  EU 

Funding  for  the  environment  from  the  ESI  Funds  has 
been  also 
funding 
programmes available to all Member States, such as, the 
loans  from  the 
LIFE  programme,  Horizon  2020  or 
European  Investment  Bank  (EIB).  This  adds  up  to  an 
estimated  total  of  EUR 655  million  of  EU  environmental 
financing for Sweden in 2014-2020.  

is  entirely  dedicated 

The  LIFE  programme146 
to 
environmental  and  climate  objectives.  It  finances  pilot 
and  best  practice  actions  for  green  solutions  to  be 
deployed. In 2014-2020, Sweden received EU support for 
21  LIFE  projects  (for  nature  and  environment)  with  EUR 
89.9  million  from  the  LIFE  programme  (out  of  1 028  EU-
27 LIFE projects with a total EU contribution of EUR 1.74 
billion)147. 

investments 

145  European  Commission,  DG  Environment  -  Data analysis. The  values 
in  the  specific 
for  environmental 
environmental  areas  may  differ 
values 
tracking 
at cohesiondata.ec.europa.eu, e.g. for clean  air or biodiversity due  to 
two factors: the set of environmental coefficients used and the range of 
funds assessed. DG Environment’s analysis here  covered the full range 
of ESI Funds. See previous footnote.  

identified  here 
the 
from 

146 European Commission, LIFE Programme. 
147 Source: CINEA 

 Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
  
 
                                                                 
Sweden  34 

In  2014-2020,  Horizon  2020  allocated  Sweden  EUR 90.2 
million  for  the  environment  –  specifically  for  climate 
action, circular economy and raw materials, which is 3.9% 
of Sweden’s total allocation148. From the European Fund 
for Strategic Investments (EFSI), Sweden received a total 
of EUR 1 849 million in financing. Of this, EUR 256 million 
related  to  direct  environmental  projects,  with  a  further 
EUR 120  million  indirect  investment  value  from  other 
projects149. 

The environment-related EIB loans to Sweden amounted 
to  EUR 161.6  million  (supporting  mostly  water  and 
sewerage), out  of an overall  EUR 12.6 billion EIB lending 
to Sweden in the period150. The country ranks 8th in size 
in total EIB lending. 

In  2020,  the  EIB  provided  EUR 24.2  billion  in  funding 
across  Europe  to  fight  climate  change,  37%  of  its  total 
financing.  It  also  provided  EUR 1.8  billion  (3%  of  its 
financing) for the environment151. 

(by  developing 

(2020)157,  sustainable 

the  EU  green  bond 
green  bond 
standard156).  Reinforced  by  the  renewed  sustainable 
finance  strategy 
finance  will 
increase  investment  flows  to  climate  and  environment. 
The new strategy on adaptation to climate change158 can 
help  to  close  the 
insurance-protection  gap,  which 
currently  leaves  many  risks  from  climate-related  events 
uninsured159.  The  EIB  will  align  50%  of  its  lending  with 
climate  and  environment  by  2025160  with  an  EUR 250 
billion contribution to the Green Deal investment plan by 
2027. 

Table  3  gives  an  overview  of  the  EU  funds  earmarked 
specifically  for  Sweden  for  2021-2027.  These  funds  are 
also supplemented by other EU funding programmes that 
are available to all Member States. 

Table 3: Key EU funds allocated to Sweden (current 
prices), 2021-2027 

Instrument 

Country funding allocation  

EU environmental funding 2021-2027 

(million EUR) 

The 2020 European Green Deal investment plan calls for 
EUR 1 trillion green investment (public and private) to be 
made across the EU by 2030. The 2021-2027 multiannual 
financial  framework  (MFF)  and  the  NextGenerationEU 
programme  will  together  mobilise  EUR  2.018  trillion  (in 
current  prices)  to  support  the  recovery  from  COVID-19 
including 
and 
environmental protection152.  

long-term 

priorities, 

EU's 

the 

Following the EU Green Deal’s153 pledge to ‘do no harm’ 
and  the  Interinstitutional  Agreement  on  the  2021-2027 
MFF154,  30%  of  the  EU  budget  will  support  climate 
efforts,  while  biodiversity  will  receive  7.5%  of  the  EU 
budget as of 2024 and 10% as of 2026, specifically under 
the 2021-2027 cohesion policy and the 2023-2027 CAP .  

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 
EU  Taxonomy)155. 
It  also  strengthens  non-financial 
reporting  requirements  and  facilitates  the  issuance  of 

148EASME , accessed: 15-12-2021. 
149  Approved  and  signed  EFSI  financing  -  EIB,  2015-2020:  Source: 
https://www.eib.org/en/products/mandates-
partnerships/efsi/index.htm. 
150 EIB loans in EU countries in 2014-2020. Source: EIB Open Data Portal:  
151  EIB  2020  Activity  Report.  The  EIB  Group  jointly  works  with  the 
European  Commission  in  implementing  several  programs  that  finance 
environmental implementation: InvestEU, the successor of EFSI, Pillar II 
and III of the Just Transition Mechanism. The EIB Group stands as a key 
implementing  partner  for  InvestEU  with  responsibility  for  managing 
75% of the overall budgetary capacity of the mandate. 
152  European  Commission,  2021-2027 
NextGenerationEU. 
153 COM/2019/640 final. 
154 Interinstitutional Agreement, OJ L 433I. 
155 European Commission, EU taxonomy for sustainable activities 

long-term  EU  budget  & 

Cohesion policy 

Total: 1 925.5 161 

ERDF 

ESF+ 

ETC (ERDF) 

862.5 

706.9 

356.1 

Just Transition Fund 

155.7 162 

EAFRD/rural 
development  

under 
Plans 2023-2027 163 

CAP 

Strategic 

European 
Fisheries 
Aquaculture 
(EMFAF) 

Maritime, 
and 
Fund 

1 059.4 164 

115.9 165 

156 EU Green Bond Standard - 2021/0191 (COD). 
157 COM (2021) 390 Final - European Commission, Strategy for Financing 
the Transition to a Sustainable Economy. 
158 COM(2021) 82 final. 
159  The  strategy  would  support  improved  insurance  gap  coverage 
including through the natural catastrophe markets as reflected with the 
EIOPA  (the  Association  for  European  Insurance  and  Occupational 
Pension Authorities) dashboard on insurance protection gap for natural 
catastrophes. See: The pilot dashboard on insurance protection gap for 
natural catastrophes | Eiopa (europa.eu). 
160 EIB Climate Bank Roadmap 2021-2025, November 2020 
161  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
162  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
163 European Commission, CAP strategic plans. 
164 Regulation (EU) 2021/2115, Annex XI.  
165 Regulation (EU) 2021/1139, Annex V. 

 Environmental Implementation Review 2022 – Sweden 

 
                                                                 
 
                                                                 
Recovery  and  Resilience 
Facility (RRF)  

2021 – 2026 166  

3 288.5 167  

Figure 41: Climate expenditure in RRPs168 

Sweden  35 

In  Sweden,  the  programming  for  most  EU  funds 
(cohesion policy funds, EAFRD and EMFAF) is ongoing.   

financial  support  under 

Sweden’s Recovery and Resilience Plan (RRP) amounts to 
EUR 3.3  billion.  Sweden  has  requested  only  non-
the  RRF.  This 
repayable 
represents  some  0.7%  of  2019  GDP.  The  plan 
is 
structured  along  five  components  aimed  at  tackling 
Sweden’s structural challenges, which the COVID-19 crisis 
exacerbated. Measures included in the plan complement 
the  national  economic  measures  introduced  by  Sweden 
in response to the COVID-19 pandemic and its economic 
fall-out and are consistent with the 2021 National Reform 
Programme.  The  plan  consists  of  27  measures  (12 
investments and 15 reforms). 

The reforms and investments in the plan can be expected 
to significantly contribute to the green transition. Overall, 
44.43%  of  the  recovery  and  resilience  plan’s  total 
allocation  contributes  to  the  climate  objectives  (see 
Figure 41). Measures focus on decarbonising industry and 
transport in Sweden. In particular, component 1 contains 
dedicated  measures 
to  decrease  process-related 
emissions and decarbonise the industry through research 
and  development  projects,  and  to  support  local  and 
regional  projects  on  CO2  emission  reductions,  including 
electric  charging  stations.  Moreover,  component  1  is 
expected  to  help  protect  valuable  nature  and  thus 
biodiversity  in  Swedish  forests,  by  establishing  formally 
protected  areas  of  nature 
In  addition, 
component  5  includes  investment  support  for  energy 
efficiency  and  building  renovation,  to  reduce  primary 
energy consumption and carbon dioxide emissions in the 
housing sector. 

reserves. 

By  2026,  under  NextGenerationEU,  the  Commission  will 
issue up to EUR 250 billion of EU green bonds (one third 
of  all  bonds  issued  under  NextGenerationEU)  that  will 
comply  with  the  general  spirit  of  the  ‘do  no  significant 
harm’  principle.  However,  this  EUR 250  billion  in  green 
bonds  will  not  be  subject  to  the  currently  developed 
delegated  acts  related  to  the  EU  Taxonomy  and  will  not 
fully  align  with  the  proposed  EU  standard  for  green 
bonds standard.  

in  2021-2027, 

there  are  also 

In  addition  to  EU  funds  earmarked  specifically  for 
Sweden 
funding 
programmes  that  can  been  accessed  at  EU  level  and 
which are open to all  Member States. These include the 
LIFE  programme169  (EUR 5.4  billion),  Horizon  Europe  
(EUR 95.5  billion)170,  the  Connecting  Europe  Facility171, 
(EUR 33.7 billion)172 or the funds to be mobilised via the 
InvestEU173 174  programme.  These  other  sources  of 
funding  will  also  support  the  green  transition,  including 
research  and  innovation  activities  for  environmental 
protection  (Horizon  Europe)192,  clean  transport  and 
energy (the Connecting Europe Facility)193 and sustainable 
infrastructure (InvestEU)194. 

168 European Commission. The contributions to climate objectives have 
been calculated using Annex VI of the RRF Regulation (EU) 2021/241. 
169 European Commission, LIFE Programme. 
170  European  Commission,  Multiannual  financial  framework  2021-2027 
(in commitments) - Current prices. 
171  The  CEF  (Transport)  includes also  EUR  11.3  billion transferred from 
the  Cohesion  Fund.  30  %  of  the  transferred  amount  will  be  made 
available,  on a competitive  basis,  to  all  Member  States eligible  for  the 
Cohesion Fund. The remaining 70% will respect the national envelopes 
until  31  December  2023.  Any  unspent  amount,  by  that  date,  under 
national envelopes will support all Cohesion Fund’s Member States. 
172 Regulation (EU) 2021/1153. 
173  The  InvestEU  Fund is envisaged to mobilise  over  EUR  372  billion of 
investment through an EU budget guarantee of EUR 26.2 billion to back 
the  investment  of  financial  partners  such  as  the  European  Investment 
Bank (EIB) Group and others. 
174 European Commission, Horizon Europe. 

166  The  actual  reforms  and  investments  under  the  RRF  have  to  be 
implemented until 31 December 2026.   
167 Sweden’s RRP endorsed by  the European Commission on 29 March 
2022 

 Environmental Implementation Review 2022 – Sweden 

 
 
 
 
                                                                 
 
 
                                                                 
Sweden  36 

which  businesses  normally  pursue  environmental 
activities as ancillary to their main  activities.  At EU level, 
37%  comes  from  governments,  33%  from  specialist 
producers  and  30%  from  industry  (business),  see  Figure 
43. 

Figure 43: EU-27 Member States' environmental 
protection investment (Capex) by institutional sector 
(Total economy = 100%), 2018177 

National expenditure on environmental 
protection  

Total  national  expenditure  on  environmental  protection 
(including all relevant current and capital expenditure)175 
in the EU-27 was EUR 272.6 billion in 2020, representing 
2%  of  the  EU-27  GDP.  This  percentage  has  remained 
quite  stable  over  time.  Although  the  largest  absolute 
amounts  of  expenditure  are  concentrated  in  a  few 
countries,  most  countries  spend  1-2%  of  their  GDP  on 
environmental  protection,  with  Sweden  dedicating  2.1% 
of its GDP (see Figure 42).  

Of this spending, the EU-27's capital expenditure (Capex) 
on environmental protection (i.e. investment)  amounted 
to  EUR 56.3  billion  in  2018,  falling  to  EUR 54.5  billion  in 
2020,  representing  around  0.4%  of  GDP.  Most  Member 
States  invested  0.2-0.5%  of  their  GDP  in  environmental 
protection,  with  Sweden  dedicating  0.5%.  During  2014-
2020, 
totalled  around  EUR 376  billion  of 
environmental  investment  in  the  EU-27,  and  EUR  13.4 
billion for Sweden. 

this 

Figure 42: Environmental protection investment in the 
EU-27 (2018, EUR million and % of GDP)176 

A  partial  breakdown  of  investment  by  environmental 
topic is available, at the level of institutional sectors only 
(rather than at economy level), due to different reporting 
patterns178.  At  Sweden’s  general  government  level,  50% 
of  environmental  protection  investment  went  to  waste 
management, 39% to wastewater and 5% to air pollution 
in  2018.  For  the  country’s  specialist  producers,  69%  of 
received  by  waste 
the 
management  and  30%  by  wastewater.  As  regards 
industry  (businesses),  32%  of  environmental  investment 
went to protection  from air pollution, 28% to protecting 
biodiversity,  12%  to  wastewater  and  10%  to  waste 
management, to name the most significant items. 

investment  was 

relevant 

In  2020,  total  annual  European  green  bond  issuance179 
(also  including  some  non-EU  countries)  was  USD 156 

177  Eurostat,  Environmental  Protection  Expenditure  Accounts 
(env_epe).  
178 Data  reporting is different  for the 3 institutional sectors, leading to 
aggregation  difficulties.  Specialist  companies  provide  comprehensive 
data  across  all  environmental  areas  (CEPA  1-9),  while  this  is  less  the 
case  for  general  government  and  industry  that  often  report  (the  non-
obligatory)  data  in  merged  categories  only  (with  difficulty  to  split)  or 
not at all.  
179  Green  bonds  were  created  to  fund  projects  that  have  positive 
environmental  and/or  climate  benefits.  The  majority  of  green  bonds 
issued are green “use of proceeds” or asset-linked bonds. The very first 

institutional  sector,  around  53%  of  Sweden’s 
By 
(capital 
environmental 
expenditure)  came 
the  general  government, 
another 17% from specialist producers (of environmental 
protection services, e.g. waste and water companies) and 
30%  from  the  classic  industry  (or  business)  sector,  in 

protection 
from 

investment 

175    At  economy  level,  including  final  consumption,  intermediate 
consumption and  capital  expenditure  of  households,  corporations  and 
governments related to environmental protection goods and services. It 
excludes  EU  funds,  while  may  include  some  international  expenditure 
beyond  domestic.  Data  source:  Environmental  Protection  Expenditure 
Accounts (EPEA), Eurostat. EPEA accounts are based on the CEPA 2000 
classification, excluding climate, energy and circular economy. 
176 Eurostat, Environmental Protection Expenditure Account, 2021.  

 Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
 
                                                                 
 
Sweden  37 

of 0.08% (see Figure 45). In the same year, environmental 
taxes totalled 4.73% of total revenues from tax and social 
security  contributions 
the  EU  average  of 
(below 
5.57%)183.  

Figure 45: Environmental taxes in the EU27 (2020)184 

billion  (EUR 137  billion180),  up  from  USD  117  billion 
(EUR 105 billion) in 2019. Looking only at EU-27 Member 
States, green bond issuance in 2020 was EUR 124 billion. 
In  2014-2020,  83%  of  the  green  bonds 
issued  by 
European countries served objectives in energy, buildings 
or transport, while 8% supported water and waste, with a 
further 6% supporting sustainable land use – with links to 
ecosystem conservation & restoration. The data based on 
the climate bonds taxonomy, which  is broadly similar  to 
the  EU  Taxonomy181.  Of  this  2020  EU  green  bond 
issuance, Sweden had EUR 12.42 billion worth of issuance 
(see Figure 44 below). 

Figure 44: Annual EU green bond issuance in 2020 (EUR 
billion)182 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience,  and  promote  a  fairer  society  and  a  fair 
transition. Tax reforms can contribute to this by sending 
the right price signals and incentives to economic actors. 
The  Green  Deal  creates  the  context  for  broad-based  tax 
reforms, the removal of fossil fuel subsidies, and a shift in 
the tax burden from labour to pollution. It does this while 
simultaneously 
social 
considerations 185. The Green Deal promotes the ‘polluter 
pays  principle’  (PPP)186,  which  stipulates  that  polluters 
should bear the cost of measures to prevent, control and 
remedy  pollution.  This  principle  is  facilitated  by  the 
Commission’s  technical  support  instrument  (TSI)  project 
on greening taxes187.   

account 

taking 

of 

According  to  a  Commission  study  on  green  taxation  and 
other  economic  instruments  (2021),  Sweden  applies 
polluter pays economic instruments on water and waste, 
as  water  consumption  charges  and  pay-as-you-throw, 
respectively 188. 

183 European Commission, Ensuring that polluters pay - Sweden.  
184 Eurostat, Environmental taxes accounts (env_eta). 
185 COM (2019/640 final), p.17 
186  Article  191(2)  of  the  Treaty  on  the  Functioning  of  the  European 
Union:  “Union  policy  on  the  environment  (…)  shall  be  based  on  the 
precautionary  principle  and  on  the  principles  that  preventive  action 
should  be  taken,  that  environmental  damage  should  as  a  priority  be 
rectified at source and that the polluter should pay”. 
187  European  Commission,  Greening  taxes-  applying  polluter  pays 
principle in practice.  
188  European  Commission,  Green  taxation  and  other  economic 
instruments, 2021 

Green budget tools 

Green taxation and tax reform 

Sweden’s revenue from environmentally relevant taxes is 
below the average in the EU. Environmental taxes stood 
at  2.02%  of  GDP  in  2020  (EU-27  average:  2.24%).  The 
largest portion of environmental taxes were energy taxes 
(1.52%  of  GDP,  against  the  EU  average  of  1.74%). 
Transport taxes represented 0.44% of GDP (slightly above 
the  EU  average  of  0.42%),  and  taxes  on  pollution  and 
resources were at 0.06%, which is below the EU average 

green  bond  was  issued  in  2007  with  the  AAA-rated  issuance  from 
multilateral  institutions,  the  European  Investment  Bank  (EIB)  and  the 
World Bank. 
180 At Eurostat’s annual average EUR/USD exchange rates. 
181 
Bonds 
information 
https://www.climatebonds.net/standard/taxonomy  
182 Climate Bonds Initiative, 2022. 

Interactive  Data  Platform  at  www.climatebonds.net.  Further 
Taxonomy: 

Climate 

on 

 Environmental Implementation Review 2022 – Sweden 

 
 
 
                                                                                                        
 
 
 
                                                                 
Environmentally-harmful subsidies 

Figure 46: Trends in natural gas, petroleum products 
and coal subsidies in Sweden191 

Sweden  38 

Addressing  and 
removing  environmentally-harmful 
subsidies  (EHS)  is  a  further  step  towards  wider  fiscal 
reforms189. 

Fossil  fuel  subsidies  are  costly  for  public  budgets  and 
make  it  difficult  to  achieve  the  objectives  of  the  Green 
Deal.  In  many  cases  they  can  also  counteract  incentives 
for  green  investment.  Annual  fossil  fuel  subsidies  have 
been  around  EUR 55  billion  in  the  EU  since  2015.  They 
rose  by  4%  between  2015  and  2019,  although  some 
countries (such as Latvia, Lithuania, Sweden, Greece and 
Ireland) managed to decrease them in this period. In the 
EU,  subsidies  on  petroleum  products  in  sectors  such  as 
transport  and agriculture continued to increase in 2015-
2019. However, subsidies  for coal and lignite decreased, 
due  to  the  diminishing  role  of  solid  fuels  in  electricity 
generation. As a share of GDP, fossil fuel subsidies ranged 
from 1.2% in Hungary to less than 0.1% in Malta in 2019 
(with an EU average of 0.4%). In 2019, the total fossil fuel 
in  Sweden  amounted  to  EUR  2.5  billion, 
subsidies 
representing 0.52% of the GDP.  

In 2020, the EU-27’s total fossil  fuel subsidies decreased 
to EUR 52 billion (due to falling consumption trends amid 
the  COVID-19-related  restrictions).  Without  Member 
State  action,  these  subsidies  are  likely  to  rebound  as 
economic activity picks up from 2020190. 

Environmentally-harmful subsidies in Sweden are  shown 
in Figure 46.  

potential 

189  European  Commission,  Study  on  assessing  th  environmental  fiscal 
reform 
2016 
https://ec.europa.eu/environment/integration/green_semester/pdf/Eu
nomia%20EFR%20Final%20Report%20MAIN%20REPORT.pdf  
190  See  table  on  EU  FFS  data  in  2019  which  is  based  on  (for  info) 
COM(2021) 950 and Annex. 

the 

28, 

for 

EU 

% GDP 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

Natural gas 

0,000 

0,000 

0,000 

0,000 

0,000 

0,000 

Petroleum  

0,003 

0,003 

0,003 

0,002 

0,002 

0,002 

Coal 

0,000 

0,000 

0,000 

0,000 

0,000 

0,000 

0,000 

0,003 

0,000 

0,00
0 

0,00
3 

0,00
0 

Sweden allocated more than the EU average to fossil-fuel 
subsidies,  and  more  than  it  did  to  renewable  energy 
subsidies192. 

Current green budgeting practices  

Green  budgeting  encompasses  various  climate  and 
environmental tagging and tracking practices in budgets. 
Some  EU  Member  states  already  use  certain  green 
budgeting  practices193.  Green  budgeting  helps  identify 
and  track  green  expenditure  and  green  revenues,  to 
increase transparency on the envrionmental impliactions 
of  budgetary  policies.  This  is  aimed  at  improving  policy 
coherence  and  supporting  green  policies  (including 
climate end environmental objectives)194. 

The Commission has also drawn up climate-proofing and 
sustainability-proofing  guidance,  as  tools  to  assess 

191 OECD, Fossil Fuel Subsidies Tracker. 

192  European  Court  of  Auditors,  Energy  taxation,  carbon  pricing  and 
energy subsidies, 2022 
193 European Commission, Green Budgeting Practices in the EU: A First 
Review,  2021  and  OECD,  Public  Governance  Directorate,  Climate 
Change  and  Long-term  Fiscal  Sustainability,  Working  Paper,  February 
2021.  Climate  Change  and  Long-term  Fiscal  Sustainability.  Tagging  is 
explained  in  European  Commission,  Green  budgeting  practices  in  the 
EU: a first review , 2021 (p.7) 
194  European  Commission,  European  Commission  Green  Budgeting 
Reference  Framework.  European  Commission,  Green  Budgeting  in  the 
EU Key insights from the 2021 Commission survey. 

 Environmental Implementation Review 2022 – Sweden 

 
                                                                 
 
                                                                 
project  eligibility  and  compliance  with  environmental 
legislation  and  criteria195.  The  Commission  developed  a 
green budgeting reference framework196 and launched a 
TSI  project  on  green  budgeting  to  help  Member  States 
develop their own national green budgeting frameworks 
to  improve  policy  coherence  and  support  the  green 
transition.  Sweden  participates 
in  the  Commission’s 
green-budgeting TSI, which started in 2021. 

Overall financing compared to the needs 

The  EU’s  overall  financing  for  environmental  investment 
is estimated to have been 0.6-0.7% of GDP in 2014-2020, 
comprising  both  major  EU  funds  and  national  financing. 
This  ranged  from  0.3%  (Ireland)  to  1.91%  (Bulgaria), 
depending  on  the  level  of  environmental  challenges  in 
different countries. In 2021-2027 it is estimated that the 
EU’s  overall  environmental  investment  needs  will  range 
between  0.9-1.5%  of  the  projected  GDP  for  the  EU-27 
(2021-2027),  suggesting  an  additional  financing  need 
(gap)  of  0.6-0.8%  of  total  EU  GDP,  unchanged  financing 
levels assumed197. 

Sweden  39 

Figure 47: Total environmental financing baseline (2014-
2020) and estimated needs (2020-2030) in the EU-27 (% 
of GDP)198 

Sweden’s  financing  for  environmental  investment  came 
to  an  estimated  0.53%  of  GDP  (EU  average:  0.7%)  in 
2014-2020, almost exclusively from national sources (see 
Figure  47).  Environmental  investment  needs  in  2021-
2027 are estimated to reach over 0.61% of GDP (covering 
needs for which  a  country-level breakdown is available), 
suggesting  an  additional  environmental  financing  need 
(gap)  of  at  least  0.08%  of  GDP.  And  this  is  likely  to  be 
higher  when  needs  that  are  currently  estimated  at  EU-
level  only  (e.g.  water  protection,  higher  circularity, 
biodiversity strategy etc.) are accounted for.    

2022 priority actions 

 

Ensure  a  sufficient  level  of  financing  in  the 
coming years through the EU funds, the RRP and 
national  financing,  to  cover  the 
investment 
needs for environmental priorities.  

195 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 
196  European  Commission,  Green  Budgeting  Reference  Framework, 
based  on  the  review  of  the  OECD  Paris  Collaborative  on  Green 
Budgeting initiative, 2017. 
197 Source: DG Environment data analysis. EU financing sources covered: 
ESI  Funds  (ERDF,  CF,  ESF,  YEI,  EAFRD,  EMFF),  Horizon  2020,  LIFE,  EFSI 
(EU amount), EIB loans. National financing: total national environmental 
protection  capital  expenditure  (investments)  -  source:  Eurostat  EPEA 
dataset.  Cut-off  date  for  data:  end  2021.  N.B.  The  total  financing  may 
be  higher,  in particular  through further  indirect  investments,  requiring 
further analysis in the future.   

198 Eurostat; ESI Funds Open Data, 2021. 

 Environmental Implementation Review 2022 – Sweden 

 
                                                                 
 
 
                                                                 
Sweden  40 

6. Environmental governance  

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention: 
(i) access to information;  
(ii) public participation in decision making; 
(iii) and access to justice in environmental eatters. 
It  is  of  crucial  importance  to  public  authorities,  the 
public, and businesses that environmental information is 
shared  efficiently  and  effectively199.  Public  participation 
allows  authorities  to  make  decisions  that  take  public 
concerns  into  account.  Access  to  justice  is  a  set  of 
guarantees that allows citizens and NGOs to use national 
courts to protect the environment200. It includes the right 
to bring legal challenges (‘legal standing’)201. 

Environmental information 

spatial  data 

infrastructure 

This  section  focuses  on  the  implementation  of  the 
INSPIRE  Directive.  The  Directive  aims  at  establishing  a 
sharing  
European 
environmental  spatial 
information  between  public 
authorities  across  Europe,  assisting    in  policy-making 
across  boundaries  and  facilitating  public  access  to  this 
information.  Geographic  information  is  needed  for  good 
governance  at  all  levels  and  should  be  readily  and 
transparently available.  

for 

implementation, especially those identified as high-value 
spatial  datasets 
implementing  environmental 
legislation203. 

for 

Table  4:  Country  dashboard  on  the  implementation  of 
the INSPIRE Directive (2016-2020) 204  

2016 

2020 

Legend 

Effective coordination and data sharing 

Ensure 
coordination  

effective 

■  ■ 

Data sharing without 
obstacle  

■  ■ 

INSPIRE performance indicators 

Conformity 

i. 
metadata  

of 

■  ■ 

ii.  Conformity  of 
spatial data sets 205 

■  ■ 

iii.  Accessibility  of 
spatial  data 
sets 
through  view  and 
download services 

iv.  Conformity  of 
network services 

■  ■ 

■  ■ 

■  Implementation  of  this 
is  well 
requirement 
advanced 
(nearly) 
or 
completed.  Outstanding 
issues  are  minor  and  can 
be 
easily. 
Percentage: >89% 

addressed 

■  Implementation  of  this 
requirement  has  started 
and  made 
some  or 
substantial  progress  but 
is  still  not  close  to  be 
complete. 
Percentage: 
31–89%  

is 

■  Implementation  of  this 
falling 
requirement 
behind. 
significantly 
efforts 
are 
Serious 
close 
necessary 
to 
implementation 
gap. 
Percentage: <31% 

Sweden’s  implementation  of  the  INSPIRE  Directive  is 
good.  Its  performance  has  been  reviewed  based  on  the 
Sweden’s  2021  country  fiche202.  Data  identification  and 
documentation  have  made  good  progress,  and 
implementation levels are good. However, more effort is 
in 
needed 

to  prioritise  environmental  datasets 

199  The  Aarhus  Convention,  the  Access  to  Environmental  Information 
Directive  (Directive  2003/4/EC)  and  the  INSPIRE  Directive,  (Directive 
2007/2/EC)  together  create  a  legal  foundation  for  the  sharing  of 
environmental  information  between  public  authorities  and  with  the 
public.  This  EIR  report  focuses  on  the  implementation  of  the  INSPIRE 
Directive. 
200 These guarantees are explained in the Commission Notice on access 
to  justice  in environmental  matters,  OJ L 275,  18.8.2017  and a related 
Citizen’s Guide. 
201  This  EIR  report  focuses  on  the  means  implemented  by  Member 
States to guarantee rights of access to justice and legal standing and to 
overcome  other  major  barriers  to  bringing  cases  on  nature  and  air 
pollution. 
202 INSPIRE knowledge base Sweden, 2021.  

Public participation 

Publication  of  the  initiation  of  environmental  impact 
assesment (EIA) and strategic environmental assessment 
(SEA)  procedures,  and  the  possibility  for  the  public  to 
submit  views  regarding  plans  or  projects  which  require 
an  EIA  or  SEA  are  a  mandatory  part  of  the  procedures. 
However, centralised statistical information regarding the 
level of public participation in decision-making processes 
regarding EIA and SEA procedures has not been found on 

In  2016,  the  deadlines  for 

203 European Commission, List of high-value spatial data sets 
204 INSPIRE knowledge base 
205 
implementating  the  spatial  data 
interoperability were still in the future: 23.11.2017 for Annex I data and 
21.10.2020 for Annex II and III data. It must be also considered that this 
conformity  indicator  will  in  many  cases  never  reach  100%  conformity, 
as  most  of  the  countries  provide  as-is-data  sets  in  addition  to  the 
INSPIRE aligned data-sets. 

Environmental Implementation Review 2022 – Sweden 

 
 
                                                                 
  
  
  
                                                                 
the relevant websites. The websites of individual  County 
Administrative Boards and permitting authorities provide 
information  for  those  seeking  a  permit  as  well  as 
information  on  public  participation  in  environmental 
impact assessments.  

Access to justice  

NGOs  do  not  need  to  demonstrate  an  interest  in  the 
specific case to have standing in an environmental court 
case  or  in  cases  which  have  significant  effects  on  the 
environment,  but  the  NGOs  have  to  meet  some 
conditions  in  connection  with  their  legal  status  and 
operation.  

In  Sweden,  the  SEA  is  an  intrinsic  part  of  the  planning 
procedure, and this assessment is not made separately to 
the  decision  regarding  the  plan  or  programme.  The  SEA 
can  be approved only if the direct and indirect impacts of 
the  plan  or  programme  are  deemed  to  be  adequately 
described  in  accordance  with  the  Code.  If  they  are 
approved,  this  will  be  noted  in  the  decision  concerning 
the plan or programme.  

Because of this system, the SEA, or any part of it, such as 
the  screening,  scoping  or  final  authorisation  of  the  EIA 
itself,  cannot  be  appealed  separately.  However,  the  EIA 
its  procedural  requirements  and  the 
including  both 
information 
in  a  specific  case  can  be 
challenged when appealing the plan as such. 

it  contains 

Plans and programmes in general are not binding for the 
public  under  Swedish  law,  they  are  only  indicative  or 
binding 
therefore 
for  authorities.  They  are  not 
considered  to  be  decisions  that  can  be    appealed  by 
individuals  or  NGOs.  There  is  no  legal  remedy  against 
these 
is  municipal 
instruments.  An  exception 
comprehensive  and  regional  planning  according  to  the 
Planning  and  Building  Act,  which  may  be  challenged 
through legal review.  

legal 

There  is  a  system  of  regular  supervision  of  regulatory 
legally  binding  acts  via  the  Chancellor  of  Justice  or  the 
Parliamentary Ombudsmen, but it is hardly accessible for 
the  members  of  the  public  and  NGOs;    they  can  only 
bring  them  to  the  attention  of  those  bodies  or  officials 
who  are  entitled  to  initiate  an  extraordinary  supervision 
procedure. 

There  is  no  organised  communication  about    where  to 
find  the  rules  on  access  to  justice  that  are  available  in 
information  may  be 
Sweden.  However,  rudimentary 
found  on 
the  main 
the  websites  of  some  of 
environmental  protection  authorities,  such  as  the 

Sweden  41 

Swedish Environmental Protection Agency (SEPA)206, and 
the National Board of Housing, Building and Planning 207. 
Some general information on access to justice can also be 
found on the website of the Swedish Courts208. 

In 2019, a priority action was addressed to Sweden about 
access  to  justice,  namely  to  better  inform  the  public 
about  their rights  in this  field. It is  concluded that there 
has been only limited progress made. 

2022 priority actions 

  Prioritise  environmental  datasets  in  implementating 
the  INSPIRE  Directive,  especially  those  identified  as 
high-value 
implementing 
environmental legislation.  

spatial  datasets 

for 

 

to 

  Better  inform  the  public  about  their  rights  to  access 
to  justice,  in  particular  by  including  links  on  national 
judical  and  administrative  websites 
the 
Commission  eJustice  fact-sheets  on  access  to  justice 
in environmental matters209. 
Improve  access  to  courts  for  the  public  concerned 
when 
it  comes  to  challenging  administrative  or 
regulatory  decisions,  in  particular  in  the  areas  of 
planning related to water, nature and air quality. 
  Measure, and track, the level of public participation in 
EIA procedures, to identify whether the full benefit of 
public  views  is  being  effectively  integrated  into  the 
decision-making  process,  and  whether  steps  at 
national or local level are needed to encourage higher 
levels of participation. 

Compliance assurance  

to  ensure 

Environmental compliance assurance covers all the work 
that 
undertaken  by  public  authorities 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect  water,  air  and  nature,  and  manage  waste210.  It 
includes  support  measures  provided  by  the  authorities 
such as: 
(i) compliance promotion211; 
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring212; 

206 Naturvårdsverket, Towards a better environment 
207 Boverket  
208  Sveriges Domstolar  
209 Access to justice in environmental matters   
210 
 The concept is explained in detail in the Communication on ‘EU actions 
to  improve  environmental  compliance  and governance’  COM(2018) 10 
and the related Commission staff working document, SWD(2018)10. 
211 
 This  EIR  report  focuses  on  the  help  given  to  farmers  to  comply  with 
nature and nitrates legislation. 
212 

Environmental Implementation Review 2022 – Sweden 

 
 
 
 
                                                                 
 
Sweden  42 

(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remediated,  i.e. 
enforcement213. 
Citizen  science  and  complaints  enable  authorities  to 
liability214 
better  focus  their  efforts.  Environmental 
ensures that the polluter pays to remedy any damage.  

Compliance promotion and monitoring 

Full  and  detailed  information  on  the  designation  and 
management  of  Natura  2000  sites  is  provided  on  the 
website  of  the  SEPA;  and  links  to  this  information  are 
provided by the Swedish Board of Agriculture. However, 
the information provided, except  for information on the 
greening  elements  of  Common  Agricultural  Policy  (CAP) 
direct  payments,  is  not  framed  in  terms  of  practical 
advice  for  farmers  and  land  managers.  Instead  this  is 
executed  through  the  CAP  support  system  and  reported 
by the Board of Agriculture.  In 2020, the Swedish Board 
of Agriculture updated their regulation for protecting the 
cultural and natural values of farmland215. 

For  the  Nitrates  Directive,  significantly  more  practical 
is  provided  by  the  Swedish  Board  of 
information 
Agriculture  (the  competent  authority  for  implementing 
the  directive).  Its  website  provides  a  wide  range  of 
information,  guidance  and  tools  related  to  manure, 
fertilizer  use,  and  farm  management  practices  that 
support  the  implementation  of  rules  under  the  Nitrates 
Directive216. The online information includes direct advice 
and  tools 
farmers,  as  well  as  downloadable 
publications on relevant topics such as reducing nutrient 
loss and self-monitoring for compliance. The publications 
also  include  more  technical/topical  support  such  as 
fertiliser-need calculations and manure management. 

for 

Detailed  information  on  the  planning  of  inspections  of 
installations covered by the Industrial Emissions Directive 
is not published. Inspection reports are recorded with the 
supervisory authority, and – although not published– are 
public  documents  which  can  be  requested  by  any 
interested party. In addition, permit holders are required 
to report annually on  their compliance with their permit 
conditions, and these reports are also public documents 
which  may  be  requested.  SEPA  is  required  by  law  to 
report  to  the  government  on  its  supervision  under  the 

Environmental  Code  (chapter  3  of  the  Ordinance  on 
Environmental  Supervision).  This  report  is  available  on 
SEPA’s  website  and  the  results  are  also  published  as 
’open data’ 217.  

Complaint handling and citizen science 

A  range  of  online  tools  is  available;  the  Police  Authority 
website  has  a  page  on  environmental  crime,  and 
encourages  citizens  to  report  suspected  environmental 
crimes by calling the national emergency number218. The 
website  of  the  Prosecution  Authority  has  a  page  on 
environmental crime providing details of how citizens can 
report  suspected  environmental  crimes  directly  to  the 
Police  or  the  Prosecution  Authority219,  with  relevant 
contact information. The public can also report suspected 
breaches  of  the  chemicals  legislation  on  the  website  of 
the Swedish Chemicals Agency220, via a simple form with 
drop-down menus. The person reporting the breach can 
choose  to  be  anonymous  and  can  also  ask  to  get 
feedback  on  the  report.  In  addition,  the  general  public 
can  make  complaints  to  the  Parliamentary  Ombudsmen  
if  they  suspect  a  public  authority 
in 
accordance  with  the  law,  or,  for  example  to  make 
complaints  about  management 
in  environmental 
cases221. 

is  not  acting 

While no summary of available information  seems to be 
published,  there  are  government  initiatives  and  policy 
documents  encouraging  the  use  of  citizen  science. 
Specifically  in  terms  of  using  citizen  information  to 
improve  compliance,  recent  campaigns  include  “Open 
eye”  (Öppet  öga)222,  which  was  launched  by  SEPA  and 
county  administrative  boards 
in  2016,  encouraging 
citizens  to  report  suspected  environmental  crimes.  The 
campaign  is  ongoing  and  an  updated  folder  about  it  is 
available  on  the  website  of  the  county  administrative 
boards223. 

Enforcement  

The  Swedish  National  Council  for  Crime  Prevention 
(Brottsförebyggande rådet or Brå) is a knowledge centre 
for  the  criminal  justice  system.  Brå  is  responsible  for 
official crime statistics, and provides detailed statistics on 
environmental  crime.  Brå  defines  ‘environmental  crime’ 
as ‘polluting land, air or water or otherwise affecting the 

 This EIR report focuses on inspections of major industrial installations. 
213 
 This  EIR  report  focuses  on  the  availability  of  enforcement  data  and 
coordination between authorities to tackle environmental crime. 
214  The  Environmental  Liability  Directive,  2004/35,  creates  the 
framework. 
215 SJVFS 2020:2 
216 Jordbruksverket:  

217 Öppna data available from Naturvårdverket 
218 Police Authority 
219 Swedish Prosecution Authority. 
220 Report a chemical safety issue - Kemikalieinspektionen 
221 Parliamentary Ombudsmen  
222 Svenska Dagbladet, Öppet öga" kamp mot naturbrott  
223 lansstyrelsen.se) 

Environmental Implementation Review 2022 – Sweden 

 
 
 
                                                                                                        
 
                                                                 
environment  so  that  it  can  harm  animals  and  plants  or 
human  health.’  According  to  Brå,  the  most  commonly 
reported and prosecuted violations of the Environmental 
Code  are  environmental  crimes 
(e.g.  pollution  or 
inconvenience),  unauthorised  environmental  activities 
(certain activities carried out without a permit or without 
following the conditions in the permit) and fly-tipping224. 
The  website  contains 
is 
considered  an  environmental  crime,  and  the  number  of 
crimes reported, prosecuted and solved by year.   

information  about  what 

Enforcement  of  the  environmental  law  is  to  a  large 
extent decentralised in Sweden and is carried out by  the 
County  Administrative  Boards  (CAB)  and  municipalities. 
Environmental  Cooperation  Sweden  (Miljösamverkan 
Sverige) is a national agency for cooperation between the 
CABs,  SEPA,  the  Swedish  Board  of  Agriculture  and  the 
Swedish  Agency  for  Marine  and  Water  Management 225. 
The  overall  aim  of  the  agency  is  to  ensure  authority  is 
exercised  in  a  more  uniform  manner  when  enforcing 
compliance  with  the  environmental  legislation.  To  that 
end,  the  agency  produces  operational  checklists  and 
other  documents  designed  to  support  inspectors  when 
checking compliance with environmental law.  

Waste  legislation  is  recognised  as  a  particular  area 
requiring inter-agency cooperation. In February 2021 the 
Swedish Government mandated a range of bodies (SEPA, 
the  CABs,  the  Swedish  Police  Authority,  the  Swedish 
Prosecution Authority, the Swedish Coast Guard and the 
Swedish  Customs)  to  present  a  report  on  the  situation 
regarding  illegal  waste  management  and  proposals  for 
measures to further prevent and deter crime in the waste 
area.  The  reports    are  due  to  be  completed  in  March 
2022. 

Environmental Liability Directive  

There does not appear to be a central database recording 
cases under the Environmental Liability Directive (ELD)or 
other  instances  of  environmental  damage.  There  is  a 
national  database  managed  by 
the  CABs  where 
contaminated, remedied or areas/sites that are assumed 
to  be  contaminated  are  registered226.  The  registered 
areas  have  been  identified  and  inventoried  by  the  CABs 
using  guidelines  from  the  SEPA227.  However,  they  have 
not  been 
in  order  to  ensure 
linked  to  the  ELD 
implementation of the polluter pays principle.  

Sweden  43 

2022 priority actions 

  Develop  a  national  database  of  environmental 
damage  cases,  highlighting  cases  under  the 
Environmental  Liability  Directive  and  providing 
full information on relevant financial sanctions. 

Effectiveness of environmental 
administrations  

in 

involved 

implementing 

environmental 
Those 
legislation at EU, national, regional, and local levels need 
to have the knowledge, tools and capacity to ensure that 
the  legislation  and  the  governance  of  the  enforcement 
process bring about the intended benefits. 

Administrative capacity and quality 

Sweden  ranks  8th  out  of  180  in  the  2020  Environmental 
Index 228.  At  present,  the  number  of 
Performance 
complaints and infringements in the environmental field 
can be considered below the EU average. Overall, during 
the last  decade an improvement  can be observed  in the 
implementation of EU environmental law in the different 
sectors. For  instance, there has been progress regarding 
the implementation of the environmental assessments. A 
recent  package  of  legislation  aimed  at  speeding-up  the 
licencing  of  the    ‘projects  of  national  interest’  raised 
some  doubts  but  no  serious  problems  have  been 
identified when it was implemented. 

Sweden  performs  well  on  digital  public  services.  The 
country  is  a  frontrunner  in  the  delivery  of  digital  public 
services among EU countries. It ranked third in the EU27 
in  the  2021  edition  of  the  Digital  Economy  and  Society 
Index (DESI), scoring 66.1 compared to the EU-average of 
50.7229. 

SEPA  offers  a  wide  range  of  e-services  in  relation  to 
extended  producer  responsibility  (EPR),  NOx  emissions 
declarations,  trans-frontier  shipments  of  waste  (Nordic 
TFS) or the Waste Registry. 

Coordination and integration  

As  mentioned  in  the  201  and  2019  EIR  Report,  the 
transposition  of  the  revised  EIA  Directive230  provides  an 

224 Swedish National Council for Crime Prevention (Brottsförebyggande 
rådet), Environemntal crime (Miljöbrott) 
225 Startsida - Miljösamverkan Sverige  
226  County  Administrative  Board  of  Stockholm:  Kartor  över  förorenade 
områden  
227 SEPAs guideline, Metodik för inventering av förorenade områden (). 

228 Environmental Performance Index. 
229  European  Commission,  Digital  Economy  and  Society  Index  (DESI) 
2021 - Sweden   
230 Directive 2014/52/EU of the European Parliament and of the Council 
of 16 April 2014 amending Directive 2011/92/EU on the assessment of 
the effects of certain public and private projects on the environment. 

Environmental Implementation Review 2022 – Sweden 

 
 
 
                                                                 
                                                                 
Sweden  44 

opportunity  to  streamline  the  regulatory  framework  on 
environmental  assessments.  Despite  a  delay 
in  full 
transposition  by    the  deadline  (May  2017),  Sweden  has 
now transposed the revised Directive. The quality of the 
transposition  is  currently  under  assessment  through 
conformity checks by the Commission.  

and circularity in policy and procurement planning (2019) 
and ammonia-reducing technology and measures (2021). 

The  Commission  encourages  the  streamlining  of  the 
environmental  assessments,  to  reduce  duplication  and 
avoid  overlaps  in  environmental  assessments  applicable 
to  projects.  Moreover,  streamlining  helps  to  reduce 
unnecessary  administrative  burden  and  accelerates 
is 
decision-making, 
done  without 
the  environmental 
compromising 
had 
assessment 
already 
environmental 
streamlining 
introduced 
assessments under EIA and Habitats Directives before the 
revision  of  the  EIA  Directive.  Coordinated  procedures 
have been established for the EIA, Water Framework and 
Industrial Emissions Directives. 

provided 
it 
the  quality  of 

procedure231. 
the 

Sweden 
of 

Reforms through the Commission’s Technical 
Support Instrument (TSI) 

The Commission supports environmental implementation 
and  the  green  transition,  not  only  through  the  EU 
financing  programs,  but  also  by  granting  technical 
the  Technical  Support 
assistance,  such  as  under 
Instrument (TSI). 

Sweden  was  not  actively  seeking  the  support  of  the  TSI 
for environmental reforms until 2022 when it submitted 
implementation 
a  request  for  technical  support 
capacity  of  sustainable  green  development  in  European 
Artic  Northern 
The 
Commission  encourages  Sweden  to  use  this  tool  more 
often in the coming years. 

Sparsely  Populated  Areas. 

in 

TAIEX EIR peer to peer Projects 

The TAIEX EIR Peer-to-Peer tool232 was  launched in 2017 
by the Commission to facilitate mutual learning between 
environmental authorities. 

During  the  reporting  period,  Sweden  participated  in    a 
workshop on circular and non-toxic reuse of phosphorus 
from sewage sludge (2019). Sweden has also participated 
in  two  multi-country  workshops  on  life  cycle  approach 

231 The Commission issued a guidance document in 2016 on how to sett 
up coordinated and/or joint procedures that are simultaneously subject 
to  assessments  under  the  EIA  Directive,  Habitats  Directive,  Water 
Framework  Directive  and  the  Industrial  Emissions  Directive,  OJ  C  273, 
27.7.2016, p. 1.  
232  TAIEX  -  Environmental  Implementation  Review  -  PEER  2  PEER  - 
Environment - European Commission (europa.eu). 

Environmental Implementation Review 2022 – Sweden