COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2025 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 2025 Environmental Implementation Review for prosperity and security
Date: 2025-07-07
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, 7.7.2025  SWD(2025) 326 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2025       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 2025 Environmental Implementation Review for prosperity and security        {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 302 final} - {SWD(2025) 303 final} - {SWD(2025) 304 final} - {SWD(2025) 305 final} - {SWD(2025) 306 final} - {SWD(2025) 307 final} - {SWD(2025) 308 final} - {SWD(2025) 309 final} - {SWD(2025) 310 final} - {SWD(2025) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 319 final} - {SWD(2025) 320 final} - {SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final}  
 
 
Sweden  2 

Contents 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 4 
Transitioning to a circular economy ..................................................................................................................... 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL ........................................................................................................................... 12 
Global and EU biodiversity frameworks ............................................................................................................. 12 
Nature protection and restoration – Natura 2000 ............................................................................................. 13 
Recovery of species ............................................................................................................................................ 14 
Recovery of ecosystems ..................................................................................................................................... 16 
Prevention and management of invasive alien species ...................................................................................... 21 
Ecosystem assessment and accounting ............................................................................................................. 22 
3. ZERO POLLUTION ..................................................................................................................................................... 23 
Clean air ............................................................................................................................................................. 23 
Industrial emissions ............................................................................................................................................ 24 
Major industrial accidents prevention – Seveso ................................................................................................. 26 
Mercury Regulation ............................................................................................................................................ 28 
Noise .................................................................................................................................................................. 28 
Water quality and management ........................................................................................................................ 28 
Chemicals ........................................................................................................................................................... 33 
4. CLIMATE ACTION ..................................................................................................................................................... 36 
The EU emissions trading system ....................................................................................................................... 37 
Effort sharing ..................................................................................................................................................... 37 
Land use, land-use change and forestry ............................................................................................................. 38 
Adaptation to climate change ............................................................................................................................ 38 

PART II: ENABLING FRAMEWORK – IMPLEMENTATION TOOLS ............................................................................ 40 

5. FINANCING ............................................................................................................................................................. 40 
Climate finance landmarks ................................................................................................................................. 40 
Environmental financing and investments ......................................................................................................... 41 
Public financial management ............................................................................................................................. 45 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 48 
Information, public participation and access to justice...................................................................................... 48 
Compliance assurance ........................................................................................................................................ 50 
EU-supported environmental capacity building ................................................................................................. 53 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
Sweden  3 

Executive summary 

In  May  2016,  the  European  Commission  launched  the 
Environmental  Implementation  Review  (EIR),  a  regular 
reporting 
tool  based  on  analysis,  dialogue  and 
collaboration  with  EU  Member  States  to  improve  the 
implementation  of  existing  EU  environmental  policy  and 
legislation (1). Following previous cycles in 2017, 2019 and 
2022,  this  report  assesses  the  progress  made  while 
the  main  outstanding  challenges  and 
describing 
opportunities 
legal 
implementation in Sweden. The purpose of this report is 
to  provide 
implementation 
performance  and  highlight  the  most  effective  ways  to 
address  the  implementation  gaps  that  impact  human 
health  and  the  environment  and  hamper  the  economic 
development  and  competitiveness  of  the  country.  The 
report relies on detailed sectoral implementation reports 
collected  or  issued  by  the  Commission  under  specific 
environmental legislation. 

information  on 

environmental 

regarding 

the 

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  taking  into 
consideration 
factors  such  as  the  gravity  of  the 
environmental implementation issue in light of the impact 
on the quality of life of citizens, the distance to target, and 
financial implications. 

Regarding  biodiversity,  77%  of  habitats  and  51%  of 
species  in  Sweden  are  in  unfavourable  conservation 
status. 6% of Swedish forest habitats protected under the 
Habitats  Directive  are  in  favourable  conservation  status, 
while all the others are in unfavourable status. For forest 
habitats, the main pressure is forestry, especially intensive 
logging,  followed  by  energy  production  and  natural 
processes. 

Sweden needs to improve its performance regarding the 
circular economy. The circular use of materials (the share 
of materials used in the economy coming from recycling) 
and resource productivity (the amount of GDP extracted 
from a kilo of materials) in Sweden continue to be below 
EU  average.  Incineration  is  the  main  type  of  waste 
treatment  in  Sweden,  accounting  for  59 %  of  all  waste 

(1) 

from 

the  Commission 

the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Delivering  the 
benefits  of  EU  environmental  policies  through  a  regular 

to 

treated.  Sweden  has  relatively  low  reuse  and  recycling 
rates, mainly due to low capture rates of recyclables. 

Despite improvements on air quality, the latest data show 
non-compliance  with  Sweden's  nationwide  ammonia 
reduction commitment and with PM10 standards in some 
areas of Sweden. 

As regards climate policy, Sweden is a frontrunner when it 
comes to battery electric vehicles, rail transport, and low 
emissions from buildings. At the same time, Sweden will 
need  to  implement  new  measures  and/or  use  available 
flexibilities  to  achieve  its  2030  effort  sharing  target.  The 
projected gap is 6.2 percentage points to the 2030 target. 
The latest projections show a gap to the Land Use, Land-
Use  Change  and  Forestry  (LULUCF)  Regulation  target, 
meaning  that  current  levels  of  CO2  removals  have  been 
insufficient.  Sweden  is  also  behind  its  renewable  energy 
and energy efficiency targets. 

The overall environmental investment needed to enable 
Sweden  to  meet  its  main  environmental  objectives  is 
estimated  at  EUR 13.9 billion  per  year,  focused  on  the 
following  areas:  pollution  prevention  and  control,  the 
circular  economy  and  waste,  water  protection  and 
management,  and  biodiversity  and  ecosystems.  The 
current 
investment  gap  stands  at  an  estimated 
EUR 8.5 billion  per  year  in  Sweden,  representing  around 
1.52 % of national gross domestic product. 

On  the  positive  side,  organic  farming  practices  are 
widespread in Sweden, with almost 20 % of the country’s 
utilised  agricultural  land  area  used  for  organic  farming. 
This  is  the  third  best  result  in  the  EU,  and  this  figure  is 
much  higher  than  the  EU  average  of  10.5 %.  Sweden  is 
therefore significantly contributing to achieving the target 
to  have  25 %  of  the  EU’s  agricultural  land  engage  in 
organic farming by 2030. Sweden continues to implement 
the Infrastructure for Spatial Information in the European 
Community  (INSPIRE)  Directive,  thus  providing  relevant 
environmental spatial information for good governance. 

implementation  review,  COM(2016) 316 
environmental 
final  of  27 May  2016,  http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN. 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
Sweden  4 

Part I: Thematic areas 

1. Circular economy and waste management 

Transitioning to a circular economy 

Figure 1: CMUR (%), 2013–2023 

Advancing the transition to a circular economy in the EU 
will reduce the environmental and climate impact of our 
industrial  systems  by  reducing  input  materials,  keeping 
products and materials in the loop for longer and reducing 
waste generation, thus decoupling economic growth from 
resource 
circular  economy  has 
considerable  potential  to  increase  competitiveness  and 
job creation and will also promote innovation and provide 
access to new markets. With the 2020 circular  economy 
action  plan  (CEAP) (2)  measures  either 
in  place  or 
legislatively advanced, EU Member States will now have to 
focus on a swift and effective implementation. 

consumption.  A 

The 2020 CEAP launched the legislative process for a set 
of  initiatives  that  will  now  have  to  be  implemented  by 
national  governments  across  the  EU.  These  initiatives 
were all introduced following a holistic life-cycle approach, 
with  measures  addressing  the  different  stages  of  a 
product’s life cycle, from design through use to end of life. 

In the CEAP, the EU sets as its overarching objective the 
doubling of its circular material use rate (CMUR) by 2030. 

The CMUR is a  measure of one aspect of circularity: the 
share of the total amount of material used in the economy 
that is accounted for by recycled waste.  A higher CMUR 
value means that more secondary materials were used as 
a  substitute  for  raw  materials,  thus  reducing  the 
environmental impacts of extracting primary material. 

The circular material use rate (CMUR) in Sweden was 9.9 % 
in 2023, against the EU average of 11.8 % (Figure 1). The 
rate had increased quickly since 2019, reaching 12.1 % in 
2022, but decreased again in 2023. 

15

10

5

0

2013

2015

2017

2019

2021

2023

Sweden

EU-27

Source: Eurostat, ‘Circular material use rate’, env_ac_cur,  last updated 
13 November 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_cur. 

9 December 

2024, 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic product (GDP). 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 2.18 generated per kg of 
resource 
material 
productivity  is  only  slightly  below  the  EU  average  of 
EUR 2.23 per kg, after a steady increase since 2019. 

in  2023,  Sweden’s 

consumed 

Figure 2: Resource productivity (EU/kg), 2013–2023 

2,4

2,2

2,0

1,8

1,6

2013

2015

2017

2019

2021

2023

Sweden

EU-27

NB: The unit of measurement used is EUR/kg chain-linked volume (2015). 
Chain-linked  volumes  focus  on  changes  on  quantities  and  prices  of 
commodities  in  previous  years,  taking  account  of  inflation,  and  are 
indexed to the nearest appropriate year, in this case 2015. 
Source:  Eurostat,  ‘Resource  productivity’,  env_ac_rp,  last  updated 
7 August 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_rp. 

9 December 

2024, 

(2) 

from 

the  Commission 

the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  A  new  circular 
economy action plan for a cleaner and more competitive Europe, 

to 

COM(2020) 98 
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A98%3AFIN. 

11 March 

2020, 

final 

of 

https://eur-

2025 Environmental Implementation Review – Sweden 

 
 
 
 
 
Policies and measures 

In  parallel  with  European  initiatives  under  the  2020 
circular economy action plan (CEAP), Member States are 
encouraged to adopt and implement circular strategies at 
the  national,  regional  and  city  levels.  These  should  be 
tailored to each national and local reality, to harness the 
proximity  economy’s (3)  potential,  while  following  the 
principles of a holistic whole-value-chain approach. 

Since the launch of the online European Circular Economy 
Stakeholder  Platform  in  2017 (4),  national,  regional  and 
local  authorities  have  used  the  platform  to  share  their 
strategies,  roadmaps  and  good  practices,  for  example 
alternative business models and innovative technologies. 

In 2020, Sweden adopted its circular economy strategy (5), 
which acts as the country’s main policy framework for the 
transition  to  a  circular  economy.  The  key  actors  to 
advance  the  transition  to  a  circular  economy  were 
identified as part of the strategy. 

As a follow-up to the strategy, in 2021 Sweden adopted a 
CEAP(6). The action plan presents more than 100 different 
measures  along  the  entire  life  cycle  of  products  and 
identifies  a  set  of  priority  sectors,  including  plastics, 
textiles,  renewable  and  bio-based  materials,  food,  the 
construction and property  sector (including building and 
demolition  waste),  and  innovation-critical  materials  and 
minerals.  An  action  plan  for  plastics (7)  was  adopted  in 
2022,  and  some  non-legislative  measures  have  been 
introduced on food waste and textiles. 

The importance of a  transition to a  competitive, circular 
and  sustainable  economy  is  emphasised  in  the  national 
strategy for sustainable regional development throughout 
the  country  2021–2030 (8).  The  strategy  allows  for 
regional 
the  EU  Regional 
including  via 
Development  Fund  and  the  Just  Transition  Fund  for 
business development through, among other things, the 
transition to a circular economy. 

funding 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
authorities’ 
consumption,  with  public 
European 

(3) 

(4) 

website, 

Commission 

European Commission, ‘Proximity and social economy ecosystem’, 
European 
https://single-market-
economy.ec.europa.eu/sectors/proximity-and-social-
economy_en. 
Circular 
(https://circulareconomy.europa.eu/platform/en/strategies). 
(5)  Ministry of the Environment, Circular Economy – Strategy for the 
2020 

transition 
https://faolex.fao.org/docs/pdf/swe208661.pdf. 

Stakeholder 

Economy 

Elanders, 

Platform 

Sweden, 

in 

(6)  Ministry  of  Climate  and  Enterprise,  Cirkulär  ekonomi – 
Handlingsplan  för  omställning  av  Sverige,  Stockholm,  2021, 
https://www.regeringen.se/informationsmaterial/2021/01/cirkul
ar-ekonomi---handlingsplan-for-omstallning-av-sverige/. 

Sweden  5 

purchasing  power  representing  around  14 %  of  EU  GDP. 
Public  procurement  using  green  or  circular  criteria  (life-
cycle analysis, platform as a service, and second hand) can 
help drive the demand for sustainable products that meet 
reparability and recyclability standards. 

A  national  strategy  for  sustainable  public  procurement 
strategy  has  been  in  place  in  Sweden  since  2016,  which 
responsible  public  procurement  under 
introduced 
objective  six  of  the  strategy.  The  National  Agency  for 
Public  Procurement  offers  a  ‘criteria  library’  containing 
recommendations 
social 
requirements to be used when purchasing goods, services 
and  works.  There  are  three  levels  of  environmental 
criteria:  basic,  advanced  and spearhead.  The  criteria  are 
available within eight product groups. 

environmental 

and 

on 

There is no mechanism for monitoring the percentage of 
public  procurement  procedures 
incorporating  green 
criteria  out  of  the  whole  volume  of  procurement  at  the 
national  level.  However,  the  National  Agency  for  Public 
Procurement  has  carried  out  a  study  that  showed  that 
90 % of the 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. 

The EU Ecolabel and the eco-management and audit 
scheme 

The  number  of  EU  Ecolabel  product  groups  and  the 
number  of  eco-management  and  audit  scheme  (EMAS)-
licensed  organisations  in  each  country  provide  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. The EU Ecolabel is 
awarded  to  products  with  best-in-class  environmental 
is  a  voluntary  environment 
performance.  EMAS 
the 
scheme 
management 
environmental impacts of organisations. 

reducing 

aimed 

at 

As of September 2024, Sweden had 6 500 products out of 
98 977,  a  significant  share  of  them  being  in  the  tissue 
category, and 53 licences out of 2 983 registered in the EU 
Ecolabel  scheme,  demonstrating  a  good  take-up  of 
products  and  licences (9).  In  addition  to  the  EU  Ecolabel 

(7)  Ministry  of  Climate  and  Enterprise,  Sveriges  handlingsplan  för 
plast –  En  del  av  den  cirkulära  ekonomin,  Stockholm,  2022, 
https://www.regeringen.se/rapporter/2022/02/sveriges-
handlingsplan-for-plast/. 

(8)  Ministry of Climate and Enterprise,  Nationell strategi för  hållbar 
regional  utveckling  i  hela  landet  2021–2030,  Stockholm,  2020, 
https://www.regeringen.se/rattsliga-
dokument/skrivelse/2021/03/skr.-202021133. 
European Commission, ‘EU Ecolabel facts and figures’, European 
website, 
Commission 
https://environment.ec.europa.eu/topics/circular-economy/eu-
ecolabel/businesses/ecolabel-facts-and-figures_en. 

(9) 

2025 Environmental Implementation Review – Sweden 

 
 
registrations,  as  of  October  2024,  Sweden  had  35 000 
products  and  services  awarded  with  the  Nordic  Swan 
Ecolabel,  a  widespread  ecolabel  used  in  certain  Nordic 
countries. Moreover, eight organisations from Sweden are 
currently registered in EMAS, four fewer than in October 
2021 (10). 

Since the figures for the CMUR in the 2022 report refer to 
2020, and the latest available data as of September 2024 
is from 2022, it is not yet possible to assess progress in this 
regard. 

2025 priority action 

•  Adopt measures to increase the CMUR. 

Waste management 

Turning waste into a resource is supported by: 

(i)  addressing  the  full  life  cycle  of  products,  from 
conception to end of life, by setting requirements on 
the design of products to ensure that they are more 
sustainable; 

(ii)  fully 

implementing  EU  waste 

legislation,  which 
includes the waste hierarchy, the obligation to ensure 
separate collection of waste, landfill diversion targets, 
etc.; 

(iii)  reducing waste generation per capita and in absolute 

terms; 

(iv)  increasing  the  recycling  rates  of  waste  containing 
critical  raw  materials,  with  a  view  to  reducing 
dependencies and building resilient value chains, and 
stimulating  demand  for  recycled  content 
in  all 
products; 

(v)  limiting energy recovery to non-recyclable materials; 

and 

(vi)  phasing  out  landfilling  of  recyclable  or  recoverable 

waste. 

One  of  the  main  objectives  of  the  EU  Waste  Law  is  to 
decouple  economic  growth  from 
its  environmental 
impacts. 

The EU’s approach to waste management is based on the 
waste  treatment  hierarchy:  prevention,  preparing  for 
reuse,  recycling,  recovery  and,  as  the  least  preferred 
option,  disposal 
landfilling  and 
includes 
incineration without energy recovery). 

(which 

All legislative proposals in the field of waste management 
put forward by the Commission since 2021 are intended 

(10) 

(11) 

European  Commission,  ‘Eco-management  and  audit  scheme 
(EMAS)’,  European  Commission  website,  October  2024, 
http://ec.europa.eu/environment/emas/emas_registrations/stati
stics_graphs_en.htm. 
Swedish  Environmental  Protection  Agency  (SEPA),  Avfall  i  ett 
cirkulärt samhälle – Nationell avfallsplan 2024–2030, Stockholm, 

Sweden  6 

to encourage Member States to promote better product 
design,  to  require  producers  to  cover  the  costs  of 
managing the waste resulting from their products and to 
ensure that waste is managed at the higher levels of the 
waste hierarchy. 

The total amount of waste generated in Sweden increased 
from 2010 to 2014, then declined between 2016 and 2018, 
with  2022  levels  returning  to  those  observed  in  2014 
(Figure 3).  This  trend  is  primarily  driven  by  the  largest 
waste category: other mineral wastes (mainly from mining 
and  quarrying  activities).  When  excluding  major  mineral 
wastes,  the  trend  is  somewhat  different,  showing  an 
increase throughout the considered time period with the 
exception of a slight drop in 2020. This trend is driven by 
the major waste category mixed wastes, while recyclable 
wastes only increased in 2018. Sweden’s GDP showed an 
overall increase, apart from a slight decline in 2020, most 
likely  due  to  the  COVID-19  outbreak.  There  is  no  clear 
indication that waste generation has been decoupled from 
economic growth. 

Figure 3: Generation of waste (total and excluding major 
mineral wastes), population and GDP, 2010–2022 

accessed 

15 October 

nama_10_gdp, 

NB: Waste generation data for odd years are interpolated. 
Sources: Eurostat, ‘GDP and main components (output, expenditure and 
income)’, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__cust
om_9301905/default/table;  Eurostat,  ‘Generation  of  waste  by  waste 
category,  hazardousness  and  NACE  Rev. 2  activity’,  env_wasgen, 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/view/env_wasgen/default/
table?lang=en; and Eurostat, ‘Population change – Demographic balance 
and  crude  rates  at  national  level’,  demo_grind,  accessed  15 October 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/demo_gind/default/t
able?lang=en&category=demo.demo_ind. 

15 October 

Critical raw materials 

Critical raw material (CRM)-relevant aspects are covered 
by Sweden’s waste management plan 2024–2030 (11). The 
Swedish CEAP (12) also mentions CRMs. 

2024, 
https://www.naturvardsverket.se/4ad992/globalassets/media/p
ublikationer-pdf/7100/978-91-620-7171-4.pdf. 

(12)  Ministry of the Environment, Circular Economy – Strategy for the 
2020 

transition 
https://faolex.fao.org/docs/pdf/swe208661.pdf. 

Elanders, 

Sweden, 

in 

2025 Environmental Implementation Review – Sweden 

 
 
 
Construction and demolition waste 

Construction  and  demolition  waste  accounts  for  almost 
40 % of all waste generated in the EU. A recent study (13) 
by  the  Joint  Research  Centre  shows  that  preparing  for 
reuse  and  recycling  operations  are  preferred  over 
incineration  and 
landfilling  from  an  environmental 
perspective  for  most  of  the  different  streams  of 
construction  and  demolition  waste.  However,  the 
economics are often unfavourable for preparing for reuse 
and recycling compared with incineration and landfilling. 
If available technology were to be applied, it is estimated 
that  the  increase  in  preparing  for  reuse  and  recycling 
would  lead  to  33 Mt  of  greenhouse  gas  (GHG)  emission 
savings  annually  (more  than  the  combined  annual  GHG 
emissions from Estonia, Latvia and Luxembourg). 

Measures to further increase the preparing for reuse and 
recycling  rate  of  construction  and  demolition  waste 
include  separate  collection  at  the  source –  for  instance, 
through  digitalised  pre-demolition  audits (14)  (‘resource 
assessments’);  extended  producer  responsibility  and 
other  economic  instruments;  and  upstream  measures 
such  as  increasing  the  recycled  content  in  construction 
products and the circular design (15) of construction works. 

There are specific milestones and targets for construction 
and  demolition  waste  in  the  Swedish  environmental 
objectives  system (16).  Guidance  on  the  handling  of 
construction  by-products  and  the  use  of  by-products  in 
construction work could be important for slags and ashes, 
and construction and demolition waste (17). 

Boosting implementation – the 2023 Waste Early 
Warning Report 

Sweden  7 

risk of missing 2025 waste targets (see Figure 4). Sweden 
is  in  the  category  of  countries  at  risk  of  missing  the 
municipal waste target. 

Figure 4:  Member  States’  prospects  of  meeting  the 
preparing  for  reuse  and  recycling  targets  for  municipal 
waste and packaging waste 

Member  States not at risk of missing both  the 55 % 
preparing for reuse and recycling target for municipal 
waste  and  the  65 %  recycling  target  for  packaging 
waste 

Member  States  at  risk  of  missing  the  preparing  for 
reuse and recycling target for municipal waste but not 
at  risk  of  missing  the  recycling  target  for  packaging 
waste 

Member States at risk of missing both targets 

Outside coverage 

This  section  focuses  on  the  management  of  municipal 
waste (18),  for  which  EU  law  sets  mandatory  recycling 
targets.  In  June  2023,  the  Commission  published  the 
Waste  Early  Warning  Report (19)  identifying  the  general 
trends in waste management and the Member States at 

Source: European Environment Agency (EEA), ‘Many EU Member States 
not on track to meet recycling targets for municipal waste and packaging 
waste’, briefing No 28/2022, Copenhagen, 2023. Reference data © ESRI. 

Under  certain  conditions,  EU  waste  legislation  enables 
some  Member  States  to  postpone  the  deadlines  for 

(13) 

(14) 

(15) 

European Commission: Joint Research Centre, Cristobal Garcia, J., 
Caro, D. et al., Techno-economic and environmental assessment of 
construction and demolition waste management in the European 
Union,  Publications  Office  of  the  European  Union,  Luxembourg, 
2024, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC1354
70. 
European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  EU  Construction  and 
Demolition Waste Management Protocol including guidelines for 
pre-demolition and pre-renovation audits of construction works – 
Updated edition 2024, Publications Office of the European Union, 
Luxembourg,  2024,  https://op.europa.eu/en/publication-detail/-
/publication/d63d5a8f-64e8-11ef-a8ba-01aa75ed71a1/language-
en. 
European Commission, Circular Economy – Principles for buildings 
design, 
2020, 
Brussels, 
https://ec.europa.eu/docsroom/documents/39984. 

(16) 

(17) 

SEPA,  ‘The  environmental  objectives  system’,  SEPA  website, 
10 February 
2020, 
https://www.sverigesmiljomal.se/environmental-objectives/. 
av  massor 
SEPA, 
anläggningsarbete’, 
https://www.naturvardsverket.se/vagledning-och-
stod/avfall/atervinning-av-avfall-i-anlaggningsarbeten. 

SEPA  website, 

‘Masshantering 

i 
2024, 

6 December 

användning 

och 

(18)  Municipal  waste  consists  of  (i)  mixed  waste  and  separately 
collected waste from households, including paper and cardboard, 
glass, metals, plastics, biowaste, wood, textiles, packaging, waste 
electrical  and  electronic  equipment,  waste  batteries  and 
accumulators,  and  bulky  waste, 
including  mattresses  and 
furniture;  and  (ii)  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, 
Article 3.2b). 
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en. 

(19) 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
 
 
 
reaching certain waste management targets for municipal 
and packaging waste. Member States that want to use this 
possibility  have  to  notify  the  Commission  24 months  in 
advance  of  the  deadline  and  submit  an  implementation 
plan  laying  down  the  steps  they  envisage  to  reach  the 
postponed targets within a new time frame. Regarding the 
2025 targets, 11 Member States, including Sweden, have 
used this prerogative. 

In December 2023, Sweden notified the Commission of its 
decision to postpone the deadline for  meeting the  2025 
targets for plastic packaging until 2028. The Commission 
found  that  the  plan  submitted  did  not  comply  with  the 
requirements set out in the relevant waste legislation20. 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 
efforts  to  improve  their  recycling  performance.  The 
Commission  is,  on  one  hand,  working  together  with  the 
national  authorities  and  stakeholders  to  speed  up  the 
implementation  of  measures  necessary  to  meet  the 
targets,  including  through  dedicated  financing.  On  the 
other  hand,  the  Commission  is  pursuing  enforcement 
actions against those Member States that, based on data 
submitted to the Commission, do not achieve the targets 
of the Waste Framework Directive (21), the Packaging and 
Packaging  Waste  Directive22  and  the  Directive  on  Waste 
Electrical and Electronic Equipment (23). 

Municipal waste 

in  reporting  methodology 

Sweden’s municipal waste generation remained stable in 
2010–2019 (Figure 5). The reported amounts in 2020 and 
2021  were  lower,  but  this  is  likely  to  be  due  to  a 
comprehensive  change 
in 
response  of  the  implementation  of  the  new  reporting 
rules  introduced  in  the  Waste  Framework  Directive  in 
2018,  and  further  adjustments  are  expected,  especially 
with  respect  to  the  generation  of  municipal  waste  from 
sources  other  than  households.  In  2022,  the  country 
generated 395 kg of municipal waste per capita, which is 
significantly  below  the  estimated  European  average  of 
513 kg per capita. 

(20) Commission Decision (C(2024) 1954) 

(21) Directive 2008/98/EC of the European Parliament and of the Council 
of 19 November 2008 on waste and repealing certain Directives, 
Directive - 2008/98 - EN - Waste framework directive - EUR-Lex. 

Sweden  8 

Figure 5:  Municipal  waste  management  and  recycling 
(including preparation for reuse), 2010–2022 

Source:  Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
env_wasmun, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table. 

22 October 

accessed 

Figure 6: Recycling (including preparation for reuse) and 
landfill rates (%), 2010–2022 

NB: As of reference year 2020, new reporting rules apply for calculating 
in 
recycled  municipal  waste  pursuant  to  the  targets 
Article 11.2(c–e) of Directive 2008/98/EC. Sweden has applied the new 
calculation rules since reference year 2020, which led to a break in series 
in 2020. 

laid  down 

Source:  Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
env_wasmun, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table. 

22 October 

accessed 

Sweden has a recycling rate of 40 %, which  is below the 
estimated EU-27 average of 49 %. The recycling rate has 
been rather stable since 2010, with a large drop in 2020, 
which  is  mainly  caused  by  the  change  in  reporting 
regarding  the  new  calculation  rules,  especially  the  new 

(22) European Parliament and Council Directive 94/62/EC of 20 December 
1994 on packaging and packaging waste (OJ L 365, 31/12/1994, p. 
10–23), Directive - 94/62 - EN - EUR-Lex. 

(23)  Directive  2012/19/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  waste  electrical  and  electronic 
equipment  (WEEE)  (OJ  L 197,  24.7.2012,  p. 38),  Directive  - 
2012/19 - EN - EUR-Lex. 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
calculation  points  that  exclude  rejects  during  sorting,  in 
compliance with the 2025 recycling target (Figure 6) (24). 

Incineration 
is  the  predominant  method  of  waste 
treatment  in  Sweden,  accounting  for  59 %  of  all  waste 
treated,  while  landfilling  accounts  for  less  than  1 %.  The 
low preparing for reuse and recycling rates are mainly due 
to  low  capture  rates  of  recyclables (25).  In  addition,  the 
recycling  efficiency  of  separately  collected  recyclables  is 
influencing the recycling rate negatively when calculating 
according to the calculation points of actual recycling (26). 

Sweden has reported data  to show compliance with the 
preparing for reuse and recycling target of 55 % for 2025, 
as  laid  down  in  the  Waste  Framework  Directive.  The 
difference  between  these  data  and  the  data  shown  in 
Figure 6 (voluntary reporting) is below 1 percentage point 
for the preparing for reuse and recycling rate both in 2021 
and 2022. 

Packaging waste 

Sweden’s  packaging  waste  generation  significantly 
increased between 2010 and 2022 (Figure 7). In 2022, the 
country  generated  130 kg  per  capita,  which 
is  still 
significantly below the estimated EU-27 average of 186 kg 
per capita in the same year (27). One reason might be the 
lack  of  estimates  for  free  riders,  which  could  lead  to  an 
underestimation of the volume of packaging placed on the 
market (28). 

Sweden  9 

Figure 7: Packaging waste generation, 2010–2022 

Source: Eurostat, ‘Packaging waste by waste management operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en. 
Figure 8: Packaging waste recycling rates (%), 2010–2022 

NB: There are breaks in the data series for paper/cardboard and plastic 
in 2020 and 2021; for plastic again in 2022; for glass in 2021; for wooden 
packaging  in  2016,  2017,  2018,  2020;  and  for  metals  in  2021.  As  of 
reference year 2020, the rules for calculating recycled packaging waste 
have changed, pursuant to Article 6a of Directive 94/62/EC. However, it 
is  unclear  based  on  the  information  available  whether  these  new 
reporting rules have been fully implemented in Sweden. 

(24)  While  compliance  with  the  2020  recycling  target  of  the  Waste 
Frame Directive is not assessed here, it is noted that the drop in 
the recycling rate is even higher when compared with the reported 
recycling  rate  for  the  2020  target.  Sweden  previously  used 
method 2 set out in Commission decision 2011/753/EU in order to 
calculate  the  2020  target  and  was  only  including  some  waste 
streams, so the change in methodology led to a drop from 61 % to 
38 % in 2020. 
Commission staff  working  document –  The  early  warning  report 
for  Sweden,  SWD(2023) 200  final  of  8 June  2023,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=SWD%3A2023%3A200%3AFIN. 

(25) 

(26) 

(27) 

(28) 

‘Kommunalt  avfall’,  SEPA  website,  16 August  2024, 

SEPA, 
https://www.naturvardsverket.se/vagledning-och-
stod/avfall/kommunalt-avfall/. 
The  EU  average  might  have  been influenced by  not  all  Member 
States  already  fully  applying  the  reporting  rules  for  packaging 
waste  set  out 
in  Commission  Implementing  Decision  (EU) 
2019/665. 
Eurostat,  ‘Country-specific  notes  referring  to  data  on  packaging 
2022, 
and 
https://ec.europa.eu/eurostat/documents/342366/13429143/Co
untry+specific+notes+for+packaging+and+packaging+waste.pdf/
59ea2d73-3416-b40b-1771-2eb33e0b8486?t=1648204996107. 

packaging 

waste’, 

2025 Environmental Implementation Review – Sweden 

 
 
 
  
Source:  Eurostat,  ‘Packaging  waste  by  waste  management  operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en. 

In 2022, the overall recycling rate for packaging waste was 
67 %, very close to the estimated EU-27 average of 65 %. 
The  recycling  rate  is  mostly  driven  by  the  two  fractions 
with  the  highest  share  in  total  packaging –  paper  and 
cardboard, and plastics – and it has stagnated compared 
with  2010  (Figure 8).  The  recycling  rates  for  plastics  and 
glass  packaging  recycling  show  a  decreasing  trend.  All 
other packaging waste fractions show an increasing trend. 
However,  these  changes  are  affected  by  methodological 
changes in the reporting, as indicated by several flagged 
breaks  in  the  data  series  for  all  materials.  The  reported 
recycling  rates  for  2022  are  above  the  2025  targets  for 
total packaging waste and for all materials except plastics. 

Policies to encourage waste prevention 

Waste  management  plans  and  waste  prevention 
programmes are instrumental to the full implementation 
of  EU  waste  legislation.  They  set  out  key  provisions  and 
investments to ensure compliance with existing and new 
legal requirements (e.g. on waste prevention, on separate 
collection for certain waste streams, on recycling and on 
landfill targets). 

For 
the  years  2024-2030,  Sweden  has  a  waste 
management  plan  in  place  ‘Waste  in  a  circular  society  – 
National  Waste  Plan  2024–2030  (29)  and  a  waste 
prevention programme ‘A circular Sweden thinks - before! 
National  Waste  Prevention  Programme  for  a  Circular 
Economy 2024 – 2030 (30). 
From  January  2024,  municipalities  in  Sweden  have  an 
expanded  responsibility  for  waste  prevention  initiatives 
and  are  also  in  charge  of  providing  information  to 
households (31). 

In order to achieve UN sustainable development goal 12.3, 
‘halve  global  per  capital  food  waste’,  in  2018  Sweden 
launched its action plan to reduce food waste by 2030 (32). 
The action plan has identified four  criteria  for success: a 
national  goal  and  development  of  monitoring  methods; 
active  collaboration  between  actors  in  the  food  supply 

(29)   Avfall i ett cirkulärt samhälle  
(30)   Ett cirkulärt Sverige tänker efter – före! 
(31) 

SEPA, ‘Avfall i ett cirkulärt samhälle’, SEPA website, 19 November 
2024, 
https://www.naturvardsverket.se/amnesomraden/avfall/avfall-i-
ett-cirkulart-samhalle/. 
Swedish Food Agency, More People Doing More – Action plan to 
reduce 
2018, 
by 
https://www.livsmedelsverket.se/globalassets/publikationsdatab
as/rapporter/2018/fler-gor-mer-handlingsplan-for-minskat-
matsvinn-2030.pdf. 
Jordbruksverket,  Slutrapport  om  livsmedelsförluster,  Jönköping, 
2024, 
https://webbutiken.jordbruksverket.se/sv/artiklar/ra241.html. 

Uppsala, 

waste 

2030, 

food 

(32) 

(33) 

Sweden  10 

chain; a change in consumer behaviour; and investigation, 
research and innovation. 

To  establish  a  baseline  for  food  losses  occurring  in  the 
initial  stages  of  the  farm  to  fork  chain,  Sweden  has 
developed  a  national  method  and  the  Swedish  Board  of 
Agriculture  has  started  monitoring  food  losses.  It  is 
anticipated  that  this  monitoring  approach  will  enhance 
the understanding of food loss and the waste generated 
during food production (33). 

Policies to encourage separate collection and recycling 

In  Sweden,  separate  collection  is  mandatory  for  both 
households  and  non-households.  Sweden  has  started  to 
move from the dominant system of bring points to door-
to-door  collection.  Newly  implemented  provisions  for 
separate  collection,  covering  the  whole  country,  require 
that food waste from households and non-households are 
collected  separately  door-to-door  (applying  from  2024). 
Paper  and  cardboard,  metal,  glass 
(coloured  and 
uncoloured) and plastic packaging waste from households 
and non-households – if their waste collection is located 
at  the  same  site  as  households –  will  be  collected 
separately through a door-to-door system (applying from 
2027). Bulky packaging waste made of paper and plastic 
should be collected at accessible public collection points. 
Garden,  wood,  ceramics  and  textile  wastes  are  mainly 
collected at the municipalities’ recycling centres (34).  

In  Sweden,  extended  producer  responsibility  applies  to 
packaging  waste 
from  both  households  and  non-
households  for  all  packaging  materials.  Sweden  applies 
limited  fee  modulation  based  on  recyclability 
some 
criteria  for  paper  and  cardboard  and  plastics  packaging. 
Sweden  had  a  tax  on  plastic  carrier  bags (35),  but  it  was 
removed in November 2024 (36). 

In order to incentivise sorting at source, Sweden has fully 
rolled  out  pay-as-you-throw  systems,  mostly  based  on 
container  volume  and  collection 
frequency.  Some 
municipalities  have  introduced  weight-based  fees.  In 
addition, the fee for biowaste is smaller than for residual 
waste or it is free of charge (37). 

(34)  

(35) 

(36) 

(37) 

SEPA, information provided during the Eionet review of the draft 
EEA country profile on waste management for Sweden, 2024. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal  and  packaging  waste –  Sweden,  Copenhagen,  2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/sweden/view. 
SEPA, information provided during the Eionet review of the draft 
EEA country profile on waste management for Sweden, 2024. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal  and  packaging  waste –  Sweden,  Copenhagen,  2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/sweden/view. 

2025 Environmental Implementation Review – Sweden 

 
 
Since it is now mandatory to collect biowaste separately, 
the Swedish government assesses that the need for these 
types of incentives for food waste will decrease. In 2027, 
when new collection rules for packaging will apply, many 
municipalities will change collection systems, as they need 
to  collect  a  larger  share  of  waste  from  each  household. 
Depending on the chosen collection systems, the previous 
pay-as-you-throw systems will probably be replaced (38). 

Sweden  has mandatory  deposit return systems for most 
aluminium drink cans and most plastic drink bottles. For 
glass drink bottles, plastic crates and wooden packaging, 
there is no deposit return system (39). 

Policies and instruments to discourage landfilling or 
incineration 

Sweden has a landfill tax in place of  SEK 725/t (EUR 60/t 
equivalent) in 2024; this is adjusted yearly (40). The landfill 
tax  is  close  to  the  average  of  landfill  taxes  of  Member 
States applying such taxes. Sweden has a ban in place for 
landfilling  residual  or  biodegradable  waste,  with  an 
exemption  for  sorted  combustible  waste  containing  less 
than  18 %  total  organic  carbon  (TOC),  and  waste 
containing  less  than  10 %  TOC (41).  The  previous  tax  on 
incineration has been removed (42). 

Sweden  11 

Sweden is currently subject to an infringement case (43) for 
failing to meet waste collection and recycling targets laid 
down under the current EU waste legislation. 

In the 2022 Environmental Implementation Review (EIR), 
it was recommended that Sweden (i) introduce policies to 
promote  waste  prevention  and  (ii)  shift  reusable  and 
recyclable waste away from incineration. Some progress 
has  been  achieved  on  those priority  actions,  but  further 
efforts are needed. 

2025 priority actions 

• 

• 

• 

• 

• 

through 

including 

Further shift reusable and recyclable waste away from 
incineration, 
economic 
instruments. 
Improve  municipal  waste  preparation  for  reuse  and 
recycling. 
Increase the collection and recycling rate of electronic 
and electric equipment waste. 
Invest  in  waste  prevention  measures  to  reduce  the 
total amount of waste generated. 
Ensure  the  achievement  of  the  2025  waste  targets, 
following 
the 
Commission  in  the  early  warning  reports  where 
applicable. 

the  recommendations  made  by 

(38) 

(39) 

(40) 

SEPA, information provided during the Eionet review of the draft 
EEA country profile on waste management for Sweden, 2024. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal  and  packaging  waste –  Sweden,  Copenhagen,  2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/sweden/view. 
januari  2024’, 
Skatteverket, 
Skatteverket 
2023, 
https://www.skatteverket.se/foretag/skatterochavdrag/punktska
tter/nyheterinompunktskatter/2023/nyheterinompunktskatter/a

‘Ändrad  avfallsskatt 
website, 

från  1 
6 December 

ndradavfallsskattfran1januari2024.5.7da1d2e118be03f8e4f2208.
html. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal  and  packaging  waste –  Sweden,  Copenhagen,  2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/sweden/view. 
SEPA information provided during the Eionet review of the draft 
EEA country profile on waste management for Sweden, 2024. 
INFR(2024)2146. 

(41) 

(42) 

(43) 

2025 Environmental Implementation Review – Sweden 

 
 
 
Sweden  12 

2. Biodiversity and natural capital 

Global and EU biodiversity frameworks

Biological  diversity  and  healthy  ecosystems  are  critical 
for our societies, underpin our economies and well-being 
and  are  essential  for  climate  change  adaptation  and 
mitigation.  The  Kunming–Montreal  global  biodiversity 
framework  (GBF),  adopted  in  December  2022,  sets 
comprehensive  and  measurable  targets  to  tackle 
biodiversity  loss  by  2030.  To  implement  this  global 
framework and integrate biodiversity considerations into 
national decision-making, the EU – as well as all Member 
States –  had  to  submit  national  biodiversity  strategies 
and action plans (NBSAPs), or to communicate national 
targets  aligned  with  the  global  targets,  by  the  end  of 
2024. 

The EU biodiversity strategy for 2030 (BDS) aims to put 
EU  biodiversity  on  a  path  to  recovery  by  2030.  It  sets 
quantified targets intended to protect and restore nature 
and manage ecosystems in a sustainable manner, as well 
and 
as  measures 
commitments  to  support  global  biodiversity.  A  BDS 
actions  tracker (44)  and  a  dashboard  of  indicators (45) 
provide information on implementation progress. 

implementation 

enable 

to 

recently 

adopted 

EU  Nature  Restoration 
The 
Regulation (46) is the first EU-wide, comprehensive law of 
its kind and a key instrument for the EU to deliver on the 
global  biodiversity  targets  for  2030.  It  lays  down  an 
overarching  objective  at  the  EU  level  to  put  in  place 
effective  restoration  measures  on  20 %  of  EU  land  and 
sea by 2030 and for all ecosystems in need of restoration 
by  2050.  To  achieve  this,  it  sets  binding  targets  for 
Member States to restore and maintain ecosystems, as 
well as an effective implementation framework based on 
national restoration plans. 

The BDS is the main instrument used by the EU to deliver 
on  its  obligation  under  the  GBF.  The  Commission  has 
submitted  to  the  Convention  on  Biological  Diversity  its 

(44) 

(45) 

(46) 

Actions 

Tracker 

Strategy 

Strategy 

Dashboard 

Biodiversity 

Biodiversity 

EU 
(https://dopa.jrc.ec.europa.eu/kcbd/actions-tracker/). 
EU 
(https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1). 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869,  OJ  L  2024/1991,  29.7.2024), 
the 
see  also 
http://data.europa.eu/eli/reg/2024/1991/oj; 
Commission 
law 
the 
on 
(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 

page 

web 

(47)  Government  of  Sweden,  ‘Sweden’s  national  statement  at  the 
sixteenth  meeting  of  the  Conference  of  the  Parties  to  the 

report on GBF-aligned EU targets that stem from the BDS 
and from other policy instruments under the European 
Green Deal. 

Member  States’  NBSAPs  need  to  provide  coherent 
frameworks  for  national  delivery  on  the  global  and  EU 
2030  biodiversity  targets. 
line  with  the  global 
obligations,  NBSAPs  should  also  include  a  biodiversity 
financing  plan  and  a  capacity-building  plan,  based  on 
needs  assessments,  as  well  as  an  overview  of  the 
national indicators used to measure progress. 

In 

Following  the  adoption  of  the  GBF,  the  process  of 
updating  Sweden’s  NBSAP  has  started.  The  NBSAP 
finalisation and adoption is envisaged in 2025 (47). In July 
2024, Sweden uploaded more than 60 national targets to 
the Convention on Biological Diversity’s online reporting 
tool,  with  each  target  drawing  on  a  range  of  national 
policies  and  instruments  that  contribute  to  the  global 
biodiversity goals (48). 

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 has 
been updated since (49). 

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

The  overarching  goal  of  this  environmental  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. 

website, 

31 October 

Convention  on  Biological  Diversity  (COP 16)’,  government  of 
Sweden 
2024, 
https://www.government.se/speeches/2024/10/swedens-
national-statement-at-the-sixteenth-meeting-of-the-
conference-of-the-parties-to-the-convention-on-biological-
diversity-cop-16/. 
https://ort.cbd.int/national-targets?countries=se. 
SEPA,  Sweden’s  Environmental  Objectives –  An  introduction, 
Stockholm, 
2018, 
https://www.naturvardsverket.se/publikationer/8800/swedens
-environmental-objectives--an-
introduction/#:~:text=The%20overall%20goal%20of%20Swedis
h,health%20problems%20outside%20Sweden's%20borders. 

(48) 
(49) 

2025 Environmental Implementation Review – Sweden 

 
 
Sweden  13 

implementation of Article 3 of the Habitats Directive. The 
Natura 2000 network should represent a complete and 
coherent  ecological network composed of sites hosting 
natural habitat types and species of community interest. 
Natura 2000 will enable the natural habitat types and the 
species’ habitats concerned to be maintained or, where 
appropriate,  restored  to  a  favourable  conservation 
status in their natural range. 

Sweden  hosts  89  habitat  types (52)  and  163  species (53) 
covered by the Habitats Directive. The country also hosts 
populations of 86 bird taxa listed in Annex I of the Birds 
Directive (54). 

As  shown  in  Figure 9,  in  2023,  12.8 %  of  Sweden’s 
national  land  area  was  covered  by  Natura  2000  (EU 
average:  18.6 %),  with  special  protection  areas  (SPAs) 
classified  under  the  Birds  Directive  covering  5.9 %  (EU 
average:  12.8 %)  and  SCIs  under  the  Habitats  Directive 
covering  12.7 %  of  the  Swedish  territory  (EU  average: 
14.3 %). 

Considering  both  Natura  2000  and  other  nationally 
designated  protected  areas,  Sweden  legally  protects 
15 % of its terrestrial areas (55) (EU average: 26.1 %) and 
16 % of its marine areas (EU average: 12.3 %) (56). 

Sweden’s  environmental  policy  is broken  down  into  16 
environmental  quality  objectives 
(EQOs)  covering 
different  areas,  including  an  EQO  focusing  on  ‘a  rich 
diversity  of  plant  and  animal  life’.  Six  other  EQOs  are 
the 
to 
particularly 
implementation of the EU Nature Directives. 

biodiversity 

relevant 

and 

The EU aims to allocate to biodiversity objectives at least 
7.5 % of annual spending under the EU budget in 2024, 
rising  to  10 % 
in  2026  and  2027.  For  details  on 
biodiversity  financing  and  investments  in  Sweden,  see 
‘Biodiversity and ecosystems’ in Chapter 5. 

Nature protection and restoration – Natura 
2000 

Natura  2000 (50),  the  largest  coordinated  network  of 
protected areas in the world, is key to the achievement 
of  the  objectives  set  out  in  the  Birds  and  Habitats 
Directives. These objectives are to ensure the long-term 
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  Birds  and  Habitats 
Directives  are  (i)  the  setting  up  of  a  complete  and 
coherent  Natura  2000  network;  (ii)  the  designation  of 
sites of community importance (SCIs) as special areas of 
conservation (SACs) (51); and (iii) effective management 
of  all  Natura  2000  sites  through  the  setting  of  site-
specific conservation objectives and measures. 

Setting up a complete and coherent network of Natura 
2000 sites 

The  setting  up  of  a  complete  and  coherent  network  of 
Natura  2000  sites 
is  a  cornerstone  of  the  EU’s 
international commitments, under the BDS and GBF, to 
legally  protect  a  minimum  of  30 %  of  its  land  area  and 
30 % of its sea area by 2030. 

Meeting 

these 

commitments 

requires 

the 

full 

(51) 

(50)  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. Numbers of protected areas in Figure 9 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. A special area of conservation (SAC) is an SCI designated 
by a Member State. 
SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
Article 17  dashboard,  Annex I 
total,  19 December  2019, 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/general-information-on-habitats-and-species-article-17-
national-summary-dashboards-archived. 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
Article 17 
2019, 
19 December 
https://www.eea.europa.eu/en/analysis/maps-and-

dashboard, 

(53) 

(52) 

(54) 

(55) 

(56) 

charts/general-information-on-habitats-and-species-article-17-
national-summary-dashboards-archived. 
EEA,  ‘Number  of  bird  species/populations  per  Member  State’, 
Article 12 dashboard, Annex I total, last updated 11 May 2023, 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/general-information-on-bird-species-populations-article-
12-national-summary-dashboards-archived.  This  counting  only 
takes  into  account  birds  taxa  for  which  information  was 
requested. 
EEA, ‘Share of country designated as terrestrial protected area 
and  the  overlap  between  Natura  2000  or  Emerald  sites  and 
national  designations’, 
last  updated  20 September  2024, 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/complementarity-between-european-designations-
3?activeTab=265e2bee-7de3-46e8-b6ee-76005f3f434f. 
Eurostat dataset env_bio4, protected area percentage for 2022, 
last 
2025, 
https://ec.europa.eu/eurostat/databrowser/view/env_bio4/de
fault/table?lang=en. 

12 March 

updated 

2025 Environmental Implementation Review – Sweden 

 
 
Figure 9: Natura 2000 terrestrial protected area 
coverage per Member State (%), 2022 

Source: European Environment Agency (EEA), ‘Natura 2000 Barometer’, 
2023  data,  accessed  March  2025,  https://www.eea.europa.eu/data-
and-maps/dashboards/natura-2000-barometer. 

Designating  special  areas  of  conservation  and  setting 
site-specific conservation objectives and measures 

In order to ensure that SCIs contribute to the objectives 
of the Habitats Directive, Member States must designate 
them  as  SACs,  setting  site-specific  conservation 
objectives based on the ecological needs of the species 
and  habitats  present  on  the  sites.  The  site-specific 
conservation  objectives  must  be  defined  in  terms  of 
attributes  and  targets  that  cover  the  properties  of  the 
feature  of  interest  that  are  necessary  to  describe  its 
condition  as  either  favourable  or  unfavourable.  These 
objectives  must  address  the  key  pressures  and  threats 
present  on  the  site.  Article 6  of  the  Habitats  Directive 
requires  Member  States  to  establish  and  implement 
conservation  measures  for  the  realisation  of  the 
objectives of the site. 

The assessment of the Natura 2000 network showed that 
there  are  insufficiencies  in  the  designation  of  SCIs  and 
SPAs. Sweden is subject to an infringement  case (57) on 
the insufficiency of (i) the list of proposed SCIs according 
to  Article 4(1)  of  the  Habitats  Directive,  and  of  (ii)  the 
SPAs under Article 4(1) and (2) of the Birds Directive, in 
particular  completion of the designation of the SPAs at 
sea. 

Recovery of species 

One  objective  set  by  the  BDS  is  that,  by  2030,  there 
should be no further deterioration in conservation trends 

Sweden  14 

or  the  status  of  any  protected  species.  The  BDS  also 
states  that  Member  States  should  ensure  that  at  least 
30 % of species not currently in favourable conservation 
status  achieve  that  status  or  show  progress  towards 
doing so (e.g. by exhibiting positive population dynamics 
or stable or increasing range and habitat size), by 2030. 
According  to  the  European  Environment  Agency  (EEA), 
based  on  reporting  required  under  Article 17  of  the 
Habitats Directive, a quarter of species in the EU were of 
good conservation status as of 2018 (58). 

One of the primary objectives of the Habitats Directive is 
the  maintenance  of  or  restoration  to  favourable 
conservation status of all species of community interest. 
Moreover, the Birds Directive also aims to ensure that all 
wild  birds  in  the  EU  enjoy  a  secure  status.  In  order  to 
achieve these objectives, it will be necessary to address 
key  pressures  and  threats.  The  Birds  Directive  and  the 
Habitats  Directive  lay  down  a  framework  of  species 
protection rules and rules on the conservation of habitats 
and species in order to combat these threats. 

Under  Article 17  of  the  Habitats  Directive,  Member 
States are required to report on the conservation status 
of  habitats  and  species  every  six  years.  The  current 
reporting cycle, covering the years 2019 to 2024, is due 
for submission in July 2025. 

According  to  the  last  available  report  from  Sweden  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 (i.e. 
2007–2012). The share of habitats in good conservation 
status  has  decreased  by  3.09 percentage  points  and 
accounted  for  22.58 %  in  2018  compared  with  the 
25.67 %  reported  under  the  previous  reporting  period 
(see  Figure 10).  As  for  protected  species,  the  share  of 
assessments  in  good  conservation  status  in  2018  has 
increased  by  1.9 percentage  points  and  accounted  for 
47.45 % compared with the 45.55 % reported under the 
previous reporting period (see Figure 11). 

However,  conservation  statuses  are  uneven  across 
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 
statuses,  while  all  the  others  have  unfavourable 
statuses (59). 

At the same time, the share  of habitats in bad  or poor 

(57) 
(58) 

INFR(2020)2207. 
EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
European 
2020, 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 

Luxembourg, 

Union, 

(59) 

EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
2020, 
European 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 

Luxembourg, 

Union, 

2025 Environmental Implementation Review – Sweden 

 
 
 
increased  to  77.42 %  (see 
conservation  status  has 
Figure 10), while the share of assessments for species in 
bad or poor conservation status has (slightly) decreased 
to 51.46 % (see Figure 11). 

and-trends 

Figure 11: Assessments of conservation status of 
species for the 2007–2012 and 2013–2018 reporting 
periods 

Sweden  15 

to 

less  biodiverse 

is  forestry 
For  forest  habitats,  the  main  pressure 
(including  conversion 
forests), 
followed  by  energy  production  (biomass)  and  natural 
processes.  For  grasslands  and  agriculture-dependent 
habitats,  the  main  pressures  relate  to  agriculture  (e.g. 
ceased grazing and grassland abandonment). For water-
dependent  habitats,  pressure  relates  to  conversion  to 
forestry and modification of hydrological flows (including 
obstacles  to  river  continuity).  For  coastal  habitats, 
urbanisation  and  industrialisation,  including  pollution, 
are  major  pressures.  Invasive  alien  species  (IAS)  are 
assessed as an increasing threat to biodiversity. 

As regards to 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  one  third  have  a  bad  status. 
According  to  national  data  regarding  forest  birds,  six 
species increased in number and six species decreased in 
number between 2002 and 2023 (60). 

Figure 10: Assessments of conservation status of 
habitats for the 2007–2012 and 2013–2018 reporting 
periods 

NB: Please note when comparing the figures shown for 2007–2012 and 
2013–2018 that these data may also be affected by changes of methods 
or due to better data availability. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2024, 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-

December 

accessed 

2019, 

NB: Please note when comparing the figures shown for 2007–2012 and 
2013–2018 that these data may also be affected by changes of methods 
or due to better data availability. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
2024, 
19 December 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

December 

accessed 

2019, 

As mentioned above, some marine Natura 2000 sites are 
not yet effectively managed and further efforts could be 
made  to  reduce  significant  disturbances  to  highly 
sensitive  marine  species.  Sweden  is  subject  to  an 
infringement  procedure  addressing  the  protection  of 
those marine areas in the framework of the designation 
of Natura 2000 sites (61). 

Another infringement case is open regarding insufficient 
action by Sweden to monitor and prevent the bycatch of 
harbour  porpoises (62).  The  same  procedure  covers 
Sweden’s  failure  to  transpose  the  prohibition –  in  the 
Habitats Directive – to significantly disturb species within 
Natura 2000 sites. There is also an ongoing infringement 
case 
licensed  hunting  of 
wolves (63). 

concerning  Sweden’s 

The  financial  instrument  for  the  environment  (LIFE) 
programme has been widely used in Sweden for nature 
purposes. Three recent example projects are: 

• 

Ecostreams  for  LIFE  (Ecosystem  based  restoration 
and management of boreal rivers); 

(60)  Green, M., Haas, F. and Lindström, Å., Övervakning av fåglarnas 
populationsutveckling –  Årsrapport  för  2023,  Lund  University, 
Lund, 
2023, 
https://www.fageltaxering.lu.se/sites/fageltaxering.lu.se/files/2
024-10/arsrapportfor2023.pdf. 

(61) 
(62) 
(63) 

INFR(2020)2207. 
INFR(2020)4037. 
INFR(2010)4200. 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
Sweden  16 

• 

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). 

2025 priority actions 

•  Complete the Natura 2000 site designation process. 
• 
Strengthen  the  integration  of  biodiversity  actions 
into  other  policies  (e.g.  on  energy,  agriculture, 
fisheries, 
infrastructure 
planning,  and  sustainable  tourism),  and  promote 
communication between stakeholders. 

forestry,  urban  and 

adequately targeted toward this objective (64). 

The  CAP  and  national  CAP  strategic  plans  are  key 
instruments  to  facilitate  and  strengthen  the  efforts  of 
European  farmers  to  protect  biodiversity  and  the 
environment  at 
large.  The  Commission  approved 
Member  States’  CAP  strategic  plans  in  2022  for  the 
programming period 2023-2027. The CAP is the  largest 
source  of  funding  dedicated  to  supporting  biodiversity 
and  plays  a  significant  role 
implementing  EU 
environmental policy. Strategic plans should continue to 
support  the  protection  of  soil,  water,  air  quality  and 
biodiversity. 

in 

•  Reinforce  action 

for  habitats  and  species 

in 
unfavourable  conservation  status,  for  example 
increased 
through 
restoration  measures, 
coordination  and 
connectivity,  better  policy 
integration, and increased funding. 

Recovery of ecosystems 

Agricultural ecosystems 

The BDS works alongside the common agricultural policy 
(CAP) to support the transition to sustainable agriculture. 

The  strategy  has  set  five  common  agriculture-related 
targets for 2030, namely to: 

—  reduce by 50 % the overall use of – and risk from – 

chemical pesticides; 

—  reduce  by  50 %  the  use  of  more  hazardous 

pesticides; 

—  reduce  by  50 %  losses  of  nutrients  from  fertilisers 
(which  will result in a  20 % reduction in the use of 
fertilisers)  while  ensuring 
is  no 
deterioration of soil fertility; 

there 

that 

—  restore  at  least  10 %  of  agricultural  area  to  have 

— 

high-diversity landscape features; and 
increase the area under organic farming to at least 
25 %. 

The  “Vision  for  agriculture  and  food”,  adopted  by  the 
European Commission in February 2025, sets a roadmap 
to  an  agri-food  system  that  is  attractive,  competitive, 
sustainable and fair for current and future generations. 
To  ensure  a  sustainable  future  for  EU  agriculture,  it  is 
crucial  that  these  four  priority  areas  are  pursued 
together,  and  that  public  and  private  support  are 

(64) 

(65) 

(66) 

https://agriculture.ec.europa.eu/overview-vision-agriculture-

food/vision-agriculture-and-food_en  
Eurostat,  ‘Utilised  agricultural  area  by  categories’,  tag00025, 
accessed 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/tag00025/de
fault/table?lang=en. 
Regulation (EU) 2024/1468 of the European Parliament and of 
the  Council  of  14 May  2024  amending  Regulations  (EU) 

5 December 

indicators 

certain  CAP 

While 
focus  on 
result 
interventions favouring sustainable agriculture practices 
impact  of  these 
that  regenerate  ecosystems,  the 
measures  is  difficult  to  assess.  The  uptake  of  the  eco-
schemes is voluntary for farmers. 

The utilised agricultural area  in  Sweden increased from 
3 031 500 ha  in  2012  to  3 036 080 ha  in  2013  and 
decreased to 2 995 180 ha in 2022 (65). 

Landscape  features  are  small  fragments  of  non-
productive  and  typically –  but  not  exclusively –  semi-
natural vegetation present in or adjacent to agricultural 
land.  They  provide  ecosystem  services  and  support  for 
biodiversity.  The  indicator  ‘share  of  agricultural  land 
covered  with  landscape  features’  is  the  ratio  between 
the  area  covered  by  landscape  features  and  the  area 
land.  Based  on  the  Land 
covered  by  agricultural 
Use/Cover  Area  Frame  Survey 
landscape  features 
estimates,  the  share  of  agricultural  land  covered  with 
non-productive  landscape  features  in  Sweden  is  8.1 %, 
above  the  EU  average.  At  the  EU  level,  landscape 
features cover 5.6 % of agricultural land. 

In  2024,  the  CAP  basic  regulations  were  amended (66), 
regarding, inter alia, the standards for good agricultural 
and  environmental  condition  of  land.  These  changes 
removed the obligation for farmers benefiting from CAP 
area-related support to have a minimum share of 3–4 % 
of  non-productive  areas  or  landscape  features  in  their 
farms.  However,  the  amended  regulation  does  not 
remove  the  obligation  under  the  GAEC  8  to  maintain 
existing  landscape  features,  and  sets  out  an  obligation 
for Member States to establish and provide support for 
eco-schemes covering practices for the maintenance of 
non-productive areas, such as land lying fallow, and for 

2021/2115 and (EU) 2021/2116 as regards good agricultural and 
environmental  condition  standards,  schemes  for  climate, 
environment  and  animal  welfare,  amendment  of  the  CAP 
strategic plans, review of the CAP strategic plans and exemptions 
from  controls  and  penalties  (OJ  L,  2024/1468,  24.5.2024), 
http://data.europa.eu/eli/reg/2024/1468/oj. 

2025 Environmental Implementation Review – Sweden 

 
 
the establishment of new landscape features on arable 
land. 

Soil ecosystems 

Sweden  17 

The recently adopted Nature Restoration Regulation (67) 
focuses on the restoration of agricultural ecosystems and 
requires  Member  States  to  put  in  place  measures  that 
aim to achieve an increasing trend at the national level in 
at  least  two  out  of  three  indicators  for  agricultural 
ecosystems (68). One of these indicators is the ‘share of 
agricultural land with high-diversity landscape features’. 

Organic  farming  practices  are  highly  beneficial  to 
biodiversity. As shown in  Figure 12, it is estimated that 
19.94 %  of  Sweden’s  utilised  agricultural  land  area  is 
used for organic farming. This is the third best result in 
the  EU  and  much  higher  than  the  EU  average  of 
10.5 % (69). Sweden is therefore significantly contributing 
to  achieving  the  target  to  have  25 %  of  the  EU’s 
agricultural land being used for organic farming by 2030. 

Figure 12:  Share  of  total  utilised  agricultural  area 
occupied  by  organic  farming  per  Member  State  (%), 
2022 

Soil is an essential, finite and extremely fragile resource. 
Its  increasing  degradation  poses  a  threat  to  EU  food 
resilience,  adaptation  and 
security  and  climate 
mitigation. 

The EU soil strategy, adopted in November 2021, aims to 
support  soil  protection,  sustainable  soil  management 
and  the  restoration  of  degraded  soils  to  achieve  the 
Green  Deal  objectives  as  well  as  land  degradation 
neutrality by 2030. 

This entails: 

—  preventing further soil degradation; 
—  making  sustainable  soil  management  the  new 

normal; 

—  taking action for ecosystem restoration. 

The  proposed  directive  on  soil  monitoring  and 
resilience (70) aims to introduce the first comprehensive 
legislation on the protection of all soils in the EU. Should 
the  directive  be  adopted,  Member  States  will  have  to 
transpose  it  into  national  legislation  and  implement  it, 
starting  with  putting  in  place  the  governance  systems 
and a sound monitoring framework building on existing 
national  soil  monitoring  frameworks.  The  objective  of 
the  proposed  directive  is  to  provide  better  and  more 
comparable  soil  health  data  with  the  view  of  attaining 
healthy soils by 2050. 

Degradation  of  soil  ecosystems  encompasses  several 
aspects. The proposed directive requires Member States 
to  assess  soil  health  according  to  a  set  of  common 
indicators  and  to  define  the  necessary  regeneration 
measures. The area of soil that is sealed is an important 
factor in monitoring land-use change and represents an 
important pressure on nature and biodiversity. Other soil 
issues  related  to  land degradation  are  soil  erosion,  soil 
compaction, 
soil 
contamination, soil salinisation and the presence in soil 
of  nitrogen  and  phosphorus  in  excess.  The  impact 
assessment accompanying the proposal, which builds on 
the data available in the EU Soil Observatory, points to 
the following soil degradation issues in Sweden (71). 

soil  organic 

loss  of 

carbon, 

Source:  Eurostat,  ‘Area  under  organic  farming’,  sdg_02_40,  accessed 
5 December 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en. 

2025 priority action 

Implement  eco-schemes  and  agri-environmental 
measures 
the 
environmental needs of Sweden. 

practices 

address 

and 

to 

• 

(67) 

(68) 

(69) 

Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
http://data.europa.eu/eli/reg/2024/1991/oj. 
The  three  indicators  are  ‘grassland  butterfly  index’,  ‘stock  of 
organic  carbon 
‘share  of 
agricultural land with high-diversity landscape features’. 
This is based on the latest available information from Eurostat, 
which 
is  currently  under  review;  European  Commission, 
Agriculture biologique au sein de l’union européenne, factsheet, 
2024, 
Brussels, 

in  cropland  mineral  soils’  and 

(70) 

(71) 

https://agriculture.ec.europa.eu/document/download/c67458e
d-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-
organic-farning_fr.pdf&prefLang=en. 
Proposal for a directive of the European Parliament and of the 
Council on soil monitoring and resilience (Soil Monitoring Law), 
COM(2023) 416 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex:52023PC0416. 
Commission  staff  working  document –  Impact  assessment 
report: Annexes – Accompanying the proposal for a directive of 
the European Parliament and of the Council on soil monitoring 

2023, 

5 July 

final 

of 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
Only 5 % of Sweden’s soils are considered unhealthy. The 
greatest  contributor  to  this  status  is  unsustainable  soil 
erosion by water, wind, tillage and harvest, which affects 
3 %  of  the  land  and  37 %  of  cropland  areas.  The  other 
indicators of unhealthy soil are negligeable. 

Grasslands 

Grasslands  are  among  the  most  diverse  ecosystems  in 
the EU; they can contain as many as 80 different  plant 
species per square metre and are home to a large variety 
of animals, ranging from small insects, birds and rodents 
to 
for 
large  herbivores.  Grasslands  are  essential 
agriculture and livestock herding. Natural grasslands also 
play  an  important  role  in  storing  carbon.  However, 
changes  in  agricultural  practices  and  land  uses  have 
caused  grasslands  to  disappear  at  an  alarming  rate, 
making  them  one  of  Europe’s  most  threatened 
ecosystems. 

Sweden hosts  14 grassland habitat  types, of which  five 
are  priority  habitats  (habitats  6110,  6120,  6230,  6270 
and 6280). The majority are in bad conservation status, 
with the exceptions of 6150, siliceous alpine and boreal 
grasslands;  6170,  alpine  and  subalpine  calcareous 
grasslands;  6110,  rupicolous  calcareous  or  basophilic 
grasslands (continental only); and 6430, hydrophilous tall 
herb fringe communities of plains and of the montane to 
alpine levels (alpine only). 

The main pressures on grasslands in Sweden come from 
abandonment  (lack  of active management)  with  risk  of 
conversion to forest, and pollution. 

Wetlands/peatlands 

Wetlands act as water sources and purifiers; they are the 
planet’s  greatest  natural  carbon  stores  and  they  are 
crucial  to  agriculture  and  fisheries.  Peatlands  are  a 
special  type  of  wetlands  dominated  by  peat-forming 
plants such as Sphagnum mosses. Nearly all peatlands in 
the EU are habitat types listed in Annex I of the Habitats 
Directive. Drained peatlands under intensive agricultural 
use  constitute  only  3 %  of  the  EU’s  utilised  agricultural 
area. At the same time, they are responsible for 25 % of 
the  GHG  emissions  from  the  EU’s  agricultural  sector. 
Restoring  peatlands  brings  multiple  benefits,  as 
peatlands  improve  water  retention  and  quality,  store 
carbon, reduce GHG emissions and increase biodiversity. 

Sweden  18 

Sweden  hosts  11  ‘bogs,  mires  and  fens’  habitat  types 
across its three biogeographical regions, all are priority 
habitats with the exception of the habitat 7 130 alkaline 
fens.  The  main  pressures  come  from  agriculture  and 
forestry as well as pollution. 

The  Swedish  Environmental  Protection  Agency  has 
funded eight research projects on the ecosystem services 
of wetlands, which will strengthen the opportunities for 
locating  future  wetlands (72). 
optimal  planning  and 
During the annual nature dialogue with the Commission, 
Swedish environmental authorities confirmed their focus 
on  wetland  restoration  in  view  of  climate  change 
mitigation  objectives and contributing to the  targets of 
the Nature Restoration Regulation. 

Forest ecosystems 

Forests are important carbon sinks, and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 
The EU forest strategy for 2030, adopted in July 2021, is 
a  plan  of  actions  to  promote  the  many  services  that 
forests  provide.  Its  key  objective  is  to  ensure  healthy, 
diverse  and  resilient  EU 
forests  that  contribute 
significantly to the achievement of the EU’s biodiversity 
and climate ambitions. About 27 % of the forest area in 
the EU is covered by habitat types listed in Annex I to the 
Habitats  Directive.  Moreover,  forests  host  several 
species  protected  under  the  Birds  and  Habitats 
is  a 
Directives, 
requirement  to  designate  Natura  2000  sites  and  to 
protect breeding sites and resting places. 

including  those  for  which  there 

Several Commission guidelines on forestry management 
were  published  in  2023.  They  covered  biodiversity-
friendly  afforestation,  reforestation  and  tree  planting; 
closer-to-nature  forest  management;  and  defining, 
mapping, monitoring and strictly protecting primary and 
old-growth  forests.  Further  guidance  on  payment 
schemes 
for  ecosystems  services  has  also  been 
published. 

In  2023,  the  Commission  proposed  a  new  forest 
monitoring  law  that  aims  to  create  a  comprehensive 
forest  knowledge  base,  address  information  gaps  and 
enable  a  better  response  to  growing  pressures  on 
forests. 

Assessments  show  that  of  the  27 %  of  the  forest  area 
protected  EU-wide  under  the  Habitats  Directive,  less 

and  resilience  (Soil  Monitoring  Law),  SWD(2023) 417  final  of 
2023, 
5 July 
https://environment.ec.europa.eu/system/files/2023-
07/IMPACT 
REPORT_ANNEXES_SWD_2023_417_part4.pdf. 

ASSESSMENT 

(72) 

SEPA,  ‘Våtmarkers  ekosystemtjänster’,  SEPA  website,  20 June 
https://www.naturvardsverket.se/om-
2024, 
miljoarbetet/forskning/miljoforskning/natur/vatmarkers-
ekosystemtjanster/. 

2025 Environmental Implementation Review – Sweden 

 
 
than  15 %  is  of  favourable  conservation  status (73).  The 
share of forested areas in the EU with a bad conservation 
status increased from 27 % in 2015 to 31 % in 2018. 

Sweden  hosts  15  forest  habitat  types,  among  which 
seven  are  priority  habitat  types  (habitats  9010,  9020, 
9030, 9080, 9180, 91D0, 91E0 and 91F0). 

In  Sweden,  forests  covered  68.7 %  of  the  territory  in 
2020 (74).  As  shown  in  Figure  13,  only  6%  of  Swedish 
forest  habitats  protected  under  the  Habitats  Directive 
are in favourable conservation status, while all the others 
are  in  unfavourable  (bad  or  poor)  status  (75).  In  total, 
2 249 000 ha,  i.e.  around  8%  of  the  total  forest  area  in 
Sweden, are covered by primary forests (76). Most of this 
area consists of formally protected areas or is exempted 
from harvesting, either by law or on a voluntary basis. Yet 
scientists  report  that  unprotected  boreal  old-growth 
forests have been cut  at a rate that could lead to their 
disappearance within 50 years (77). 

By  far  the  main  threat  to  forests  is  forestry,  especially 
intensive  logging,  followed  by  energy  production  and 
natural  processes. 
Environmental 
Protection Agency has found that Sweden is not on track 
to  meet  its  sustainable  forest  goals  for  2030  as  policy 
towards 
instruments 
production rather than valuing biodiversity.(78)  

forest  management 

Swedish 

steer 

The 

According to the OECD, "[f]orestry practices need to be 
adapted  to  better  support  biodiversity,  especially  in 
areas  of  high  conservation  values.  Production  and 
environmental  objectives  are  not  well  balanced  in 
forestry  policy,  which  favours  voluntary  biodiversity 
conservation.  Ambiguities  of  the  Forestry  Act  have 
hindered the supervision of the Swedish Forestry Agency 
and  the  proper  application  of  the  Environmental  Code, 
resulting  in  the  continued  felling  of  forests  with  high 

(73) 

(74) 

(75) 

(76) 

base: 

Union, 

Luxembourg, 

EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
European 
2020, 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 
EEA,  forest  information  system  for  Europe,  ‘Countries –  FISE 
country  factsheets’,  forest  information  system  for  Europe 
website, https://forest.eea.europa.eu/countries. 
Commission staff working document – Stakeholder consultation 
document 
evidence 
and 
Communication 
from  the  Commission  to  the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – New EU forest 
strategy  for  2030,  SWD(2021) 652  final  of  16 July  2021, 
https://eur-lex.europa.eu/legal-
content/NL/TXT/?uri=CELEX:52021SC0652. 
European  Commission:  Joint  Research  Centre,  Mapping  and 
assessment  of  primary  and  old-growth  forests  in  Europe, 
Publications Office of the European  Union, Luxembourg, 2021, 
p. 13, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC124
671. 

Accompanying 

the 

Sweden  19 

conservation values."(79) 

Figure 13:  Conservation  status  of  forests  protected 
under the Habitats Directive  per Member State 2013–
2018 (% of assessments) 

Source:  Source: Commission staff working document – New EU forest 
strategy  for  2030,  SWD(2021) 652  final  of  16 July  2021,  p. 24,  eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0652.f. 

The  EU  Timber  Regulation  (EUTR) (80)  prohibits  the 
placing on the EU market of illegally harvested timber.  

(EUDR) (81)  entered 

On  29 June  2023,  the  Regulation  on  Deforestation-free 
(82).  The 
Products 
regulation  seeks  to  guarantee  that  products  in  the  EU 
that  are  made  using  any  of  seven  listed  commodities 
have  no  links  to  deforestation.  The  EUDR  repeals  the 
EUTR.  

force 

into 

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 

(77) 

A.  Ahlström,  J.  G.  Canadell,  D.  B.  Metcalfe,  "Widespread 
Unquantified Conversion of Old Boreal Forests to Plantations", 
Earth's Future, 2022, https://doi.org/10.1029/2022EF003221.  

(78)   Naturvårdsverket, "Fördjupad utvärdering av Sveriges miljömål 
2023, 

2023", 
https://www.naturvardsverket.se/4acc3d/globalassets/media/
publikationer-pdf/7000/978-91-620-7088-5.pdf.  

January 

(79)  OECD, Environmental Performance Review of Sweden, 2025.  
(80) 

(81) 

Regulation (EU) No 995/2010 of the European Parliament and of 
the  Council  of  20 October  2010  laying  down  the  obligations  of 
operators who place timber and timber products on the market 
(OJ  L 295,  12.11.2010,  p. 23),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010R0995. 
Regulation (EU) 2023/1115 of the European Parliament and of 
the  Council  of  31 May  on  the  making  available  on  the  Union 
market and the export  from the Union of certain commodities 
and  products  associated  with  deforestation  and 
forest 
degradation  and  repealing  Regulation  (EU)  No 995/2010  (OJ 
L 150,  9.6.2023,  p. 206),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461. 

(82)   The law will apply to large and medium-sized companies starting 
on  December  30,  2025,  and  to  micro  and  small  enterprises 
starting on June 30, 2026. 

2025 Environmental Implementation Review – Sweden 

 
 
 
2030. In the 2022 EIR, Sweden was called upon to involve 
the forestry sector in management practices compatible 
with species preservation, and to identify and preserve 
areas  of  high  ecological  value  for  the  Natura  2000 
network. As no substantial progress has been achieved, 
these  recommendations  are  repeated  in  the  current 
report. 

2025 priority actions 

• 

• 

Improve  the  conservation  status  of  forests  by 
promoting  sustainable  forest  management  and 
ensuring  compliance  with  the  Habitats  Directive 
before granting/renewing permits for forest logging. 
Implement  peatland  conservation  and  restoration 
measures and include such measures and objectives 
in the national restoration plans. 

Marine ecosystems 

The  Marine  Strategy  Framework  Directive  (MSFD) 
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 other Member States 
sharing  the  same  marine  region  or  subregion.  These 
marine  strategies  comprise  different  steps  to  be 
developed and implemented over six-year cycles. 

in 

Since the 2022 EIR report, no additional data regarding 
Member  States’  set  of  GES  characteristics  for  each 
descriptor 
the  MSFD  has  become  available. 
Nevertheless, Member States had to report updates by 
October  2024.  In  the  context  of  this  reporting,  in 
accordance  with  the  MSFD  and  the  Commission  GES 
decision (83), Member States must include as part of their 
set  of  GES  characteristics  any  threshold  values  for  the 
descriptors in the MSFD that may have been established 
in  cooperation  with  other  Member  States  at  the  EU  or 
regional level (84). Sweden has reported the Articles 8, 9 
and  10  data  required  by  the  Article 17  of  the  MSFD, 
which are now under the assessment of the Commission. 

The  Commission  assessed  the  updated  monitoring 
programme reported by Member States in 2020 (85). At 
that time, their updates on the elements, features and 
parameters identified monitoring gaps. The Commission 
recommended  that  Member  States  should  prioritise 

(83) 

(84) 

Commission  Decision  (EU) 2017/848  of  17 May  2017  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 (OJ L 125, 18.5.2017, p. 43–74), 
http://data.europa.eu/eli/dec/2017/848/oj. 
Commission notice on the threshold values set under the Marine 
(Directive 2008/56/EC)  and 
Strategy  Framework  Directive 

to  address 

work 
implementation of the MSFD. 

those  gaps  at  all 

Sweden  20 

levels  of 

Member States also reported their updated programmes 
of measures, which are required under Article 13 of the 
MSFD and  which  must  be updated every  six years. The 
Commission has assessed Member States’ programmes 
of measures. 

Figure 14: Level of adequacy of Sweden’s updated 
programme of measures under Article 13 of the MSFD 
(2022 reporting exercise) 

Source: Technical assessment carried out by the European Commission, 
pursuant  to  Article 16  of  the  MSFD,  based  on  the  data  reported  by 
Sweden in March 2022. 

Sweden’s  updated  programme  of  measures  was 
assessed overall with a good adequacy level, with most 
descriptors scoring ‘good’ or ‘very good’. This is due to a 
comprehensive gap analysis and, in most cases, targeted 
measures that aimed at directly addressing the relevant 
environmental pressures. 

For biodiversity (D1), new measures were introduced to 
reduce harmful fishing techniques  such as trawling and 
to  prevent  oil  spills.  For  sea-floor  integrity  (D6),  while 
important gaps remain regarding bottom trawling in the 
North Sea, a new measure to reduce the trawling swept 
area stands out as particularly effective in contributing to 
GES. 

For contaminants (D8) and contaminants in seafood (D9), 
the effectiveness of new measures remains unclear due 
to a lack of quantification of the anticipated impact. For 

Commission  Decision  (EU)  2017/848  (C/2024/2078)  (OJ  C, 
C/2024/2078, 
11.3.2024), 
http://data.europa.eu/eli/C/2024/2078/oj. 
https://environment.ec.europa.eu/system/files/2023-
04/C_2023_2203_F1_COMMUNICATION_FROM_COMMISSION
_EN_V5_P1_2532109.PDF. 

(85) 

2025 Environmental Implementation Review – Sweden 

 
 
 
Sweden  21 

marine litter (D10), there is a need to more extensively 
cover micro-, seabed and surface litter alongside macro- 
and beach litter. 

and 38 additions. Of these additions, 27 were already on 
the Union concern list in 2021, and 11 were added later 
under  Commission 
(EU) 
2022/1203. 

Implementing  Regulation 

Prevention and management of invasive alien 
species 

Figure 15: Number of IAS of EU concern, based on 
available georeferenced information for Sweden, 2024 

IAS  are  a  major  cause  of  biodiversity  loss  in  the  EU. 
Besides  inflicting  direct  and  indirect  damage  on  nature 
and  the  economy,  some  IAS  also  carry  and  spread 
infectious  diseases,  posing  a  threat  to  humans  and 
IAS 
wildlife.  Regulation 
Regulation) aims to prevent, minimise and mitigate the 
adverse impacts of IAS on biodiversity. It focuses action 
on a list of IAS of EU concern (the ‘Union list’), which is 
regularly updated (86). 

(EU)  No 1143/2014 

(the 

The third update of the Union list (87) entered into force 
on 2 August 2022. The fourth update is in preparation. 

The IAS Regulation (88) currently lists 88 species subject 
to  restrictions  on  keeping,  importing,  selling,  breeding, 
growing  and  releasing  into  the  environment.  Member 
States are required to take measures to (i) prevent the 
introduction of IAS, (ii) ensure early detection and rapid 
eradication  of  IAS  and  (iii)  manage  species  that  are 
already  widespread  on  their  territory.  This  aligns  with 
target 6 of the GBF to reduce the introduction of IAS by 
at least 50 % by 2030 and minimise their impact. 

Preventing  the  introduction  and  spread  of  IAS,  and 
managing  them, 
including  through  eradication  and 
control,  can  result  in  a  substantial  cost  saving.  Studies 
estimate  that  the  total  cost  of  IAS  in  Europe  (damages 
and  management)  amounted  to  EUR 116.61 billion 
between  1960  and  2020 (89).  More  recent  studies  have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 
increasing  to  USD 148.2 billion  by  2040 (90),  and  at 
USD 423 billion annually at the global level (91). 

There are in total 54 IAS of Union concern in Sweden. This 
includes 16 species recorded in the previous EIR (2021) 

(86) 

(87) 

(88) 

Commission Implementing Regulation (EU) 2016/1141 of 13 July 
2016 adopting a list of invasive alien species of Union concern 
pursuant  to  Regulation  (EU)  No 1143/2014  of  the  European 
Parliament  and  of  the  Council  (OJ  L 189,  14.7.2016,  p. 4),  as 
amended  by  Commission 
Implementing  Regulations  (EU) 
2017/1263,  (EU)  2019/1262  and  (EU)  2022/1203,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN. 
Commission Implementing Regulation (EU) 2022/1203 of 12 July 
2022  amending  Implementing  Regulation  (EU)  2016/1141  to 
update  the  list  of  invasive  alien  species  of  Union  concern  (OJ 
L 186,  13.7.2022,  p. 10),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32022R1203. 
Regulation (EU) No 1143/2014 of the European Parliament and 
of  the  Council  of  22 October  2014  on  the  prevention  and 

Sweden has made significant progress on the action on 
implementation of the IAS Regulation. 

2025 priority action 

• 

Step  up  implementation  of  the  IAS  Regulation, 
including  with  regard  to  enforcement  and  the 
capacity of inspection authorities. 

Ecosystem assessment and accounting 

The  BDS  calls  on  Member  States  to  better  integrate 
biodiversity  considerations  into  public  and  business 
decision-making  at  all  levels  and  to  develop  natural 
capital accounting. 

Similarly, target 14 of the GBF (92) aims to ensure the full 

management  of  the  introduction  and  spread  of  invasive  alien 
species (OJ L 317, 4.11.2014, p. 35). 

(89)  Haubrock, P. J., Turbelin, A. J., Cuthbert, R. N. et al., ‘Economic 
costs of invasive alien species across Europe’, NeoBiota, Vol. 63, 
2021, pp. 153–190. 

(91) 

(90)  Henry, M., Leung, B., Cuthbert, R. N. et al., ‘Unveiling the hidden 
economic  toll  of  biological  invasions  in  the  European  Union’, 
Environmental Sciences Europe, Vol. 35, No 1, 2023, p. 43. 
on 
Platform 
IPBES 
Biodiversity 
for 
Summary 
Policymakers –  Invasive  alien  species  assessment,  Bonn,  2023, 
https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 

Science-Policy 
Services), 

(Intergovernmental 

Ecosystem 

and 

(92)  Decision 15/4 adopted by the Conference of the Parties to the 
Convention  on  Biological  Diversity:  Kunming–Montreal  global 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
Sweden  22 

integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 
accounting.  This  requires  effective  and  coherent 
biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (93). 

The amended Regulation (EU) No 691/2011 on European 
environmental  economic  accounts (94)  introduces  new 
requirements  for  Member  States  to  report  on  the 
condition  of  ecosystems  including  urban  ecosystems, 
croplands,  grasslands,  forest  and  woodlands,  coastal 
beaches,  dunes  and  wetlands.  Data  reported  by  the 
Member  States  will  feed  into  the  second  European 
ecosystem assessment, due in 2027, and can also be used 
to support policy decisions. 

An ecosystem assessment is an analysis of the condition 
of ecosystems and the pressures acting on them, as well 
as  the  benefits  that  they  provide  to  people,  either 
directly or indirectly through the economy. 

Sweden  has  ongoing  projects 
for  communicating 
information  about  ecosystem  services  and  a  research 
programme on ‘the value of ecosystem services’. 

An 
increasing  number  of  platforms,  networks  and 
communities of practice involve businesses in protecting 
biodiversity,  including  the  EU  Business  &  Biodiversity 
Platform (95). These platforms and communities are key 
tools  for  promoting  and  facilitating  natural  capital 
assessments  among  businesses  and  financial  services 
providers. 

Natural  capital  assessments  help  private  businesses  to 
better  understand  both  the  negative  and  positive 
impacts that they have on nature, and to appreciate how 
nature contributes to their success. Such understanding 
contributes to the implementation of the EU’s BDS. 

One  Swedish  business  and  biodiversity  network  is  an 
active  member  of  the  EU  Business  &  Biodiversity 
Platform. 

(93) 

framework 

biodiversity 
(https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-
en.pdf). 
European  Commission:  Joint  Research  Centre  and  EEA,  EU 
Ecosystem 
policymakers, 
Publications Office of the European  Union, Luxembourg, 2021, 
https://op.europa.eu/en/publication-detail/-
/publication/81ff1498-b91d-11eb-8aca-
01aa75ed71a1/language-en. 

Assessment – 

Summary 

for 

(94) 

(95) 

final 

Proposal for a regulation of the European Parliament and of the 
Council  amending  Regulation  (EU)  No 691/2011  as  regards 
introducing  new  environmental  economic  accounts  modules, 
COM(2022) 329 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:329:FIN. 
The  EU  Business  &  Biodiversity  Platform  (https://green-
business.ec.europa.eu/business-and-biodiversity_en)  aims  to 
promote  the  business  case  for  biodiversity  to  businesses  and 
financial institutions through workshops, seminars, reports and 
a cross-media communication strategy. 

11 July 

2022, 

of 

2025 Environmental Implementation Review – Sweden 

 
 
 
Sweden  23 

Clean air

3. Zero pollution 

EU  clean  air  policies  and  legislation  have  successfully 
reduced  emissions  of  key  air  pollutants  and  significantly 
improved  air  quality,  which  is  now  moving  towards  the 
levels  recommended  by  the  World  Health  Organization 
(WHO).  This  has  resulted  in  clear  health  benefits  and 
reduced adverse impacts on ecosystems and biodiversity. 
However, to achieve the WHO-recommended levels, more 
efforts  are  needed,  including  full  compliance  with  EU 
legislation.  To  guide  these  efforts,  the  EU  zero  pollution 
action plan sets targets for 2030 relative to 2005. These 
are to reduce the health impacts of air pollution by 55 % 
and  to  reduce  the  EU  ecosystems  threatened  by  air 
pollution by 25 %. 

methane  volatile  organic  compounds  (NMVOC),  sulphur 
dioxide  (SO2)  and  PM2.5,  and  has  not  met  them  for 
ammonia  (NH3).  According  to  the 
latest  projections 
submitted  under  Article 10(2)  of  the  NECD,  Sweden  is 
projected to meet its emission reduction commitments for 
2030 onwards for NMVOC, SO2 and PM2.5, but not for NOx 
and NH3. 

Sweden  submitted  its  updated  national  air  pollution 
control  programme  (NAPCP)  to  the  Commission  on 
1 February 2024. 

Figure 16: Emission trends of main pollutants / GDP in 
Sweden (%), 2005–2022 

The EU has developed a comprehensive suite of air quality 
policies (96).  These  set  health-based  EU  air  quality 
standards (97)  and  stipulate  Member  States’  national 
emission  reduction  commitments (98)  for  several  air 
pollutants. 

The  air  quality  in  Sweden  is  generally  good,  with  some 
exceptions. 

The  latest  available  annual  estimates  (for  2022)  of  the 
EEA (99)  for  Sweden  attribute  480  deaths  each  year  (or 
4 500 years  of  life  lost  (YLL))  to  fine  particulate  matter 
(PM2.5) (100), 60 deaths each year (or 540 YLL) to nitrogen 
dioxide (NO2) (101) and 740 deaths each year (or 7 000 YLL) 
to ozone (102). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Sweden since 2005, while GDP growth has 
continued  (see  Figure 16).  According  to  the  inventories 
submitted  under  Article 10(2)  of  the  National  Emission 
Reduction  Commitments  Directive  (NECD) (103)  in  2024, 
Sweden has met its emission reduction commitments for 
2020–2029 for air pollutants  nitrogen oxides (NOx), non-

200%

150%

100%

50%

0%

NH₃

PM2.5

NMVOC

SO₂

NOₓ

GDP

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

(96) 

(97) 

(98) 

(99) 

European  Commission,  ‘Air’,  European  Commission  website, 
https://environment.ec.europa.eu/topics/air_en. 
European  Commission,  ‘EU  air  quality  standards’,  European 
Commission 
website, 
https://environment.ec.europa.eu/topics/air/air-quality/eu-air-
quality-standards_en. 
European  Commission,  ‘Reducing  emissions  of  air  pollutants’, 
European 
website, 
Commission 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants_en. 
EEA, Harm to human health from air pollution in Europe: Burden 
of  disease  2024,  briefing  No 21/2024,  Copenhagen,  2024, 
https://www.eea.europa.eu/en/analysis/publications/harm-to-
human-health-from-air-pollution-2024. 

(100)  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 µm  or  less.  PM2.5 

refers to particles with a diameter of 2.5 µm or less. PM is emitted 
from many human sources, including combustion. 

(101)  Nitrogen  dioxide  (NO2)  here  pertains  to  a  group  of  gases  called 
NOx, which also comprises nitrogen monoxide (NO). NOx is emitted 
during fuel combustion – for example, from industrial facilities and 
the road transport sector. 
Low-level  ozone 
is  produced  by  photochemical  action  on 
pollution.  This  year,  for  the  first  time,  the  impact  of  long-term 
exposure to ozone has also been taken into account. In previous 
analysis by the EEA, only the impact of short-term exposure was 
estimated. 

(102) 

(103)  Directive (EU) 2016/2284 of the European Parliament and of the 
Council  of  14 December  2016  on  the  reduction  of  national 
emissions of  certain atmospheric pollutants, amending Directive 
2003/35/EC  and  repealing  Directive  2001/81/EC  (OJ  L 344, 
17.12.2016, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2016.344.01.0001.01.ENG. 

p. 1), 

2025 Environmental Implementation Review – Sweden 

 
 
 
Figure 17: PM2.5 and NOx emissions by sector in Sweden 
(%), 2022 

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5

4,95%

30,08%

NOₓ

0,15%

50,52%

32,43%

3,50%

23,57%

21,57%

5,29%

3,67%

12,58%

11,67%

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

In  2023,  exceedances  above  the  limit  values  set  by  the 
Ambient Air Quality Directive (AAQD) (104) were registered 
for carbon monoxide (CO) in one air quality zone (105) and 
for PM10 in two air quality zones (106) in Sweden (107). 

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 covering all 
Member  States  concerned, 
for 
exceedances  of  PM10  limit  values (108).  The  aim  is  that 
appropriate measures will be put in place to bring all zones 
into compliance. Infringement procedures have also been 
opened  for  Member  States  not  meeting  the  emission 
reduction  commitments  for  2020–2029,  including  for 
Sweden with regard to NH3 (109). 

including  Sweden, 

(104)  Directive  2008/50/EU  of  the  European  Parliament  and  of  the 
Council of 21 May 2008 on ambient air quality and cleaner air for 
https://eur-
Europe 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0050. 

11.6.2008, 

L 152, 

p. 1), 

(OJ 

(105)  Zone SW4, Stockholm Agglomeration. 
(106)  Zone SW1, North Sweden, and Zone SW3, South Sweden. 
(107)  EEA, 

Central 

Data 

Repository 

Eionet 
(https://cdr.eionet.europa.eu/). 
INFR(2012)2216. 
INFR(2022)2080. 

(108) 
(109) 

Sweden  24 

In the 2022 EIR, Sweden received two priority actions. The 
first priority action was to further reduce emissions in the 
context of the NAPCP. Sweden has not made progress on 
this  action,  as  the  latest  reported  data  show  continued 
non-compliance  with  the  2020–2029  emission  reduction 
commitment  for  NH3  and  also  projects  non-compliance 
with 2030-onwards emission reduction commitments for 
NOx and NH3. The second priority action was to ensure full 
compliance  with  EU  air  quality  standards  and  maintain 
downward  emission  trends.  Based  on  the  latest  data, 
Sweden  has  made  some  progress  in  this  regard.  Since 
2019, downward emission trends have been reported for 
all main pollutants. However, exceedances above the limit 
values remain for CO and PM10, requiring further action. 

2025 priority actions 

•  As part of the NAPCP, take action to reduce emissions 

• 

of air pollutants. 
Ensure  full  compliance  with  the  current  AAQD 
standards, also in light of future stricter requirements 
under the revised AAQD. 

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to: 

(i)  protect  air,  water  and  soil  and  to  prevent  harmful 
effects on human health and the environment; 

(ii)  prevent and manage waste; 
(iii)  improve energy and resource efficiency; 
(iv)  clean up contaminated sites. 

The  cornerstone  of  the  policy  is the  Industrial  Emissions 
Directive  (IED),  which  was  revised  in  2024 (110).  The 
revision improves the directive’s contribution to the zero 
pollution  objective.  It  has  a  strong  focus  on  innovation, 
and 
depollution, 
decarbonisation and circularity, making it a key regulatory 
tool  to  accompany  the  green  transformation  of  EU 
industry by 2050. 

between 

builds 

solid 

links 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 (111). 

(110)  Directive  2010/75/EU  of  the  European  Parliament  and  of  the 
Council of 24 November 2010 on industrial emissions and livestock 
rearing  (integrated  pollution  prevention  and  control)  (OJ  L  334, 
17.12.2010, p. 17), as amended by Directive (EU) 2024/1785 of the 
European  Parliament  and  of  the  Council  of  24 April  2024, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02010L0075-
20240804&qid=1725983863299. 
European 

Portal, 
Industrial 
https://industry.eea.europa.eu/, 2022 being the baseline year for 
all reports. 

(111)  EEA, 

Emissions 

2025 Environmental Implementation Review – Sweden 

 
 
 
In  Sweden,  around  1 300  industrial  installations  were 
required to have a permit based on the IED in 2022. 

Figure 19: Industrial releases of pollutants to water and 
industrial activity in the EU-27 

Sweden  25 

The  industrial  sectors  in  Sweden  with  the  most  IED 
installations in 2022 were the waste management sector 
(29 %), followed by intensive rearing of poultry and pigs 
(25 %) and the mineral and energy sectors, with 11 % and 
9 %, respectively. 

Figure 18  shows  the  damage  to  human  health  and  the 
environment due to the main industrial air pollutants. As 
this  depends  on,  among  other  factors,  the  size  of  the 
industrial  sector  in  each  Member  State,  the  figure  also 
shows  the  ratio  between  the  damage  and  the  industrial 
activity  (expressed  in  gross  value  added  (GVA)),  which 
gives an indication of the emissions  ‘intensity’. Although 
Sweden has the 16th highest damage in the EU, it comes 
24th  for  emissions  intensity,  below  the  EU  average  of 
EUR 27.5/EUR 1 000  GVA. 
industrial 
contributors to emissions to air (112) are the energy sector, 
the  mineral 
industry  for  NOX  emissions,  the  waste 
management  and  chemical  industry  for  dust  emissions, 
the  energy  sector,  and  the  metals  sector  and  mineral 
sector for SO2 and heavy metals. 

The  main 

Figure 18: Industrial air pollution damage and intensity, 
per Member State, 2021

NB: Cd, cadmium; Hg, mercury; Ni, nickel; Pb, lead; total N, total nitrogen; 
total P, total phosphorous. 

Source:  EEA,  ‘Industrial  pollutant  releases to  water  in Europe’,  30 May 
2024, 
https://www.eea.europa.eu/en/analysis/indicators/industrial-
pollutant-releases-to-water. 

Concerning  Sweden  in  particular,  Figure 20  shows  the 
industrial emissions of heavy metals to water, taking into 
account the human toxicity of each metal, as well as  the 
emissions  intensity,  based  on  its  ratio  to  the  industrial 
activity  (expressed  in  GVA).  Sweden  has  the  7th  highest 
amount of emissions of heavy metals to water and is in 5th 
position  for  emission  intensity  (above  the  EU  average 
intensity of 0.864 kg/EUR 1 billion GVA). 

Figure 20: Industrial releases and intensity of heavy 
metals to water per Member State, 2022 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
air  pollution  damage  costs  intensity’,  European  Industrial  Emissions 
Portal, 
https://industry.eea.europa.eu/analyse/industrial-
emissions-indicator. 

2024, 

Overall, the industrial emissions to water in the EU have 
decreased  over  time  for  all  the  main  pollutants.  On 
average in the EU, they appear to be decoupled from the 
industrial  activity,  which  has  increased  over  the  same 
period (expressed in GVA), as shown in Figure 19. 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
water  pollution  intensity’,  European  Industrial  Emissions  Portal,  2024, 
https://industry.eea.europa.eu/analyse/industrial-emissions-indicator. 

As shown in Figure 21, the main industrial contributors to 
emissions  to  water  in  Sweden  are  the  pulp  and  paper 
industry for all pollutants, and the metal production and 
processing sector for heavy metals and nitrogen. 

(112)  European  Environment  Agency,  LRTAP,  Air  pollutant  emissions 
data viewer (Gothenburg Protocol, LRTAP Convention) 1990-2022, 

https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/air-pollutant-emissions-data-viewer-1990-2022. 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
Figure 21: Relative releases to water from industry in 
Sweden (%), 2022 

slaughterhouses,  animal  by-products  and/or  edible  co-
products industries; and (v) smitheries and foundries. 

Sweden  26 

100%

75%

50%

25%

0%

Heavy Metals
Ecotoxicity

Heavy Metals
Human Toxicity

Total nitrogen

Total organic
carbon (TOC)

Total phosphorus

Chemicals
Extractive industry
Food and drink
Livestock
Other manufacturing
Pulp, paper and wood

Electricity and heat production
Ferrous metal
Landfill
Non-ferrous metal
Other waste management
Refineries

Source: EEA, ‘Industrial reporting under the Industrial Emissions Directive 
2010/75/EU  and  European  Pollutant  Release  and  Transfer  Register 
Regulation (EC) No 166/2006 – ver. 12.0 Sep. 2024 (tabular data)’, EEA 
Geospatial 
2024, 
Catalogue, 
https://sdi.eea.europa.eu/catalogue/srv/api/records/cf5e54c1-be99-
4426-bcad-baa26c4f27a0?language=all. 

13 September 

Data 

IED  provisions  on  public  information  and  participation 
require Member States to adopt transposition legislation 
enabling members of the public to have access to relevant 
information  and  participate  in  the  approval  process  for 
potentially  polluting  installations.  Thus,  the  public  and 
non-governmental  organisations 
(NGOs),  alongside 
competent authorities, play a role in ensuring compliance 
of  these  permits  with  EU  legislation.  The  IED  contains 
mandatory  requirements  on  environmental  inspections, 
requiring a site visit to take place at least every 1–3 years, 
using  risk-based  criteria.  In  addition,  IED  enforcement 
provisions require Member States to determine effective, 
proportionate,  and  dissuasive  penalties  applicable  to 
infringements  of  IED-based  national  provisions.  In  the 
that  worst 
the  provisions 
revised  directive, 
infringements can be sanctioned by fines of at least 3% of 
the  annual  EU  turnover  of  the  legal  person.  The  revised 
IED will also introduce a right to compensation for people 
whose health has been harmed by such infringements. 

set 

The development of best available techniques (BATs), BAT 
reference  documents  and  BAT  conclusions  ensures 
effective collaboration between stakeholders and enables 
better implementation of the IED. 

Since  the  2022  EIR,  the  Commission  has  adopted  BAT 
conclusions  on  (i)  ferrous  metal  processing;  (ii)  textiles 
industry;  (iii)  common  waste  gas  management  and 
(iv) 
treatment 

the  chemical 

systems 

sector; 

in 

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

2025 priority actions 

•  Reduce industrial air pollution damage and intensity. 
•  Reduce 
industrial  releases  to  water  and  their 

• 

• 

intensity. 
Engage  with  industry  and  environmental  NGOs  to 
ensure proper contribution to and implementation of 
BAT conclusions and ensure timely updates to permits 
following the publication of BAT conclusions. 
Ensure  effective  public  participation  and  access  to 
justice in relation to the IED. 

Major industrial accidents prevention – Seveso 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 

(i)  control  major-accident  hazards  involving  dangerous 

(ii) 

substances, especially chemicals; 
limit the consequences of such accidents for human 
health and the environment; 

(iii)  continuously 

improve 

the 

prevention 

of, 

preparedness for and response to major accidents. 

The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive) (113). 

The overview below of industrial plants regulated by the 
Seveso III Directive (‘Seveso establishments’) is based on 
data  reported  on  eSPIRS  (e-Seveso  Plants  Information 
Retrieval  System)  for  2022–2024 (114)  and  the  report  by 
Sweden on the implementation of the Seveso III Directive 
for 2019–2022 (115). 

in  Sweden,  out  of  the  387  Seveso 
As  of  2024, 
establishments,  185  are  categorised  as 
lower-tier 
establishments  and  202  as  upper-tier  establishments 
(UTEs),  based  on  the  quantity  of  hazardous  substances 
likely  to  be  present.  UTEs  are  subject  to  more  stringent 
requirements.  The  change  in  the  number  of  Seveso 
establishments is presented in Figure 22. 

(113)  Directive  2012/18/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  the  control  of  major-accident  hazards 
involving  dangerous  substances,  amending  and  subsequently 
repealing  Council  Directive  96/82/EC  (OJ  L 197,  24.7.2012,  p. 1), 
https://eur-lex.europa.eu/eli/dir/2012/18/oj. 

(114)  https://espirs.jrc.ec.europa.eu/en/espirs/content; data extracted 

in September 2024. 

(115)  As provided for by Article 21(2) of the Seveso III Directive. 

2025 Environmental Implementation Review – Sweden 

 
 
 
Figure 22: Number of Seveso establishments in Sweden, 
2018, 2022 and 2024  

NB: LTE, lower-tier establishment. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

Member  States  are  required  to  draw  up  external 
emergency plans (EEPs) for certain UTEs. These EEPs are 
essential  to  allow  proper  preparation  and  effective 
implementation  of  the  necessary  actions  to  protect  the 
environment and the population should a major industrial 
accident occur. According to Sweden, in 2022, an EEP was 
required for all 201 UTEs; 193 UTEs had an EEP and 126 of 
these EEPs had been tested over the last three years. The 
summary is shown in Figure 23. 

Figure 23: Situation regarding EEPs in Sweden, 2022 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
2014/896/EU 
Implementing  Decision 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
https://op.europa.eu/en/publication-detail/-
Luxembourg, 

2022, 

Sweden  27 

/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

The information  for the public referred to in  Annex V to 
the  Seveso III  Directive –  especially  regarding  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 –  is 
permanently  available  for  all  Seveso  establishments  in 
Sweden. 

The  shares  of  UTEs  for  which  information  on  safety 
measures and requisite behaviours was made available to 
the public in recent  years  is  presented in Figure 24. This 
provision on knowledge is an important  provision of the 
Seveso III Directive, as public awareness may mitigate the 
consequences of a major industrial accident. 

Figure 24: Share of UTEs for which information on safety 
measures and requisite behaviours were actively made 
available to the public in per Member State (%), 2022 

NB: No data available for Greece. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
involving 
2012/18/EU  on  the  control  of  major  accident  hazards 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

In  2022,  Sweden  received  priority  actions  to  strengthen 
control  and  enforcement  to  ensure  compliance  with 
Seveso-III  Directive  provisions,  especially  on  EEP.  Data 
reported  on  implementation  of  the  directive  for  2019–
2022 for Sweden shows that improvement is still needed 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
 
Sweden  28 

to  establish  EEPs  for  all  UTEs,  and  to  test  them  at  least 
every three years. 

2025 priority action 

• 

Strengthen  compliance  with  requirements  on  safety 
measures  to  prevent  major  accidents  and  ensure 
appropriate preparedness and response in relation to 
UTEs, in particular  as regards reviewing, testing and 
updating  EEPs,  at  intervals  of  no  more  than  three 
years. 

Mercury Regulation 

The  Mercury  Regulation  establishes  measures  and 
conditions concerning the use and storage of and trade in 
mercury,  mercury  compounds  and  mixtures  of  mercury, 
the manufacture and use of and trade in mercury-added 
products and the management of mercury waste, in order 
to ensure a high level of protection of human health and 
the  environment  from  anthropogenic  emissions  and 
releases of mercury and mercury compounds. The revision 
of the Mercury Regulation adopted in 2024 sets out rules 
to address the last intentional uses of mercury in the EU 
by  phasing  out  the  use  of  dental  amalgam  by  1 January 
2025 except when deemed strictly necessary by the dental 
practitioner  based  on  the  specific  medical  needs  of  the 
patient,  and  prohibiting  the  manufacture  and  export  of 
additional mercury-containing lamps from 1 January 2026 
or 1 January 2027 (depending on the lamp category). 

Sweden  already  completely  phased  out  dental  amalgam 
more than a decade ago. Sweden will also need to ensure 
that  the  manufacture  and  export  of  mercury-containing 
lamps  are  prohibited  by  the  deadlines  required  by  the 
Mercury Regulation. 

Noise 

The  Environmental  Noise  Directive (116)  requires  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  noise.  The  designated  authorities  are 
responsible  for  making  and  approving  noise  maps  and 
action  plans  for  agglomerations,  major  roads,  major 

railways  and  major  airports.  Member  States  decide  on 
noise limits that are not set at the EU level. Nevertheless, 
the zero pollution action plan sets as a 2030 target a 30 % 
reduction  compared  with  2017  in  the  share  of  people 
chronically disturbed by transport noise. 

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental health‐related issues in 
the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress (117). 

In Sweden, environmental noise is estimated to cause at 
ischaemic  heart  disease 
least  around  580  cases  of 
annually (118)  and  some  132 000  people  to  suffer  from 
disturbed sleep(119). 

Based on the latest set of information analysed, Sweden 
has  completed  its  noise  mapping  of  agglomerations, 
roads, railways and airports. 

Action  plans  for  noise  management  for  agglomerations, 
roads,  railways  and  airports  must  be  updated  and 
submitted  to  the  Commission  every  five  years.  The 
deadline for reporting noise action plans under the most 
recent  reporting  cycle  was  18 January  2025;  these  plans 
have not been assessed yet. 

2025 priority action 

•  Complete  and  implement  action  plans  on  noise 

management. 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures on transitional waters, coastal waters and fresh 
water  (including  surface  waters  and  groundwater)  be 
significantly reduced. Achieving, maintaining or enhancing 
a  good  status  of  waterbodies  as  defined  by  the  Water 
Framework Directive will ensure that EU citizens and the 
environment 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. 

(116)  Directive  2002/49/EC  of  the  European  Parliament  and  of  the 
Council  of  25 June  2002  relating  to  the  assessment  and 
management  of  environmental  noise –  Declaration  by  the 
Commission  in  the  Conciliation  Committee  on  the  directive 
relating  to  the  assessment  and  management  of  environmental 
noise (OJ L 189, 18.7.2002, p. 12), https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32002L0049. 

(117)  WHO,  Environmental  Noise  Guidelines  for  the  European  Region, 
Copenhagen, 
2018, 
https://www.who.int/europe/publications/i/item/978928905356
3. 

(118)  These figures are an estimation by the EEA based on (i) the data 
reported  by  Member  States  on  noise  exposure  covered  by 
Directive 2002/49/EC for the round of noise mapping of 2022; (ii) 

European  Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Industrial Pollution (ETC/ATNI), 2021, Noise Indicators under the 
Environmental Noise Directive 2021: Methodology for estimating 
missing  data,  Eionet  report  ETC/ATNI  No 2021/06,  Kjeller,  2021; 
and  (iii)  the  methodology  for  health  impact  calculations  in 
European  Topic  Centre  on  Air  Pollution  and  Climate  Change 
Mitigation  (ETC/ACM),  Implications  of  environmental  noise  on 
in  Europe,  Eionet  report  ETC/ACM 
health  and  wellbeing 
No 2018/10, 
2018, 
https://www.eionet.europa.eu/etcs/etc-atni/products/etc-atni-
reports/eionet_rep_etcacm_2018_10_healthimplicationsnoise. 

Bilthoven, 

(119)  More information on the adverse health effects of noise pollution 

is available at: 
https://www.eea.europa.eu/themes/human/noise/noise-2 

2025 Environmental Implementation Review – Sweden 

 
 
  
Water Framework Directive 

The Water Framework Directive (120) is the cornerstone of 
EU water policy (121). The Water Framework Directive and 
other  water-related  directives (122)  form  the  basis  of 
sustainable and integrated water management in the EU. 
They  aim  to  achieve  a  high  level  of  protection  of  water 
resources,  prevention  of  further  deterioration,  and 
restoration  to  good  status.  These  objectives  are  very 
important 
the  EU’s  competitiveness,  strategic 
autonomy  and  security,  yet  have  become  even  more 
challenging  in  the  face  of  climate  change  affecting  our 
precious water resources. 

for 

The Water Framework Directive establishes a procedural 
framework  for  reaching  good  ecological  and  chemical 
status  of  surface  water  and  good  quantitative  and 
chemical  status  of  groundwater.  This  implies  monitoring 
and  classification  of  all  waterbodies,  assessment  of 
pressures and impacts, and identification of the most cost-
effective  measures  to  achieve  the  objectives  of  the 
directive. The directive dates from 2000 and set an initial 
deadline  of  2015  for  achieving  its  objectives,  with  the 
option to extend the deadline to the end of 2027. Every six 
years,  Member  States  must  report  their  river  basin 
management  plans  (RBMPs)  to  the  Commission.  They 
should cover river basin districts, some of which may be 
shared with other countries. The Commission has assessed 
the third cycle of RBMPs, which were to be submitted by 
March  2022,  and  reported  its  findings  to  the  European 
Parliament and to the Council on 4th February 2025 (123). 

Sweden  has  23 813  surface  waterbodies  and  3 704 
groundwater bodies, divided over five river basin districts 
(the North Baltic, the South Baltic, the Bothnian Bay, the 
Bothnian Sea, and Skagerrak and Kattegat). Approximately 
3 % of surface waters are designated as ‘heavily modified’ 
and  about  0.2 %  as  ‘artificial’.  Heavily  modified  and 
reach  good  ecological 
artificial  waterbodies  must 
potential rather than good ecological status, which means 
that all measures must be taken to mitigate the adverse 
impact  of  the  sustainable  human  development  activities 
causing the waterbody to be heavily modified / artificial, 
while not significantly affecting these activities. 

(120)  https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=CELEX:32000L0060. 

(121)  https://environment.ec.europa.eu/topics/water_en. 
(122)  These 

the  Groundwater  Directive 

include 

(https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32006L0118), 
the  Environmental  Quality  Standards  Directive  (https://eur-
lex.europa.eu/eli/dir/2008/105/oj), 
Directive 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32007L0060), the Bathing Water 
(https://eur-lex.europa.eu/legal-
Directive 
Urban 
content/EN/TXT/?uri=celex%3A32006L0007), 
Wastewater 
(https://eur-
Directive 
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31991L0271), 
(https://eur-
the 

Drinking  Water 

Treatment 

Directive 

Floods 

New 

the 

the 

Sweden  29 

It  follows  from  the  assessment  of  the  third  RBMPs  that 
there  has  been  a  minor  improvement  in  the  ecological 
status/potential  of 
surface  waterbodies,  and  no 
improvement in their chemical status, as compared  with 
the status reported in the second RBMPs (covering 2015–
2021).  There  has  been  a  slight  deterioration  in  the 
quantitative  status  and  chemical  status  of  groundwater 
bodies. 

The following figures show the evolution of the ecological 
status/potential  and  the  chemical  status  of  surface 
waters,  and  of  the  quantitative  and  chemical  status  of 
groundwater in 2010, 2015 and 2021. 

Figure 25:  Ecological 
waterbodies in each RBMP cycle 

status/potential  of 

surface 

About 41 % of surface waterbodies are in good or better 
ecological  status/potential,  showing  some  improvement 
compared  with  the  second  RBMPs.  However,  the 
monitoring extent has reduced: now only 21 % of surface 
waterbodies  are  monitored 
to  assess  ecological 
status/potential. 

According  to  the  Swedish  Agency  for  Marine  and  Water 
Management, hydropower is the most extensive pressure 
on  lake  and  river  waterbodies  in  Sweden (124).  Almost 
4 000  river  waterbodies  and  1 000  lake  waterbodies  are 
affected by water regulation or lack of connectivity. 

lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32020L2184), 
Directive 
content/EN/ALL/?uri=celex%3A31991L0676), 
(https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32008L0056) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075). 

the 

Nitrates 
(https://eur-lex.europa.eu/legal-
MSFD 

the 

and 

the 

IED 

(123)   ENV - Bibliothèque 
(124)  Swedish  Agency  for  Marine  and  Water  Management,  ‘Towards 
sustainable hydropower in Sweden’, Swedish Agency for Marine 
and  Water  Management  website,  27 November  2019, 
https://www.havochvatten.se/en/eu-and-international/towards-
sustainable-hydropower-in-sweden.html. 

2025 Environmental Implementation Review – Sweden 

 
 
 
While  Sweden  has  introduced  a  national  assessment 
plan (125) to review the permits of hydropower plants that 
have  a  significant  effect  on  waterbodies,  the  review 
process  is  expected  to  take  until  the  early  2040s,  which 
means  that  Sweden  does  not  expect  improvements  in 
hydromorphological conditions to be achieved by 2027. 

Coastal  waterbodies  are  also  under  pressure,  with  79 % 
below a good ecological status. Furthermore, only 2 % of 
highly  modified  and  artificial  surface  waterbodies  have 
good  ecological  potential.  By  2027,  less  than  50 %  of 
surface  waterbodies  are  expected  to  reach  good 
ecological status/potential. 

Figure 26: Chemical status of surface waterbodies in each 
RBMP cycle (%) 

In  total,  9 %  of  surface  waterbodies  are  monitored  for 
chemical  status,  covering  all  three  matrices:  water, 
sediments  and  biota.  Nevertheless,  all  45  priority 
substances  are  monitored  with  a  network  set  at  a  risk-
based approach. 

A total of  100 % of surface waterbodies are expected to 
fail to achieve a good chemical status in 2027, which has 
been the case since the first RBMPs. 

Failure to achieve good chemical status is mostly due to 
toxic 
ubiquitous  persistent  bioaccumulative 
substances  (uPBTs),  which  are  difficult  to  address  and 
often  have  transboundary  sources.  In  Sweden,  these 
uPBTs  are  mainly  mercury  and  polybrominated  diphenyl 
ether. 

and 

Sweden  30 

Figure 27: Quantitative status of groundwater bodies in 
each RBMP cycle (%) 

The percentage of groundwater bodies not achieving good 
quantitative status has increased to 0.8 % since the second 
RBMPs.  However,  the  total  number  of  groundwater 
bodies has increased by 12 % due to re-delineation. 

3.1 %  of  groundwater  bodies  are  at  risk  of  failing  to 
achieve a good quantitative status by 2027. 

Figure 28: Chemical status of groundwater bodies in each 
RBMP cycle (%) 

97.6 %  of  groundwater  bodies  in  Sweden  have  a  good 
chemical  status,  showing  a  slight  deterioration  from  the 
second RBMPs. 4 % of groundwater bodies are at risk of 
failing to maintain good chemical status by 2027. 

Until the end of 2027, Member States can still apply for 
time-related exemptions, subject to providing evidence of 
compliance  with  the  strict  criteria  set  out  in  the  Water 
Framework  Directive.  After  2027,  the  possibilities  for 
applying for exemptions will be much more limited. 

In the 2022 EIR, it was recommended that Sweden assess 
new  physical  modifications  of  waterbodies  in  line  with 
Article 4(7) of the Water Framework Directive, considering 
alternative  options  and  adequate  mitigation  measures. 
Some progress has been made  in following up with  that 
priority action. 

(125)  Swedish  Energy  Agency,  ‘Nationell  plan  för  omprövning  av 
vattenkraft’,  Swedish  Energy  Agency  website,  12 January  2024, 
https://www.energimyndigheten.se/energisystem-och-

analys/elproduktion/vattenkraft/nationell-plan-for-moderna-
miljovillkor/#:~:text=Den%201%20oktober%202019%20lämnade,
beräknas%20ta%20ca%2020%20år. 

2025 Environmental Implementation Review – Sweden 

0 20 40 60  0 100 1st2nd3rdS B chemical status for SEGood ailing to achieve goodUnknown 
 
 
 
 
to 

subject 

A  positive  point  is  that,  to  tackle  pollution  from  non-
agricultural,  diffuse  pollution  from  both  nutrients  and 
other  chemicals,  Sweden  introduced  several  concrete 
measures,  implemented  at  the  waterbody  level  and 
specified by the relevant authority. For example, discharge 
permits  are 
review  and  appropriate 
requirements  are  added  to  comply  with  the  stricter 
objectives.  For  nutrients,  Sweden  has  set  reduction 
targets  covering  nitrogen  and  phosphorus  for  various 
sectors  at  a  waterbody  level.  To  support  measures  to 
tackle agricultural pollution, the Swedish CAP SP for 2023–
2027  envisaged  EUR 1.3 billion  of  funding  to  support 
including  the 
environmental  and  climate  objectives, 
implementation of environment-friendly practices as well 
as raising awareness among farmers on these issues. The 
agriculture sector finances 30 % of the cost  of measures 
and  the  rest  is  funded  by  the  CAP  and/or  other  public 
support. 

2025 priority actions 

Without prejudice to the list of recommended actions in 
the Commission report to the European Parliament and to 
the  Council  on  the  assessment  of  the  third  RBMPs,  the 
following priority actions can be highlighted. 

• 

• 

flows, 
Improve  river  continuity  and  ecological 
boosting efforts on nature-based solutions to reduce 
hydromorphological pressures 
Ensure  periodic  reviews  of  permits  for  discharges, 
including 
abstractions  and  other  water  uses, 
hydropower pressures. 

•  Reduce  pollution  from  nutrients,  chemicals,  metals 

• 

and saline discharges. 
Improve  the  classification  of  water  bodies  and 
strengthen monitoring systems. 

•  Develop  more  robust  programmes  of  measures, 
tackle  obstacles  identified  in  the  implementation  of 
for 
measures  and  ensure  adequate 
implementation, including through better use of the 
cost recovery and polluter pays principle. 

financing 

Floods Directive 

Every six years, following the same reporting cycle as the 
RBMPs,  all  Member  States  also  report  their  flood  risk 
management  plans  (FRMPs),  based  on  the  flood  hazard 

(126)  https://environment.ec.europa.eu/publications/implementing-

decision-drinking-water-directive-watch-list_en. 

(127)  Commission Delegated Decision (EU) 2024/1441 of 11 March 2024 
supplementing  Directive  (EU)  2020/2184  of  the  European 
Parliament and of the Council by laying down a methodology to 
measure microplastics in water intended for human consumption 
(notified  under  document  C(2024) 1459)  (OJ  L,  2024/1441, 
21.5.2024), http://data.europa.eu/eli/dec_del/2024/1441/oj. 
2024/365, 

23.4.2024, 
http://data.europa.eu/eli/dec_impl/2024/365/oj; OJ L, 2024/367, 
http://data.europa.eu/eli/dec_impl/2024/367/oj; 
23.4.2024, 

(128)  OJ L, 

Sweden  31 

and  risk  maps  (FHRMs)  and  the  preliminary  flood  risk 
assessments  drawn  up  during  the  second  cycle  (2016–
2021). 

The  Commission  assessed  the  FRMPs  and  reported  its 
findings to the European Parliament and to the Council on 
4th  February  2025,  together  with  the  assessment  of  the 
RBMPs. 

information  on  the 

Three of the five Swedish FRMPs provide an overview of 
the achievements of the objectives in the respective first 
plans.  The  second  FRMPs  provide  more  specific  and 
measurable 
implementation  of 
measures,  including  some  information  on  the  costs  and 
the  progress  made.  Three  FRMPs  refer  to  nature-based 
solutions,  and  four  discuss  cultural  heritage.  Moreover, 
four FRMPs mention damage costs and insurance-related 
issues,  which  was  not  assessed  in  the  first  FRMPs.  Two 
FRMPs refer to cost–benefit analysis in detail, while only 
one of the first FRMPs (briefly) did so. All FRMPs refer to 
coordination  with 
for  climate 
adaptation. 

strategies 

regional 

2025 priority actions 

• 

FRMPs  should  provide  details  on  how  the  FHRMs 
were  used  in  the  choice  of  measures  and  how  to 
consider pluvial flooding. 

•  Better explain the choice and implementation of flood 
prevention  and  protection  measures  (prioritisation, 
monitoring, costs of measures). 
Improve  public 
involvement. 

consultation  and 

stakeholder 

• 

Drinking Water Directive 

The recast Drinking Water Directive is now applicable, and 
Member States were required to transpose its provisions 
into their national legal systems by 12 January 2023. Since 
into  force  of  the  recast  directive,  the 
the  entry 
several  delegated  and 
Commission  has  adopted 
implementing  acts  establishing  (i)  a  watch 
list  of 
substances  and  compounds  of  concern  for  drinking 
water (126), (ii) a methodology for measuring microplastics 
in drinking water (127) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (128). Member States will have to take 

2024/369, 

OJ L, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/369/oj;  OJ L,  2024/368, 
23.4.2024, http://data.europa.eu/eli/dec_impl/2024/368/oj; OJ L, 
2024/370, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/370/oj;  OJ L,  2024/371, 
23.4.2024,  http://data.europa.eu/eli/reg_del/2024/371/oj;  see 
the  Commission  web  page  on  all  six  delegated  acts  for  more 
information 
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en). 

2025 Environmental Implementation Review – Sweden 

 
 
these  various  Commission  acts 
implementing the recast directive. 

into  account  when 

Nitrates Directive 

Sweden  32 

Finally,  the  Commission  has  now  received  data  from 
Member States on the quality of drinking water in 2017–
2019.  The  quality  of  drinking  water  (supplied  by  large 
water  suppliers) 
in  Sweden  does  not  give  rise  to 
concern (129). 

Sweden, however, is subject to an infringement procedure 
for  failing  to  communicate  its  national  laws  transposing 
the recast Drinking Water Directive (130). 

From  January  2026,  the  European  quality  standards  for 
per-  and  polyfluoroalkyl  substances  (PFAS)  in  drinking 
water  will  apply,  ensuring  harmonised  Member  States’ 
reporting of PFAS monitoring data in the future. 

2025 priority action 

• 

Take  actions  to  ensure  full  compliance  with  the 
Drinking Water Directive. 

Bathing Water Directive 

The  Bathing  Water  Directive  requires  Member  States  to 
monitor and assess bathing water. It requires that, during 
the bathing season, Member States actively and promptly 
disseminate information on bathing water quality to the 
public.  In  particular,  notices  banning  or  advising  against 
bathing should be rapidly and easily identifiable. 

It  should  be  highlighted  that  in  2023,  out  of  the  468 
Swedish bathing waters, 72.9 % were of excellent quality, 
12 %  were  of  good  quality  and  4.5 %  were  of  sufficient 
quality. 5.1 % were found to be of poor quality and 5.6 % 
were not classified. 

Figure 29: Bathing water quality per Member State, 
Albania and Switzerland (%), 2023 season 

The  Nitrates  Directive (131)  aims  to  protect  water  quality 
across  Europe  by  preventing  nitrates  from  agricultural 
sources that can pollute groundwater and surface waters 
and by promoting the use of good farming practices. The 
latest  Commission  report  on  the  implementation  of  the 
Nitrates  Directive (132),  dating  back  to  2021,  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. Cleaning of waters by national authorities 
or  farmers,  where  it  has  been  undertaken,  has  had  a 
positive  impact  on  the  drinking  water  supply  and  on 
biodiversity.  It  has  also  benefited  the  sectors –  such  as 
fisheries and tourism – that depend on biodiversity and on 
a good supply of drinking water. Nevertheless, excessive 
fertilisation remains a  problem in  many parts of the EU. 
The  report  on  the 
implementation  of  the  Nitrates 
Directive covering 2020–2023 will be available in 2025. 

The analysis of Sweden’s RBMPs has identified nutrients 
from  agriculture  as  an 
important  pressure  on 
groundwater / surface water that is affecting water status 
and as one of the main factors for Sweden not meeting the 
Water Framework Directive objectives. 

2025 priority action 

• 

Tackle  nutrient  pollution,  especially  nitrates  from 
implementation  of  the 
agriculture,  through  the 
Nitrates Directive. 

Urban Wastewater Treatment Directive 

The  Urban  Wastewater  Treatment  Directive  (UWWTD) 
aims to protect human health and the environment from 
the  effects  of  untreated  urban  wastewater.  It  therefore 
requires Member States to collect and treat (secondary or 
biological  treatment)  waste  water  in  all  urban  areas  of 
more  than  2 000  people,  and  to  apply  a  more  stringent 
treatment 
than  secondary,  with  nitrogen  and/or 
phosphorus  removal,  to  the  waste  waters  generated  in 
urban areas, also known as agglomerations, of more than 
10 000 people, before they are discharged into waters and 
their  catchments,  when  they  are  sensitive  to  nitrogen 
and/or phosphorus (i.e. eutrophic or tending to become 
eutrophic). 

Source:  EEA,  European  Bathing  Water  Quality 
No 04/2024, 
https://www.eea.europa.eu/publications/european-bathing-water-
quality-in-2023/. 

in  2023,  briefing 
2024, 

Copenhagen, 

(129) 

In summary, the compliance for all parameter groups in Sweden 
was at least 99.56 % in 2017, 99.37 % in 2018 and 99.41 % in 2019. 
(130)  https://eur-lex.europa.eu/eli/dir/2020/2184/oj; INFR(2023)0098. 

(131)  https://eur-lex.europa.eu/legal-

content/EN/TXT/?qid=1561542776070&uri=CELEX:01991L0676-
20081211. 

(132)  https://environment.ec.europa.eu/topics/water/nitrates_en. 

2025 Environmental Implementation Review – Sweden 

 
 
Figure 30:  Proportion  of  urban  wastewater  that  fully 
complies with the UWWTD (%), 2020 

Chemicals 

Sweden  33 

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 strategy for 
sustainability  towards  a  toxic-free  environment (134), 
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. 

The  EU’s  chemicals  legislation (135)  provides  a  baseline 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating in the internal market. 

Source:  12th  technical  assessment  of  UWWTD 
Publications Office of the EU 

implementation  - 

The  revised  directive  (133)  builds  on  the  current  acquis, 
strengthens existing treatment standards and establishes 
a  new  additional  treatment  of  micropollutants  in  urban 
wastewater.  Other  new  requirements  relate  to  moving 
towards  the  energy neutrality of the sector, establishing 
an  extended  producer  responsibility  system  to  ensure 
sustainable financing of micropollutant treatment by the 
industries,  and  ensuring  access  to 
most  polluting 
sanitation,  especially  for  vulnerable  and  marginalised 
groups.  Sweden  has  until  31 July  2027  to  transpose  the 
new directive into its national legal system. 

2025 priority actions 

• 

the  necessary  measures 

Take 
full 
implementation  of  the  current  urban  wastewater 
treatment  directive,  taking  into  account  the  new 
requirements of the recast directive. 

to  ensure 

(133)   Directive (EU) 2024/3019 of the European Parliament and of the 
Council  of  27  November  2024  concerning  urban  wastewater 
treatment (recast). 

(134)  Communication 

to 

from 

the  Commission 

the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Chemicals 
strategy  for  sustainability:  Towards  a  toxic-free  environment, 
COM(2020) 667 
final  of  14 October  2020,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A667%3AFIN;  Regulation 
(EC) No 1272/2008 of the European Parliament and of the Council 
of 16 December 2008 on classification, labelling and packaging of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
p. 1), 
L 353, 
https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2. 

31.12.2008, 

(OJ 

(135)  Namely,  Regulation 

(EC)  No 1907/2006  of  the  European 
Parliament  and  of  the  Council  of  18 December  2006  concerning 
the  registration,  evaluation,  authorisation  and  restriction  of 
chemicals  (REACH),  establishing  a  European  Chemicals  Agency, 
amending Directive 1999/45/EC and repealing Council Regulation 
(EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as 
well as Council Directive 76/769/EEC and Commission Directives 

and 

enforcement 

Since 2007, the Commission has gathered information on 
the  enforcement  of 
the  Registration,  Evaluation, 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 
assessed  the  Member  States’  reports (136)  on  the 
implementation 
these 
regulations (137).  It  is  apparent  from  the  Commission’s 
in  the 
report  that  there  are  still  many  disparities 
implementation  of  the  REACH  and  CLP  Regulations, 
notably 
law  enforcement.  Recorded 
compliance levels in Member States, generally quite stable 
over time, appear to be getting slightly worse. This may be 
because  (i)  enforcement  authorities  are  becoming  more 
effective in detecting non-compliant products/companies; 
and (ii) more non-compliant products are being placed on 
the EU market. 

in  the  area  of 

of 

In August 2021, the Commission published a measurable 
assessment  of the enforcement (138) of the two  main EU 

p. 1), 

91/155/EEC,  93/67/EEC,  93/105/EC  and  2000/21/EC  (OJ  L 396, 
30/12/2006, 
https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32006R1907; and Regulation (EC) 
No 1272/2008 of the European Parliament and of the Council of 
16  December  2008  on  classification,  labelling  and  packaging  of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC)  No 
1907/2006 
(OJ  L  353,  31.12.2008,  p.  1),  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 
(136)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
2020, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 
In 
Article 46(2) of the CLP Regulation. 

line  with  Article 117(1)  of  the  REACH  Regulation  and 

Luxembourg, 

Union, 

(137) 

(138)  European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  REACH  and  CLP 
Enforcement: EU-level enforcement indicators, Publications Office 
2021, 
Union, 
of 

Luxembourg, 

European 

the 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
regulations  on  chemicals  using  a  set  of  indicators  on 
different  aspects  of  enforcement.  Since  2021,  the  list  of 
chemicals  subject  to  restrictions  has  been  expanded  as 
new entries have been added to Annex XVII to the REACH 
Regulation(139). 

in 
The  Member  States’  reporting  exercise  set  out 
Article 117 of the REACH Regulation and Article 46 of the 
CLP Regulation is conducted every five years. The results 
of the coming one are expected in 2025, hence the lack of 
new country-specific data on enforcement since 2022. 

Sweden  34 

In  2020,  Sweden  participated  in  an  EU  coordinated 
enforcement  project  on  products  sold  online,  called  the 
REACH-EN-FORCE  (REF)-8  project (145).  The  report  was 
adopted in November 2021, so it could not be taken into 
account in the previous EIR. 

Figure 31: Compliances of imported products – results of 
the REF-8 project (%) 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (140).  The  new  hazard 
classes  cover  endocrine  disruptors  and  persistence-
related  hazards  while  the  revision  of  the  regulation 
encompasses  new  rules  on  online  sales  to  better  tackle 
non-compliances  observed  over  the  years.  Also  in  2023, 
the  Conference  of  the  Parties  of  the  Stockholm 
Convention (COP) decided to include, in its Annex A (which 
lists  banned  substances),  three  new  chemicals (141).  The 
Commission  is  working  on  the  delegated  acts  to  include 
these  substances  in  Annex I  to  the  Persistent  Organic 
Pollutants Regulation by 2025 at the latest. 

Responsibility  for  checking  compliance  with  the  REACH 
Regulation 
following 
in 
authorities (142): 

lies  with 

Sweden 

the 

• 
• 
• 
• 

Swedish Chemicals Agency, 
Swedish Work Environment Authority, 
Swedish county administrative boards, 
Swedish municipal authorities. 

Sweden  has  devised  and 
strategies for both the REACH and CLP Regulations (143). 

implemented  enforcement 

In 2020, Sweden reported that between 9 000 and 9 500 
person-hours  annually  were  allocated 
to  REACH 
Regulation  enforcement  and  7 700  person-hours  to  CLP 
Regulation enforcement (144), not including the work done 
by staff members of the 300 national and 290 municipal 
authorities. 

https://op.europa.eu/en/publication-detail/-
/publication/e5c3e461-0f85-11ec-9151-01aa75ed71a1/. 
(139)  These are substances in tattoo inks and permanent make-up, N,N-
dimethylformamide, formaldehyde (and formaldehyde releasers), 
lead in PVC (polyvinyl chloride), siloxanes (D4, D5, D6) and, finally, 
microplastics. 

(140)  Regulation (EU) 2024/2865 of the European Parliament and of the 
Council  of  23  October  2024  amending  Regulation  (EC)  No 
1272/2008 on classification, labelling and packaging of substances 
and mixtures, OJ L, 2024/2865, 20.11.2024, p.1 (Regulation - EU - 
2024/2865 - EN - EUR-Lex). 

(141)  These are methoxychlor, dechlorane plus and UV-328. In the case 
of the pesticide methoxychlor, there are no exemptions from the 
ban. However, for the two plastic additives, dechlorane plus and 
UV-328,  the  COP  decision 
lists  some  time-limited  specific 
exemptions. 

(142)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 71, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-

Luxembourg, 

Union, 

2020, 

A  risk  approach  was  used  for  the  targeting  of  control 
measures in order to maximise the chances of identifying 
non-compliances.  Therefore,  the  non-compliance  rates 
presented above cannot be considered the average non-
compliance  rates  of  products  in  the  EU.  However,  the 

277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

(143)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 76, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(144)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 75, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(145)  European Chemicals Agency, REF-8 project report on enforcement 
of the CLP, REACH and BPR duties related to substances, mixtures 
p. 20, 
and 
https://echa.europa.eu/documents/10162/17088/project_report
_ref-8_en.pdf/ccf2c453-da0e-c185-908e-
3a0343b25802?t=1638885422475. 

Helsinki, 

articles 

online, 

2021, 

sold 

2025 Environmental Implementation Review – Sweden 

 
 
 
proportion  of  non-compliance  cases  found  in  the  REF-8 
project are of concern. 

Figure 32: Number of REF-8 checks performed per 
100 000 inhabitants (EU average = 1.24) 

Sweden  35 

Swedish participation in the REF-8 project was above the 
EU  average,  which  is  rather  low  because  of  the  lack  of 
involvement of certain large Member States. 

In  this  and  other  projects  conducted  with  the  help  of 
European Chemicals Agency in the past years, online sales 
have  been  proved  to  consistently  correspond  to  higher 
non-compliance rates in checks performed across the EU, 
in particular when related to imported products. 

In 2022, Sweden received a priority action related to the 
upgrading  administrative  capacities  in  implementation 
and  enforcement  to  move  towards  a  policy  of  zero 
tolerance for instances of non-compliance. In the absence 
of  reporting  since  2022,  no  progress  has  been  reported 
and  this  priority  action  remains  valid  in  2025,  partly 
because of the experience with the REF-8 project. 

2025 priority actions 

•  Upgrade 

the 

capacities 

in 
administrative 
implementation and enforcement to move towards a 
policy of zero tolerance of non-compliance. 
Increase customs checks and checks of products sold 
online  with  regard  to  compliance  with  chemicals 
legislations. 

• 

2025 Environmental Implementation Review – Sweden 

 
 
 
Sweden  36 

4. Climate action 

and  (iii)  a  revised  regulation  for  Land  Use,  Land  Use 
Change  and  Forestry (147).  The  package  has  been  fully 
adopted,  and 
the  Member  States  have  been 
implementing the legislation. 

The  key  strategic  document  at  the  country  level  is  the 
NECP (148).  Sweden  submitted  its  updated  plan  in June 
2024 in line with the deadline set by the  Regulation on 
the Governance of the Energy Union and Climate Action 
(149).  The  European  Commission  assessed  the  plan  and 
the  extent  to  which  Sweden  has 
followed  the 
recommendations  for  the  draft  version.  The  findings 
from the assessment are: 

• 

• 

• 

Emissions  under  the  Effort  Sharing  Regulation  will 
decrease  by  44%  in  2030  compared  to  2005,  and 
Sweden  will  have  to  use  flexibilities  to  meet  its 
target of 50%. 
The latest projections show a gap to the  Land Use, 
Land-Use Change and Forestry (LULUCF) Regulation 
target, meaning that current levels of removals have 
been insufficient.  
Sweden  has  a  gap  to  its  target  for  the  share  of 
renewable energy and energy efficiency targets. 

To minimise the impacts of climate policies on vulnerable 
people and sectors, Sweden is using the Just Transition 
Fund  and  will  use  Social  Climate  Fund  from  2026  (for 
more information, see Chapter 5 Financing). 

Figure 33: Total GHG emissions (excluding international 
aviation) (%), 1990–2022 

the  EU  has  demonstrated 

The  impacts  of  climate  change  have  continued  to 
increase in recent years, inflicting damage and suffering 
in the EU and around the world. Globally, 2023 was the 
hottest year on record, while Europe has been warming 
twice  as  quickly  as  the  global  average,  and  is  now  the 
fastest-warming  continent.  The  frequency  and  severity 
of  extreme  climate  events  are  also  increasing.  Against 
its 
this  backdrop, 
determination  to  implement  the  European  Green  Deal 
and  to  become  climate  neutral  and  resilient  by  2050, 
ensuring sustainable competitiveness and supporting EU 
industry in the net-zero transition. The European Climate 
Law is the EU’s response to the need for action. It sets 
the objective of achieving climate neutrality by 2050 and 
a midterm target of a reduction in GHG emissions of at 
least 55 % by 2030, and outlines the adaptation efforts 
necessary  to  adjust  to  climate  change’s  present  and 
future impacts. Almost  all the  ‘Fit for 55’ proposals set 
out in the European Green Deal have been agreed in law, 
and  the  European  Commission  recommended  a  new 
intermediate  climate  target  of  a  90 %  reduction  in 
emissions  by  2040. 
In  2024,  the  Member  States 
submitted  updated  National  Energy  and  Climate  Plans 
(NECPs) 
increased 
ambition  of  the  revised  EU  legislation.  In  2024,  the 
European Commission also released, jointly with the EEA, 
the first-ever European climate risk assessment. 

for  2021–2030, 

reflecting 

the 

Over  the  last  three  decades,  since  1990,  the  EU  has 
achieved  steady  decreases  in  its  emissions,  reaching  a 
running total in 2022 of – 32.5 % (146). However, the EU 
and 
its  Member  States  need  to  step  up  their 
implementation  efforts  and  accelerate  emissions 
reduction to stay on track to reach their targets of a 55 % 
reduction  in  net  GHG  emissions  by  2030  and  climate 
neutrality  by  2050.  Between  1990  and  2022,  net  GHG 
emissions of Sweden decreased by 80 %, making it one 
of the countries with an above-average decrease. 

transition. 

the  green 

The  ‘Fit  for  55’  legislative  package  reflects  the  need  to 
speed  up 
(i) 
strengthening  and  expanding  the  EU  emissions  trading 
system (ETS), with the creation of a new, second, ETS for 
transport and buildings together with a dedicated Social 
Climate  Fund  to  help  citizens  during  the  transition;  (ii) 
increasing  targets  under  the  effort  sharing  regulation; 

includes 

It 

(146)  EU  net  domestic  emissions,  including  the  land  use,  land-use 
change and forestry (LULUCF) sector and excluding international 
aviation. 

(148)  More  information  about  NECP  is  on  the  dedicated  website 

https://energy.ec.europa.eu/topics/energy-strategy/national-
energy-and-climate-plans-necps_en. 

(147)  A  full  overview  of  the  Fit  for  55  package  is  available  at 

(149)   Article  14  of  regulation  2018/1999  on  the  Governance  of  the 

https://commission.europa.eu/strategy-and-policy/priorities-
2019-2024/european-green-deal/delivering-european-green-
deal/fit-55-delivering-proposals_en. 

Energy Union and Climate Action. 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
The EU emissions trading system 

The EU ETS is the key tool for reducing  GHG emissions 
cost-effectively across all Member States. It is the world’s 
biggest carbon market, covering around 40% of the EU’s 
total  GHG  emissions 
from  electricity  and  heat 
generation, the manufacturing industry, aviation within 
Europe (150) and, from 2024, also maritime transport. 

The  system  sets  a  limit  or  cap  on  the  total  amount  of 
GHGs  that  can  be  emitted  at  the  EU  level.  Within  this 
limit,  companies  buy  emissions  allowances 
(one 
allowance  gives  the  right  to  emit  1 tonne  of  CO2 
equivalent),  in  auctions  or  through  trading  allowances 
with others. The cap is reduced annually to ensure that 
overall  emissions  in  the  sectors  covered  decrease  over 
time. 

In  Sweden,  the  emissions  under  the  ETS  decreased  by 
15% from 2005 to 2023. 

In  2023,  only  18 %  of  GHGs  emitted  by  Sweden’s  ETS 
installations  came  from  power  generation.  Of  the  total 
emissions  from  all  industry  sectors,  cement  and  lime 
production  emitted  16 %,  the  metals  industry  emitted 
43 %, refineries accounted for 19 %, and 21 % came from 
other  industries.  With  1 %,  the  share  of  the  chemicals 
industry  was  negligible.  Between  2019  and  2023, 
emissions  from  the  power  sector  decreased  by  40 %, 
while  the  industry  sectors  slightly  increased  emissions, 
by  1 %  (EU  averages:  26 %  and  14 %,  resulting  in  an 
overall decrease of 14 %). Between 2013 and 2023, GHG 
emissions  declined  by  56 %  in  power  generation  but 
increased  by  5 %  in  industrial  manufacturing,  driven 
mainly by metals but also by refineries. 

From 2027, a new emissions trading system, called ETS2, 
for  buildings,  road  transport  and  additional  sectors 
(mainly  industry  not  covered  by  the  current  ETS)  will 
become  fully  operational (151).  Member  States  should 
have  notified  full  transposition  of  the provisions  of the 
revised  EU  ETS  Directive  related  to  the  new  ETS2  into 
national law by 30 June 2024. 

Sweden  did  not  communicate  full  transposition  into 
national law by this deadline. Therefore, on 25 July 2024, 
the  Commission  opened  an  infringement  procedure 
against  Sweden  for  its  failure  to  fully  transpose  the 
provisions  into  national  law.  Sweden  has  since  notified 

(150)  Flights  between  the  EU  Member  States  including  departing 
flights to Norway, Iceland, Switzerland and the United Kingdom. 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.ENG). 

(EU)  2023/959 

(151)  Directive 

Sweden  37 

transposition  of  the  relevant  provisions  of  the  ETS2 
Directive  to  the  Commission.  The  monitoring  and 
reporting  requirements  and  the  obligation  to  hold  a 
permit to carry out activities under ETS2 commenced on 1 
January 2025. 

The  Commission  also  opened  infringement  procedures 
against Sweden on 25 January 2024 for its failure to fully 
transpose  previous  revisions  of  ETS  Directive (152)  into 
national law. Sweden has since notified full transposition 
of the abovementioned directives to the Commission. 

Effort sharing 

The  Effort  Sharing  Regulation (ESR) (153)  covers  GHG 
emissions  from  domestic  transport  (excluding  CO₂ 
emissions  from  aviation),  buildings,  agriculture,  small 
industry  and  waste.  Emissions  from  these  sectors 
account for around 60 % of the EU’s domestic emissions. 
The  regulation  sets  the  EU-wide  target  to  reduce 
emissions  from  the  effort  sharing  sectors  by  40 %  by 
2030 compared to 2005 levels. This overall target for the 
EU  translates  to  binding  national  emission  reduction 
targets for each Member State. Sweden’s target is –50%. 

In  addition  to  the  2030  targets,  Member  States  have 
annual  GHG  emissions 
(annual  emission 
allocations), reducing every year until 2030. 

limits 

There  is  some  flexibility  to  take  account  of  annual 
fluctuations  in  emissions,  by  trading  emissions  and 
transfers from the ETS and LULUCF. 

Based  on  historical  emissions  and  the  most  updated 
implement  new 
projections,  Sweden  will  need  to 
measures and/or use available flexibilities to achieve its 
2030  ESR  target.  The  projected  gap  is  6.2  percentage 
points to the 2030 target. 

The largest contributor is the domestic transport sector, 
which accounted for 50 % of all effort sharing emissions 
in 2022. 

Sweden  is  an  EU  frontrunner  in  sustainable  transport. 
Standing at 6.1 % in 2023, Sweden has the highest share 
of battery electric vehicles in its passenger car fleet of all 
EU  countries.  Its  31  800  publicly  accessible  charging 
points  provided  one  charging  point  for  every  15  e-
vehicles  in  2023  (below  the  EU  average  of  1:10).  The 
composition  of  road  transport  is  very similar  to  the  EU 

(152)  Directive - 2023/959 - EN - EUR-Lex and Directive - 2023/958 - EN 

- EUR-Lex. 
(153)  Regulation 

(EU) 

2018/842 

(https://eur-

lex.europa.eu/eli/reg/2018/842). 

 2025 Environmental Implementation Review – Sweden 

 
 
 
 
 
 
 
Sweden  38 

Sweden’s target for 2030 is to enhance land removals by 
additional –4.0 Mt of CO2 equivalent compared with the 
yearly  average  of  the  period  2016–2018.  The  latest 
available projections show a gap to target of 13.3 Mt of 
CO2  equivalent  in  2030.  Therefore,  Sweden  needs  to 
apply additional measures to reach its 2030 target. 

Adaptation to climate change 

Halting all GHG emissions would still not prevent climate 
impacts 
that  are  already  occurring.  Therefore, 
adaptation to climate change is also a key component of 
climate policy. 

Sweden has one out of three region categories identified 
as  hotspots  of  climate  risks  most  affected  by  climate 
change – low-lying coastal regions (154). 

Climate  change  will  have  a  significant 
impact  on 
Sweden’s natural and built environment and give rise to 
major  societal  challenges.  Projected 
impacts  and 
challenges  include  landslides  and  erosion,  floods,  and 
water  shortages.  Climate  change  is  also  expected  to 
considerably 
impact  Sweden’s  forests.  Sweden  has 
earmarked a budget for climate adaptation that can be 
deployed  at  short  notice.  It  has  also  created  an 
adaptation  fund  for  municipalities  and  increased  their 
funding  to  prevent  natural  disasters  such  as  landslides 
and  floods.  Despite  stepping  up  its  efforts  on  climate 
is  still  facing 
adaptation,  Sweden’s  forestry  sector 
significant  challenges  due  to  new  risks  associated  with 
climate change. 

Sweden adopted its national adaptation strategy in 2009 
and  updated  it  in  2018  and  in  2024.  Sweden  also  has 
sectoral  and  regional  adaptation  plans  with  regular 
updates. 

European  Commission  identified  five  priority  actions  in 
the 2022 EIR. 

Despite being the front  runner in  sustainable transport 
and energy efficiency of buildings, Sweden needs to do 
more to achieve its interim and 2045 climate neutrality 
targets. 

Sweden’s share of renewable energy is the highest in the 
EU and it is growing steadily.  Nevertheless, the current 
target  is  still  below  the  required  contribution  and 
Sweden needs to do more to increase the share. 

average,  with  passenger  cars  accounting  for  83 %  of 
distances  travelled,  and  rail  and  buses  and  coaches 
together for 15 %. On the transport of freight, the split 
between modes of transport is relatively more balanced, 
with  railways  accounting  for  29 %  and  road  transport 
accounting for 71 % of freight  movements. 75 % of the 
Swedish rail network is electrified, which is above the EU 
average of 56 %. 

Sweden’s buildings are among the most efficient in the 
EU.  Although  the  pace  has  slowed  down  in  the  recent 
years, energy consumption and emissions from buildings 
are continuously declining. Buildings accounted for just 
8 % of effort sharing emissions. 

Figure 34: Effort-sharing emissions by sector (%), 2022 

Land use, land-use change and forestry 

The Land Use, Land-Use Change and Forestry (LULUCF) 
sector  plays  a  significant  role  in  achieving  the  EU’s 
climate  neutrality  goal.  In  the  EU,  this  sector  absorbs 
more GHGs than it emits, removing significant volumes 
of carbon from the atmosphere. Thus, it is the only sector 
with negative emissions. 

Sweden is facing significant challenges in enhancing the 
carbon-absorbing  capacity  of  its  land-use  sector,  as 
carbon  removals  have  declined  at  a  worrying  speed  in 
recent years. 

(154)  European Climate Risk Assessment (EUCRA). 2024. Available at 

European Climate Risk Assessment (europa.eu). 

 2025 Environmental Implementation Review – Sweden 

 
 
 
 
 
 
 
 
Sweden  39 

The  Sustainability  Act  (155)  regulates  the  national  REDII 
sustainability  criteria  scheme.  Within  the  scheme, 
sustainability  decisions  can  be  granted  by  the  Swedish 
Energy  Agency.  These  decisions  also  are  used  to 
demonstrate  compliance  with  the  REDII  sustainability 
requirements for biomass fuels as of January 2022. 

Sweden requires new transmission grid investments and 
renewal  of  extensive  parts  of  the  existing  transmission 
network.  In  its  2022–2031  network  development  plan, 
Sweden  has  identified  a  need  to  construct  around 
800 km  of  new  transmission 
lines  and  25  new 
substations,  and  to  renew  1  700 km  of  lines  and  45 
substations. 

2025 priority action 

• 

Implement all polices and measures that are needed 
to  achieve  targets  laid  down  in  the  Effort  Sharing 
Regulation  (ESR)  and  the  Land  Use  and  Land-Use 
Change  and  Forestry  (LULUCF)  Regulation.  More 
detailed  priority  actions  are  set  out 
in  the 
assessment of the final National Energy and Climate 
Plan (NECP) (156). 

(155)   Act (2010:598) on sustainability criteria for biofuels and biofuels. 
Lag  (2010:598)  om  hållbarhetskriterier  för  biodrivmedel  och 
biobränslen | Sveriges riksdag 

(156)   National energy and climate plans. 

 2025 Environmental Implementation Review – Sweden 

 
 
 
 
 
 
 
Sweden  40 

Part II: Enabling framework – implementation tools 

5. Financing

The  EU  budget  supports  climate  investment  in  Sweden 
with  significant  amounts  in  2021–2027,  with  revenues 
from the ETS also feeding into the national budget. During 
2020–2022, Sweden’s revenues from auctioning reached 
EUR 633 million in total, with  84 % spent  on climate and 
energy. 

the  ERDF),  with  a  further  EUR 80.3 million  from  the 
European  Maritime,  Fisheries  and  Aquaculture  Fund 
(EMFAF) (158). 

The  RRF  contributes  to  climate  finance  in  Sweden  with 
EUR 1.5 billion  up  to  2026,  representing  43.6 %  of 
Sweden’s recovery and resilience plan (RRP) (159). 

In  addition,  the  annual  investment  needed  to  meet  its 
environmental  objectives 
in  the  areas  of  pollution 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems is estimated to be EUR 13.9 billion per year in 
Sweden. 

The  European 
(EIB)  provided 
Investment  Bank 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021  and  mid-2024  to  support  energy,  transport  and 
industry  projects  that  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 4.9 billion was assigned to 
Sweden in the reference period (160). 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 5.4 billion per year; thus, there is a 
gap of EUR 8.5 billion per year. 

National financing, including EU emissions trading 
system revenues 

the 

annual 

Of 
gap, 
environmental 
EUR 6.1 billion  concerns  biodiversity  and  ecosystems, 
EUR 1 billion pollution prevention and control, and around 
EUR 500 million  water  and  EUR 900 million  the  circular 
economy objective. 

investment 

Climate finance landmarks 

EU funding for climate action 

The EU budget supports climate action in the EU-27 with 
EUR 657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy provides EUR 120 billion (over half of it through the 
European  Regional  Development  Fund  (ERDF)),  the 
recovery  and  resilience  facility  (RRF)  EUR 275.7 billion, 
and CAP EUR 145.9 billion (157). 

In  Sweden,  the  EU  cohesion  policy  (considering  the  EU 
contribution  amount)  provides  EUR 429 million 
for 
climate action in 2021–2027 (with around half of this via 

European  Union, 

(157)  European  Commission,  Statement  of  Estimates  of  the  European 
Commission –  For  the  financial  year  2025,  Publications  Office  of 
the 
pp. 94–96, 
https://commission.europa.eu/document/download/7a0420e1-
599e-4246-9131-ccb7d505d6d9_en?filename=DB2025-
Statement-of-Estimates_1.pdf.  See  the  Cohesion  Open  Data 
Platform (https://cohesiondata.ec.europa.eu/). 
Cohesion 

Luxembourg, 

(158)  See 

Platform 

2024, 

Open 

Data 

the 

(https://cohesiondata.ec.europa.eu/). 

(159)  European Commission datasets, and the Recovery and Resilience 
(https://ec.europa.eu/economy_finance/recovery-

Scoreboard 
and-resilience-scoreboard/index.html). 

to  EUR 128 million 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
budgets,  amounted 
in  2020, 
EUR 222 million  in  2021  and  EUR 283 million  in  2022  in 
Sweden,  totalling  at  EUR 633 million  in  the  three-year 
period.  In  Sweden,  revenues  are  not  earmarked;  for 
example,  projects  have  been  reported  for  at  least  the 
minimum  required  spending  on  energy  and  climate 
purposes (161). 

From the remaining part of the EU ETS revenues that feed 
into  the  Innovation  Fund  and  the  Modernisation  Fund, 
further  support  is  available  to  climate  action  at  the  EU 
level. 

the  environment 

It should be noted that investment in climate action also 
supports 
the 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (162). 

therefore, 

and, 

(160)  A 

list  of 

financed  projects 

is  provided  by 

the  EIB 

(https://www.eib.org/en/projects/loans/index.htm). 

(161)  European  Commission:  Directorate-General  for  Climate  Action, 
Progress Report 2023 – Climate action, Publications Office of the 
European 
2023, 
https://climate.ec.europa.eu/news-your-voice/news/climate-
action-progress-report-2023-2023-10-24_en. 

Luxembourg, 

Union, 

(162)  NB:  Indirect  investments  (from  climate  and  other  policies)  in 

support of the environment are accounted for via the tracking. 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
 
Environmental financing and investments 

Table 1: Key environmental allocations from EU funds to 
Sweden (million EUR), 2021–2027 

Sweden  41 

This  section  describes  Sweden’s 
investment  needs, 
current  financing  and  gaps  as  they  relate  to  the  four 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (163). 

The environment overall 

Investment needs 

The  overall  environmental 
investment  needs  to  be 
sufficient to enable Sweden to meet its objectives in the 
areas  of  pollution  prevention  and  control,  the  circular 
economy and waste, water protection and management, 
and biodiversity and ecosystems. The required investment 
is  estimated  to  be  EUR 13.9 billion  per  year  (in  2022 
prices). 

A  significant  part  of  the  estimated  requirement,  around 
EUR 6.7 billion per year, can be attributed to the need to 
support biodiversity and ecosystems, and EUR 4 billion to 
support  circular  economy.  For  pollution  prevention  and 
control, the annual investment needs are estimated to be 
EUR 1.9 billion; for water they are EUR 1.2 billion (in 2022 
prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR 5.4 billion  in  Sweden  from  EU  and  national 
sources combined (in 2022 prices). 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 2.5 billion for Sweden in total, during 2021–2027 (or 
EUR 358.5 million per year). 

Instrument 

Cohesion policy 
ERDF 
Just Transition Fund 

CAP 
European Agricultural Guarantee Fund 
European  Agricultural  Fund  for  Rural 
Development 

EMFAF 

Other MFF sources 

RRF (d) (2021–2026) 

Allocations 
228.0 (a) 
174.8 
53.1 
1 232.5 (b) 
569.5 
663.0 

69.4 
979.5 (c) 
1 051.7 

(a) 

(b) 

(c) 

(d) 

European  Commission,  2021-2027  cohesion  policy  (planned) 
allocations in EU amount excluding national co-financing, based on 
the  tracking  in  the  Common  Provisions  Regulation  (CPR,  2021) 
Annex I. Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 
its  publication  date.  Note  that  Sweden  is  not  eligible  for  the 
Cohesion 
information: 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

further 

Source 

Fund. 

and 

Regulation (EU) 2021/2115 of the European Parliament and of the 
Council  of  2 December  2021  establishing  rules  on  support  for 
strategic  plans  to  be  drawn  up  by  Member  States  under  the 
common agricultural policy (CAP strategic plans) and financed by 
the  European  Agricultural  Guarantee  Fund  (EAGF)  and  by  the 
European  Agricultural  Fund  for  Rural  Development  (EAFRD)  and 
repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013 
(OJ 
https://eur-
p. 1), 
lex.europa.eu/eli/reg/2021/2115. 

6.12.2021, 

Annex XI, 

L 435 

Note that 2021-2027 combines factual data for 2021 and 2022 and 
expenditure  under  the  relevant  specific  objectives  (SOs)  of  the 
CAP strategic plans from 2023, using the EU biodiversity tracking 
methodology  (https://commission.europa.eu/system/files/2023-
06/Biodiversity%20tracking%20methodology%20for%20each%20
programme%202023.pdf). Source: European Commission.  

Space  Fund,  Horizon  Europe,  LIFE  and  the  Connecting  Europe 
Facility. 

Outside  the  MFF.  Note  that  the  RRF  applies  a  similar 
environmental tracking scheme (set in the RRF Regulation, Annex 
VI)  as  the  EU’s  cohesion  policy.  RR   dataset  version  used:  July 
2024, prior to 2025 revisions. Data source: European Commission. 

Sweden,  in  addition  to  receiving  EU  funds  earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
the LIFE programme (EUR 5.4 billion) (164), Horizon Europe 
(EUR 95.5 billion) (165),  the  Connecting  Europe  Facility 

(163)  Research,  development  and  innovation  is  accounted  for  under 
each environmental objective. The financing needs, baselines and 
gap  estimates  are  based  on  the  Directorate-General  for 
Environment’s 
internal  analysis  (of  2024).  Throughout  this 
chapter,  specific  references are  provided to  the  most  important 
data sources used. 

(164)  https://cinea.ec.europa.eu/programmes/life_en. 
(165)  European  Commission,  Horizon  Europe  (https://research-and-
innovation.ec.europa.eu/funding/funding-opportunities/funding-
programmes-and-open-calls/horizon-europe_en). 

2025 Environmental Implementation Review – Sweden 

 
 
Sweden  42 

The gap 

To meet its four environmental objectives beyond climate 
change, the additional investment needs over the current 
levels (i.e. the gap) are estimated to reach EUR 8.5 billion 
per  year  in  Sweden,  representing  around  1.5 %  of  the 
national GDP, being higher than the EU average (0.77 %). 

Figure 35: Environmental financing, needs and gaps  per 
Member State (% of GDP) 

(EUR 37.7 billion) (166)  and  funds  that  can  be  mobilised 
through the InvestEU programme (167). 

Sweden’s  RRP  supports  climate  objectives  through 
funding of EUR 1.5 billion (43.6 % of Sweden’s total RRP), 
with  an  additional  5 %  of  funds  for  the  environment 
(EUR 170 million). 

The EIB provided around  EUR 1.5 billion in environment-
related  financial  contribution  to  Sweden  from  2021  to 
mid-2024,  most  of  which,  EUR 1.2 billion  (80 %),  in  the 
area  of  sustainable  energy,  transport  and 
industrial 
projects,  which  provides  significant  co-benefits  to 
reducing  air  pollution,  environmental  noise  and  other 
pollution. 

The  EU’s  total  national  expenditure  on  environmental 
protection  (operating  plus  capital  expenditure)  was 
EUR 298 billion  in  2020  and  EUR 321 billion  in  2021, 
representing around 2.2 % of EU-27 GDP. In Sweden, the 
total national environmental protection expenditure was 
EUR 10 billion in 2020 and EUR 11.3 billion in 2021, both 
representing 2.1 % of GDP. 

Of  the  total  environmental  expenditure,  the  national 
capital  expenditure 
(investment)  on  environmental 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
In  Sweden,  the  national 
0.4 %  of  the  EU’s  GDP. 
environmental 
reached 
EUR 2.4 billion  in  2020,  rising  to  EUR 2.6 billion  in  2021, 
representing 0.5 % of GDP. 

investment 

protection 

protection 

investment 

Split  by  institutional  sector,  53 %  of  Sweden’s  national 
environmental 
(capital 
expenditure) comes from the general government budget, 
with 17 % coming from specialist private-sector producers 
(of environmental protection services, such as waste and 
water  companies)  and  30 %  from  the  business  sector, 
whose environmental activities are usually ancillary to its 
main  activities.  At  the  EU  level,  38 %  of  environmental 
protection  investment  comes  from  governments,  40 % 
from  specialist  private-sector  producers  and  22 %  from 
the general business sector (168). 

Sweden’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 5.4 billion  per  year  (in  2022 
prices),  including  EU  funding  and  national  public  and 
national private expenditure. Of the total, the share of EU 
fund (including EIB funds) reaches 13 %, with around 87 % 
national  financing.  The  total  public  financing  (EU  plus 
national public) represents 59 % of the total. 

Source: Analysis of Directorate-General for Environment. 

The following table provides the distributions of Sweden’s 
environmental  investment  gap  (expressed  in  various 
forms) by environmental objective. 

Table 2: Summary of environmental investment gaps in 
Sweden per year, 2021–2027, per year 

Environmental 
objective 

Investment gap per year  

Million EUR 
(2022 
prices) 

% of 
total 

% of 
GDP 

Pollution prevention 
and control 

Circular economy and 
waste 

Water management 
and water industries 

1 016 

12.0 

0.18 

902 

10.6 

0.16 

473 

5.6 

0.08 

(166)  The  Connecting  Europe  Facility  Transport  part  also  includes 
EUR 11.3 billion  transferred  from  the  Cohesion  Fund,  of  which 
30 % 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. 

(167)  The  InvestEU  Fund  is  set  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  EIB  group 
and others. 

(168)  Eurostat, 

‘Environmental  protection  expenditure  accounts’, 

env_ac_epea. 

2025 Environmental Implementation Review – Sweden 

 
 
 
Biodiversity and 
ecosystems 

6 092 

71.8 

1.09 

Total 

8 432 

100.0 

1.5 

Source: Directorate-General for Environment analysis. 

Pollution prevention and control 

Investment needs 

In pollution prevention and control, Sweden’s investment 
needs  are  estimated  to  reach  EUR 1.9 billion  per  year 
(including  baseline  investments)  in  2021–2027.  Most  of 
this,  EUR 1.3 billion,  relates  to  air  pollution  control,  to 
comply with the clean air requirements for the five main 
air  pollutants  under  the  National  Emission  Reduction 
Commitments  Directive  (NECD)  by  2030.  The  estimated 
needs to reduce environmental noise reach EUR 0.8 billion 
per  year,  most  of  which  is  delivered  by  the  (same) 
sustainable  energy  and  transport  investments  that  also 
benefit  clean  air (169).  Protection  from  radiation  costs 
EUR 369 million  a  year,  while  industrial  site  remediation 
an  estimated  EUR 102 million  per  year.  Microplastics 
pollution  and  the  chemicals  strategy  require  around 
EUR 60–80 million per year (each) (170). 

Current investments 

reach 

control 

investment 
and 

levels  supporting  pollution 
The  current 
prevention 
estimated 
an 
EUR 866 million per year in Sweden in 2021–2027. Most of 
the  financing  concerns  clean  air  (EUR 518 million  per 
year).  Protection  from  environmental  noise  receives 
around  EUR 128 million  per  year,  with  a 
further 
EUR 31 million spent on site remediation. 

In Sweden, the EU MFF provides an estimated 5.9 % of the 
clean  air  financing  (mostly  via  cohesion  policy),  with  a 
further  10.6 % from the RRF, adding up to  16.4 % of the 
total. EIB financing contributes 19 % and national sources 
reach 65 % (171). 

(169)  2021 

assessment 

Phenomena 

project 
(https://op.europa.eu/en/publication-detail/-
/publication/f4cd7465-a95d-11eb-9585-01aa75ed71a1)  and  the 
Directive 
Commission’s 
implementation 
report 
(https://environment.ec.europa.eu/system/files/2023-
03/COM_2023_139_1_EN_ACT_part1_v3.pdf). 

Environmental 

Noise 

2023 

(170)  European  Commission,  Third  Clean  Air  Outlook,  Brussels,  2022, 

https://environment.ec.europa.eu/topics/air/clean-air-
outlook_en. See also the impact assessment for the revision of the 
AAQD, available from the Commission web page on the proposed 
revision 
(https://environment.ec.europa.eu/publications/revision-eu-
ambient-air-quality-legislation_en). 

(171)  Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure (EPEA accounts, Eurostat). Note that the bulk of clean 
air  financing  is  provided  as  a  contribution  from  climate  (energy 
and  transport)  measures,  as  per  the  tracking  schemes  in  the 

Sweden  43 

The gap 

To meet its environmental objectives concerning pollution 
prevention and control (towards zero pollution), Sweden 
needs  to  provide  an  additional  EUR 1 billion  per  year 
(0.18 % of GDP), mostly related to clean air and noise. The 
adequate 
the 
investments included for sustainable energy and transport 
would largely deliver this, while in many Member States 
additional measures and investments may be required to 
comply with the ammonia reduction requirements. 

implementation  of 

the  NECP  with 

According to the latest (2023) NAPCP review report (172), 
Sweden  did  not  comply  with  ammonia  reduction 
requirements in 2020 and 2021,  while  it is not  at risk  of 
non-compliance  with  ammonia  concerning  the  NECD’s 
2030  emission  reduction  commitments,  based  on  the 
policies and measures in its NAPCP that takes into account 
climate, energy and CAP plans and financing baselines. 

Circular economy and waste 

Investment needs 

Sweden’s  investment  needs  in  circular  economy  and 
waste  are  estimated  to  reach  an  EUR 4 billion  per  year 
(including  baseline  investments).  Most  of  this,  around 
EUR 3.1 billion  per  year,  relates  to  circular  economy 
measures  in  the  mobility,  food  and  built  environment 
systems,  with  a  further  EUR 900 million  necessary  for 
waste  management  (municipal  and  packaging  waste), 
covering  waste  collection,  biowaste  treatment,  recycling 
reprocessors, waste-sorting facilities, and digitalisation of 
the  waste  registry.  The  amount  for  waste  excludes  the 
investments  needed  for  the  uptake  of  circularity  and 
waste prevention across the economy (173). 

Current investments 

Circular economy investments across the economy reach 
around EUR 2.3 billion per year in Sweden in 2021-2027, 
with  a  further  EUR 800 million  provided  for  waste 
management that does not constitute circular economy. 

information  on  clean  air 

Common  Provisions  Regulation  Annex  I  and  the  RRF  Regulation 
Annex  VI.  Further 
tracking: 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 
(172)  European Commission, ‘National air pollution control programmes 
website, 
European 

projections’, 

and 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants/national-air-pollution-control-
programmes-and-projections_en. 

Commission 

(173)  See Systemiq and Ellen MacArthur Foundation, Achieving ‘Growth 
Within’, 2017; and European Commission: Directorate-General for 
Environment, Study on investment needs in the waste sector and 
on  the  financing  of  municipal  waste  management  in  Member 
States,  Publications  Office  of  the  European  Union,  Luxembourg, 
2019, 
https://op.europa.eu/en/publication-detail/-
/publication/4d5f8355-bcad-11e9-9d01-01aa75ed71a1. 

2025 Environmental Implementation Review – Sweden 

 
 
Around 0.4 % of this combined financing for circularity and 
waste  comes  from  EU  MFF,  with  a  further  0.6 % 
contribution from the RRF, adding up to 1 % together. EIB 
loans  identified  in  support  of  circularity  and  waste 
represent 1.1 % of the total. The share of national sources 
is overwhelming, reaching 98 % of the total financing (174). 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  Sweden  needs  to  increase 
investments  by  an  estimated 
circular  economy 
EUR 831 million 
additional 
EUR 71 million concerning waste management action, not 
belonging to circular economy. Combined, this amounts to 
EUR 902 million per year, representing 0.16 % of Sweden’s 
GDP. 

year,  with 

per 

an 

Of  the  circular  economy  gap,  EUR 217 million  relates  to 
recent  initiatives,  such  as  the  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 
digital tools, CRM recycling and measures proposed under 
the  amendment  of  the  Waste  Framework  Directive,  and 
EUR 613 million constitutes a further investment need to 
unlock Sweden’s circular economy potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 1.2 billion  (in  2022  prices)  in  2021-2027  in  Sweden. 
This  comprises  investment  needs  both  for  the  water 
industry and  for  the  protection  and  the  management  of 
water. Of the total annual need, EUR 957 million relates to 
the management of wastewater (also including additional 
costs  associated  with  the  revised  UWWTD).  A  further 
EUR 21 million  is  necessary  for  drinking-water-related 
investments  and  around  EUR 220 million 
the 
protection and management of water (175). 

for 

Current investments 

Water investments in Sweden are estimated to be around 
EUR 736 million per year (in 2022 prices) in 2021–2027. Of 

(174)  Waste management and circular economy expenditure tracking in 
the  EU  funds,  EIB  projects  and  in  the  national  expenditure 
(Eurostat).  Datasets:  EPEA  accounts  (env_epi)  and  circular 
economy private investments (cei_cie012). 

(175)  See  European  Commission,  ‘Estimating  investment  needs  and 
financing capacities for water-related investment in EU Member 
States’, 
2020, 
2  May 
https://commission.europa.eu/news/estimating-investment-
needs-and-financing-capacities-water-related-investment-eu-
member-states-2020-05-28_en;  and  OECD,  Financing  Water 
Supply, Sanitation and Flood Protection: Challenges in EU Member 
States  and  policy  options,  OECD  Publishing,  Paris,  2020, 
https://www.oecd-ilibrary.org/environment/financing-water-
supply-sanitation-and-flood-protection_6893cdac-en. 

(176)  Water investment levels are estimated through tracking EU funds, 
EIB projects and national expenditure (EPEA accounts, Eurostat). 

Sweden  44 

this,  EUR 671 million supports wastewater  management, 
EUR 5 million  drinking  water  and  around  EUR 55 million 
the  other  aspects  of  the  Water  Framework  Directive 
(water management and protection). 

Of  the  total  financing,  1.2 %  is  provided  by  the  EU  MFF 
(mostly through cohesion policy), with no further support 
from the RRF. EIB financing is around  1.1 % of the total, 
while the bulk of financing comes from national sources 
(98 %) (176). 

The gap 

Sweden’s  water  investment  gap  to  meet  the  various 
environmental  targets  under  the  Water  Framework 
Directive  and  the  Floods  Directive 
is  estimated  at 
EUR 473 million  per  year 
(0.08 %  of  GDP),  with 
EUR 287 million linked to wastewater measures. Drinking 
water measures require an additional EUR 16 million per 
year  and  the  other  aspects  of  the  Water  Framework 
Directive  around  EUR 165 million  per  year  over  the 
existing levels of financing. 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 6.7 billion per year (in 2022 prices) in 
Sweden 
includes  the  following 
financing needs: 

in  2021–2027.  This 

• 

• 

• 

action 

prioritised 

framework (177), 
Sweden’s 
concerning  the  Natura  2000  areas:  EUR 507 million 
per year, mostly running costs; 
additional BDS costs (178): EUR 4.4 billion per year on 
top of the framework; 
sustainable 
EUR 1.8 billion per year. 

management 

costs (179): 

soil 

Current investments 

The current level of biodiversity financing is estimated to 
be EUR 655 million per year (in 2022 prices) in 2021–2027. 
81.3 % of this is considered direct financing to biodiversity 

(177)  European Commission, ‘ inancing Natura 2000 – Prioritised action 
website, 

Commission 

frameworks’, 
https://environment.ec.europa.eu/topics/nature-and-
biodiversity/natura-2000/financing-natura-2000_en. 

European 

(178)  See European Commission: Directorate-General for Environment, 
Biodiversity  Financing  and  Tracking –  Final  report,  Publications 
Office 
2022, 
https://op.europa.eu/en/publication-detail/-
/publication/793eb6ec-dbd6-11ec-a534-
01aa75ed71a1/language-en. 

European  Union, 

Luxembourg, 

the 

of 

(179)  See Proposal for a directive of the European Parliament and of the 
Council  on  soil  monitoring  and  resilience  (Soil  Monitoring  Law), 
2023, 
COM(2023) 416 
https://environment.ec.europa.eu/publications/proposal-
directive-soil-monitoring-and-resilience_en. 

5 July 

final 

of 

2025 Environmental Implementation Review – Sweden 

 
 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

Public financial management 

Sweden  45 

0.2 % of the total financing is estimated to come from EU 
cohesion  policy,  25.1 %  from  CAP,  9.1 %  from  Horizon 
Europe, around 3.5 % from LIFE and 1 % from EMFAF. The 
EU  MFF  altogether  accounts  for  40.1 %  of  the  financing 
and the RRF for 5 %, adding up to a total of 45.1 % from 
the  EU  budget.  The  rest,  54.9 %,  comes  from  national 
sources (180). 

Sweden has a relatively high share of funds dedicated to 
biodiversity  under  the  RRF  (7.2 %)  and  under  the  CAP 
(19.9 %),  both  well  above  the  EU  average.  On  the  other 
hand,  Sweden  is  among  the  Member  States  with  the 
lowest  share  of  cohesion  policy  funding  (considering  EU 
contribution  amounts,  disregarding  ESF+)  programmed 
for  measures  supporting  biodiversity  in  2021–2027,  at 
only 1.0 %. 

Figure 36: 2021–2027 contributions to biodiversity from 
the main EU instruments per Member State (% of policy 
total) 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools  to 
achieve climate and environmental goals. Some Member 
States,  including  Sweden,  already  use  green  budgeting 
tools  for  identifying  and  tracking  green  expenditures 
and/or revenues (181). Green budgeting practices provide 
increased transparency on the environmental implications 
of budgetary policies. 

The  Commission  has  developed  a  non-mandatory  green 
budgeting  reference  framework  that  brings  together 
methodologies  for  assessing  the  impacts  of  budgets  on 
climate and environmental goals (182). 

To help Member States develop national green budgeting 
and  thereby  improve  policy  coherence  and  support  the 
green  transition,  the  Commission  facilitated  a  technical 
support instrument (TSI) project on green budgeting from 
2021 to 2024 (183). Sweden did not participate. 

Beyond green budgeting, to improve policy outcomes, the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (184)  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

NB: ESF+, European Social Fund Plus. 

The gap 

To  meet  the  environmental  objectives  concerning  the 
protection and restoration of biodiversity and ecosystems 
and  other  relevant  cross-cutting  measures,  Sweden’s 
investment gap is estimated to be around EUR 6 billion per 
year, corresponding to 1.09 % of its GDP. 

formed  the 

Total environmental taxes amounted to EUR 10.8 billion in 
Sweden  in  2022,  representing  1.9 %  of  its  GDP  (EU 
average:  2.0 %).  Energy  taxes 
largest 
component of environmental taxes, accounting for 1.5 % 
of  GDP,  which  is  lower  than  the  EU  average  of  1.6 %. 
Transport taxes, at 0.4 % of GDP, were at the EU average 
(0.4 %), while taxes on pollution and resources, at 0.06 % 
were  slightly  under  the  EU  middle  value  (EU  average: 
0.08 %). 
in  Sweden 
accounted  for  4.6 %  of  total  revenues  from  taxes  and 

In  2022,  environmental  taxes 

(180)  Based  on 

biodiversity 

tracking 

in 

the 

EU 

budget 

(182)  European  Commission, 

(https://circabc.europa.eu/ui/group/3f466d71-92a7-49eb-9c63-
6cb0fadf29dc/library/8e44293a-d97f-496d-8769-50365780acde), 
and national expenditure into biodiversity from the Classification 
of the Functions of Government accounts. 

(181)  European  Commission,  Green  Budgeting  in  the  EU.  Key  Insights 
from the 2023 European Commission Survey of Green Budgeting 
Practices, 
https://economy-
finance.ec.europa.eu/economic-and-fiscal-governance/national-
fiscal-frameworks-eu-member-states/green-budgeting-
eu_en#:~:text=European%20Commission%20Green%20Budgetin
g%20Survey%C2%A0. 

2023, 

‘European  Union  green  budgeting 
https://economy-

2022 

framework’, 

reference 
finance.ec.europa.eu/economic-and-fiscal-governance/green-
budgeting-eu_en. 

(183)  https://reform-support.ec.europa.eu/what-we-do/revenue-

administration-and-public-financial-management/supporting-
implementation-green-budgeting-practices-eu_en. 

(184)  Commission notice – Technical guidance on the climate proofing 
of infrastructure in the period 2021–2027 (OJ C 373, 16.09.2021, 
p. 1), 
https://op.europa.eu/en/publication-detail/-
/publication/23a24b21-16d0-11ec-b4fe-
01aa75ed71a1/language-en. 

2025 Environmental Implementation Review – Sweden 

 
 
 
social security contributions (slightly under the EU average 
of 5.0 %) (185). 

issuance 
(EUR 12.5 billion). 

in  2023  amounted 

to  USD 13.5 billion 

Sweden  46 

Figure 37: Environmental taxes per Member State, 2022 

The EU Green Deal emphasises the role of well-designed 
tax  reforms  (e.g.  shifts  from  taxing  labour  to  taxing 
pollution) to boost economic growth and resilience, and to 
foster  a  fairer  society  and  a  just  transition  through  the 
right price signals. The Green Deal promotes the ‘polluter-
pays  principle’,  which  makes  polluters  bear  the  costs  to 
prevent, control and remedy pollution. 

According to a 2024 study (186), Sweden applies emission 
charges  (e.g.  for  NOx,  sulphur  oxides  and  other  sulphur 
emissions to air), product charges (for vehicles, pesticides 
and  batteries),  and  user  charges  (for  waste  volumes 
produced and through road pricing). An example of good 
practices  are  congestion  charges  applied  in  Stockholm 
that helped reduce PM10 pollution by 18 %. On the other 
hand, Sweden has recently decided to abolish the plastic 
bag tax. 

Green bonds and sustainable bonds 

In  2023,  the  total  value  of  the  green  bonds  issued  by 
Member States  was USD 245 billion (EUR 227 billion), up 
from USD 234 billion (EUR 198 billion) in 2021 (187). 

During 2021–2023 combined, Sweden issued green bonds 
worth  USD 42 billion  (EUR 35.5 billion).  Of  this,  the 

During  2014–2023,  83 %  of  the  green  bonds  issued  by 
European  countries  (excluding  supranational  entities) 
served objectives in energy, buildings or transport, while 
5 % supported objectives in water, 5.1 % related to land 
use  (with  links  to  nature  and  ecosystems)  and  3.8 % 
applied  to  waste  management.  By  2023,  the  combined 
share of energy, buildings and transport had decreased to 
73 %, the shares of waste management and land use had 
increased (to 5.9 % and 8.4 %, respectively) and the share 
of water had remained around 5 %. 

In  2021–2023,  31.7 %  of  the  European  green  bonds 
(excluding  supranational 
issued  by 
financial  corporates,  29.1 %  by  sovereign  governments 
and  23.1 %  by  non-financial  corporates.  8.3 %  of  the 
issuances was linked to government-backed entities, 6.4 % 
to development banks and 1.4 % to local governments. 

issuances)  was 

Figure 38: Value of green bonds issued per Member State 
(billion EUR), 2021, 2022 and 2023 

Data source: Climatebonds.net, with some additional data from national 
sources (e.g. Croatia, Slovenia). 

Environmentally harmful subsidies 

Addressing  and  phasing  out  environmentally  harmful 
subsidies, in particular fossil fuel subsidies (FFS) is a further 
step  towards  achieving  the  eighth  environment  action 

(185)  Eurostat, ‘Environmental taxes accounts’, env_eta. 
(186)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
Annex 1, 
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

(187)  Climate  bonds  initiative  (https://www.climatebonds.net/).  NB. 
Additionally (and not included in this), national sources indicated 
EUR 544.8 million issuance for Croatia, in 2022-2023, and a slightly 
higher  amount  for  Slovenia  (+0.27  billion)  during  2021-2023  in 
total. 

2025 Environmental Implementation Review – Sweden 

 
 
 
 
 
programme  objectives  and  the  enabling  conditions (188). 
FFS are costly for public budgets and make it difficult to 
achieve European Green Deal objectives. 

The overall downward trend of FFS mentioned in past EIRs 
was disrupted from 2022 due to the European response to 
the 2021 energy crisis and subsequent increase in energy 
prices. 

As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 109 billion in 2023 from EUR 57 billion in 
2020. From 2021 to 2023, there was a marked increase in 
annual FFS of 72 % in the EU (189). 

For the majority of the Member States (16), the year 2022 
saw  a  peak  in  the  amount  of  overall  FFS.  A  decline  was 
then observed in 2023 (190). In particular, FFS for coal and 
lignite, natural gas and oil increased in 2022, and a strong 
increase was observed for natural gas subsidies. 

In Sweden, the energy subsidies were relatively stable in 
2015–2018,  showed  a  marked  decrease  in  subsequent 
years (2019–2021), and in 2022, were in line with the EU-
wide  trend.  FFS  decreased  since  2016  (EUR 1.2 billion), 
reaching its annual minimum (EUR 300 million) in 2021. In 
2022,  FFS  increased  to  EUR 800 million,  and  in  2023  to 
EUR 900 million. 

As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to less than 0.1 % in Denmark and Sweden (the EU average 
was 0.8 %) (191). 

Sweden  47 

Figure 39:  Energy  subsidies  by  energy  carrier  (billion 
EUR), 2015–2023 

NB: RES, renewable energy source. 

Source: analysis of Directorate-General Energy 

In 2022, Sweden received the following priority action: 

• 

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

investment  needs 

Overall, Sweden has  a  similar environmental investment 
gap level as at the time of the 2022 EIR, at around 1.5 % of 
GDP; this gap is above the EU average and is mostly related 
to biodiversity and ecosystems. 

2025 priority action 

•  Use more national funding (for instance by increasing 
taxes  in  favour  of  the  environment  and  reducing 
environmentally  harmful  subsidies),  EU  funding  and 
private funding to help close the investment gap. 

(188)  Article 3(h) and 3(v) of the eighth environment action programme. 
(189)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 

European Union, COM(2025). 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en. 

(190)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

(191)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 

European Union, COM (2025). 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en.  

2025 Environmental Implementation Review – Sweden 

 
 
 
 
 
 
 
6. Environmental governance 

Sweden  48 

Information, public participation and access 
to justice 

Citizens can more effectively protect the environment 
if  they  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention:  (i)  access  to 
information,  (ii)  public 
participation  in  decision-making  and  (iii)  access  to 
is  of  crucial 
justice  in  environmental  matters.  It 
importance  to  public  authorities,  the  public  and 
businesses  that  environmental  information  is  shared 
efficiently  and  effectively (192).  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 environment, safeguard 
the  rights  of  citizens  and  ensure  accountability  of 
authorities (193).  It  includes  the  right  to  bring  legal 
challenges (‘legal standing’) (194). 

Environmental information 

This  section  focuses  on  the  implementation  of  the 
Infrastructure for Spatial Information in the European 
Community  (Inspire)  Directive.  The  Inspire  Directive 
aims  to  set  up  a  European  spatial-data  infrastructure 
for sharing environmental spatial information between 
public authorities across Europe. It is expected that this 
will help policymaking across boundaries and facilitate 
information.  Geographic 
public  access 
information is needed for good governance at all levels 
and  should  be  readily  and  transparently  available 
(Table 3). 

this 

to 

(192)  The  Aarhus  Convention 

(https://unece.org/environment-
policy/public-participation/aarhus-convention/text), 
the 
Access  to  Environmental  Information  Directive  (Directive 
(https://eur-lex.europa.eu/legal-
2003/4/EC) 
Inspire 
content/EN/TXT/?uri=CELEX:32003L0004)  and  the 
Directive 
(https://eur-
lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32007L0002)  together  create  a 
legal foundation for the sharing of environmental information 
between public authorities and with the public. 

2007/2/EC) 

(Directive 

(193)  These guarantees are explained in the European Commission’s 
2017  notice  on  access  to  justice  in  environmental  matters 
(https://eur-lex.europa.eu/legal-

Table 3: Sweden dashboard on implementation of the 
Inspire Directive, 2016–2023 

2016  2023 

Legend 

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

addressed 

■ 
Implementation  of 
this provision has started 
and  made 
some  or 
substantial  progress  but 
is  still  not  close  to  being 
completed. 
Percentage = 31–89 % 

■ 
Implementation  of 
this  provision  is  falling 
behind. 
significantly 
Serious 
are 
necessary  to  close  the 
implementation 
gap. 
Percentage < 31 % 

efforts 

Effective  coordination  and 
data sharing 

Ensure 
effective 
coordination  

sharing 

Data 
without 
obstacle  

Inspire 
indicators 

■  ■ 

■  ■ 

performance 

(i)  Conformity 
of metadata  

■  ■ 

(ii)  Conformity 
spatial 
of 
datasets 

(iii) 
Accessibility  of 
spatial datasets 
through 
view 
and  download 
services 

(iv)  Conformity 
of 
network 
services 

■  ■ 

■  ■ 

■  ■ 

Source:  European  Commission,  ‘Sweden’,  Inspire  Knowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/sweden_en. 

Sweden’s  performance  in  implementing  the  Inspire 
Directive  is  substantial  and  has  been  reviewed  based 
on its 2023 country fiche (195) (see Table 3). 

In 2022, Sweden received a priority action on the need 
to prioritise environmental datasets (196). Sweden has 

content/EN/ALL/?uri=CELEX:52017XC0818(02))  and a related 
2018  citizen’s  guide  (https://op.europa.eu/en/publication-
detail/-/publication/2b362f0a-bfe4-11e8-99ee-
01aa75ed71a1/language-en/format-PDF). 

(194)  This  EIR  focuses  on  the  means  used  by  Member  States  to 
guarantee rights of access to justice and legal standing and to 
overcome  other  major  barriers  to  bringing  cases  on 
environmental protection. 

(195)  European  Commission,  ‘Sweden’,  Inspire  Knowledge  Base, 

https://knowledge-base.inspire.ec.europa.eu/sweden_en. 

(196)  An  overview  of  these  datasets  can  be  found  online 

(https://github.com/INSPIRE-MIF/need-driven-data-

Environmental Implementation Review 2025 – Sweden 

 
 
 
 
 
 
made good progress on making priority environmental 
data  accessible,  but  more  efforts  are  needed. 
Therefore, the 2022 priority action is repeated. 

Public participation 

impact 

assessment  procedure. 

Public  involvement  at  both  the  planning  and  the 
project  phase  maximises  transparency  and  social 
acceptance of programmes and projects. Consultation 
with  the  public  (including  NGOs)  and  environmental, 
local  and  regional  authorities  is  a  key  feature  of  an 
effective 
Such 
consultation  also  provides  an  opportunity  for  public 
authorities and project promoters to engage with the 
public actively and meaningfully by making information 
on  the  likely  significant  effects  widely  available.  If 
into 
carried  out  with  due  diligence  and  taking 
consideration useful public input, this process leads to 
better-informed  decision-making  and  can  promote 
information  available 
public  acceptance.  Making 
lessening 
increases  stakeholder 
resistance and preventing (or minimising) litigation. On 
the other hand, it is paramount that the procedure is 
effective. 

involvement,  thus 

This  section  examines  how  public  involvement  and 
transparency  are  ensured  under  two  instruments, 
namely  the  Environmental  Impact  Assessment  (EIA) 
Directive (197)  and 
the  Strategic  Environmental 
Assessment (SEA) Directive (198). 

EU  law  provides  for  a  flexible  framework  concerning 
EIAs.  The  aim  of  this  framework  is  to  ensure  the 
application of the necessary environmental safeguards, 
while  enabling  speedy  approval  of  projects.  The 
Commission  has  contributed  to  simplifying  and 
accelerating permitting for renewable energy projects 
and  continues  to  support  the  Member  States  in  this 
regard (199). Sweden has already taken steps aiming to 
accelerate 
taking 
advantages of the broad flexibilities offered by the EU 
legal framework, such as the establishment of one-stop 

permit-issuing 

procedures 

prioritisation/blob/main/documents/INSPIRE_EEA_Reporting
_blueprint_v1.0.pdf). 

(197)  Directive 2011/92/EU of the European Parliament and of the 
Council of 13 December 2011 on the assessment of the effects 
of certain public and private projects on the environment (OJ 
L 26, 
28.1.2012,  p. 1),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32011L0092. 

(198)  Directive 2001/42/EC of the European Parliament and of the 
Council  of  27 June  2001  on the  assessment  of  the  effects of 
certain plans and programmes on the environment (OJ L 197, 
21.7.2001, 
https://eur-lex.europa.eu/legal-
p. 30), 
content/EN/ALL/?uri=CELEX:32001L0042. 

(199)  Commission Staff Working Document  (SWD/2022/0149 final), 
https://eur-lex.europa.eu/legal-

2022, 

May 

18 

Sweden  49 

shops  and  accelerated  short  deadlines  for  issuing 
permits for renewable energy projects. 

The  average  speed  in  the  EU  for  issuing  permits 
involving  an  EIA  procedure  is  20.6 months,  with  a 
minimum  duration  of  11.4 months  and  a  maximum 
duration of 75.7 months (200). The duration of each step 
in an EIA process (screening, scoping, EIA report, public 
reasoned  conclusion,  development 
consultation, 
consent) varies considerably between Member States 
and  projects.  The  available  data  for  Sweden  do  not 
cover  all  the  steps  of  the  EIA  to  draw  overall 
conclusions.  Moreover,  Sweden  reported  a  relatively 
large difference between the minimum and maximum 
duration  of  the  screening  (0–20 months)  and  of  the 
development  consent  step  (1.2–22 months).  Effective 
use  of  EU  procedures  can  positively  influence  the 
the 
timely  approval  of  activities  underpinning 
decarbonisation of the economy on the way to net zero 
by 2050. 

A new report is not yet available on the application and 
effectiveness  of  the  SEA  Directive 
in  the  EU. 
Nevertheless, a support study has been published with 
information by Member State (201). 

Publication of the initiation of EIA and 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  the  relevant  websites.  The  websites  of  individual 
and  permitting 
county 
authorities  provide  information  for  those  seeking  a 
permit as well as information on public participation in 
EIAs. 

administrative  boards 

In  the  2022  EIR,  it  was  recommended  that  Sweden 
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  the 
national or local levels are needed to encourage higher 

content/EN/TXT/?uri=CELEX%3A52022SC0149&qid=1653034
229953. 

(200)  European Commission: Directorate-General for Environment, 
Collection of information and data on the implementation of 
the  revised  Environmental  Impact  Assessment  (EIA)  Directive 
(2011/92/EU) as amended by 2014/52/EU), Publications Office 
of  the  European  Union,  Luxembourg,  2024,  Tables 5  and  6, 
https://op.europa.eu/en/publication-detail/-
/publication/8349a857-2936-11ef-9290-01aa75ed71a1/. 
(201)  European  Commission:  Directorate-General  for  Environment, 
Lundberg,  P.,  McNeill,  A.,  McGuinn,  J.,  Cantarelli,  A.  et  al., 
Study  supporting  the  preparation  of  the  report  on  the 
application  and  effectiveness  of  the  SEA  Directive  (Directive 
2001/42/EC) – Final study, Publications Office of the European 
Union, 2025, https://data.europa.eu/doi/10.2779/1615072 

Environmental Implementation Review 2025 – Sweden 

 
 
 
levels of participation. There is no information available 
about the progress on this priority action. 

justice can also be found on the website of the Swedish 
courts (205). 

Sweden  50 

Sweden  is  subject  to  an  infringement  case  for  non-
compliance in transposing the EIA Directive (202). 

Access to justice 

Access  to  justice,  guaranteed  by  Article 19(1)  of  the 
Treaty  on  European  Union  and  Article 47  of  the  EU 
Charter of Fundamental Rights, is a fundamental right 
and part of the democratic process. It is vital to ensure 
the full application of EU law in all Member States and 
individuals, 
the  legal  protection  of  the  rights  of 
including in environmental matters. Access to justice is 
essential  to  enable  judicial  review  of  the  decisions  of 
public  authorities  and  to  allow  the  correction  of  any 
wrongdoing committed by these authorities. 

This section provides a snapshot of the state of play of 
access  to  courts  by  the  public,  particularly  when  it 
comes  to  challenging  plans,  or  the  non-adoption  of 
plans, under EU law, in the areas of water, waste, air 
quality and noise, irrespective of the form of the legal 
act (i.e. regulatory act or administrative decision). 

As  mentioned  in  the  2022  EIR,  individuals  and  NGOs 
meeting  the  requirements  stipulated  in  the  Swedish 
Environmental  Code  may  challenge  administrative 
decisions. 

are  not 

and  programmes 

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

There is no organised communication regarding where 
to find the rules on access to justice that are available 
in Sweden. However, rudimentary information may be 
found  on  the  websites  of  some  of  the  main 
environmental  protection  authorities,  such  as  the 
Swedish Environmental Protection Agency (SEPA) (203), 
and  the  National  Board  of  Housing,  Building  and 
Planning (204).  Some  general  information  on  access  to 

INFR(2019)2222. 

(202) 
(203)  https://www.naturvardsverket.se/en. 
(204)  https://www.boverket.se/en/start/. 
(205)  https://www.domstol.se. 
(206)  The  concept 

in  the  European 
Commission’s 201  communication on EU actions to improve 

is  explained 

in  detail 

In 2022, two priority actions were addressed to Sweden 
about access to justice, namely to (i) better inform the 
public  about  their  rights  in  this  field  and  (ii)  improve 
access  to  courts  for  the  public  concerned  when  it 
comes  to  challenging  administrative  or  regulatory 
decisions.  It  is  concluded  that  no  progress  has  been 
made. The priority actions are therefore reiterated. 

2025 priority actions 

• 

•  Make  spatial  data  more  widely  accessible  and 
prioritise environmental datasets in implementing 
the Inspire Directive, especially those identified as 
high-value  spatial  datasets  for 
implementing 
environmental legislation. 
Ensure  correct  transposition  of  the  revised  EIA 
Directive. 
Improve 
national 
environmental cases by the public concerned and 
eliminate  practical  barriers,  such  as  length  of 
proceedings and excessive costs in some Member 
States. 

access 

courts 

to 

in 

• 

Compliance assurance 

Environmental  compliance  assurance  covers  all  work 
undertaken  by  public  authorities  to  ensure  that 
industries, farmers and others fulfil their obligations to 
protect  water,  air  and  nature,  to  manage  waste (206) 
and to remedy any environmental damage. It includes 
measures  such  as  (i)  compliance  promotion,  (ii) 
compliance  monitoring  (i.e.  inspections  and  other 
checks), (iii) enforcement, that is, steps taken to stop 
breaches  and  impose  sanctions,  and  (iv)  ensuring 
damage  prevention  and  remediation  in  line  with  the 
polluter-pays principle. 

Compliance promotion, monitoring and enforcement 

reasons, 

for  different 

Non-compliance  with  environmental  obligations  may 
occur 
including  poor 
understanding  or  lack  of  acceptance  of  the  rules, 
opportunism  or  even 
criminality.  Compliance 
promotion  activities  help  duty-holders  to  comply  by 
providing  information,  guidance  and  other  support. 
This is particularly important in areas where new and 
complex legislation is put in place. 

environmental  compliance  and  governance  (https://eur-
lex.europa.eu/legal-
the 
content/EN/TXT/?uri=CELEX%3A52018DC0010) 
related  Commission  staff  working  document  (https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010). 

and 

Environmental Implementation Review 2025 – Sweden 

 
 
 
When inspections and other control activities identify 
problems,  a  range  of  responses  may  be  appropriate, 
including  the  use  of  administrative  and  criminal 
enforcement tools. 

Since  the  2022  EIR,  the  Swedish  National  Council  for 
Crime Prevention (Brottsförebyggande rådet (Brå)) has 
continued  to  oversee  and  publish  detailed  crime 
statistics,  including  on  environmental  crimes.  Brå’s 
platform  provides  updated  data  on  the  types  and 
frequencies of environmental offences, the outcomes 
of  legal  proceedings  and  crime  trends  through  2023, 
with  accessible  data  on  their  website  for  public 
review (207). 

It  appears  that 
inter-agency  cooperation  remains 
crucial.  This  includes  involvement  from  SEPA,  county 
local  authorities,  with 
administrative  boards  and 
continued attention being paid to the enforcement of 
waste management and pollution regulations (208). 

The new EU Environmental Crime Directive 

The EU has recently strengthened its legal framework 
on tackling the most serious breaches of environmental 
obligations,  notably  by  the  adoption  of  the  new 
Environmental  Crime  Directive  (ECD)  (Directive  (EU) 
2024/1203)  (209)  and  new  sectoral  legislation  with 
stronger  provisions  on  compliance  monitoring, 
enforcement  and  penalties.  Issues  important  for  the 
transposition and the implementation of the relevant 
new  instruments  are  highlighted  below;  a  detailed 
assessment of these topics will be included in the next 
EIR  once  more  implementation  measures  are  put  in 
place and more systematic information is available. 

The  new  ECD  replaced  the  2008  ECD  and  introduced 
several new offence categories, such as  unlawful ship 
recycling,  unlawful  water  abstraction,  and  serious 
breaches  of  EU  legislation  on  chemicals,  mercury, 
fluorinated GHG and IAS of EU concern. It also covered 
the  establishment  of  qualified  offences,  subject  to 
more  severe  penalties  where  one  of  the  offences 
defined  in  the  Directive  leads  to  serious  widespread 
and  substantial  damage  or  destruction  of  the 

(207)  https://bra-se.translate.goog/bra-in-english/home/crime-

and-
statistics.html?_x_tr_sl=sv&_x_tr_tl=en&_x_tr_hl=it&_x_tr_p
to=wapp. 

Stockholm, 

(208)  For  example,  please  see  ‘ orking  together  to  meet  the 
objectives’  in  SEPA,  Sweden’s  Environmental  Objectives –  An 
introduction, 
p. 6, 
https://www.naturvardsverket.se/publikationer/8800/swede
ns-environmental-objectives--an-
introduction/#:~:text=The%20overall%20goal%20of%20Swed
ish,health%20problems%20outside%20Sweden's%20borders. 
(209)    Directive 2024/1203/EU on the protection of the environment 
https://eur-

through 
law 
lex.europa.eu/eli/dir/2024/1203/oj/eng 

criminal 

2018, 

Sweden  51 

environment.  Concrete  provisions  on  the  types  and 
levels  of  penalties  for  natural  and  legal  persons,  who 
introduced.  Other 
commit  an  offence  were  also 
provisions  will  help  considerably  to 
improve  the 
effectiveness in combating environmental crime of all 
actors  along  the  enforcement  chain.  These  include 
obligations 
resources  and 
investigative tools, specialised regular training and the 
establishment of cooperation mechanisms within and 
between Member States as well as national strategies 
on combating environmental crime. 

to  ensure  adequate 

and 

approaches. 

Member States are required to transpose the new ECD 
into national law by 21 May 2026 and to take additional 
measures  to  more  effectively  combat  environmental 
crime,  in  particular  through  training,  coordination, 
cooperation 
The 
strategic 
including  by 
Commission  will  provide  support, 
facilitating  the  identification  and  sharing  of  good 
practices. Member States are expected  to ensure the 
necessary resources and specialised skills required and 
they  are  invited  to  encourage  their  authorities  to 
support  and  cooperate  with  the  recognised  EU-level 
networks of environmental enforcement practitioners, 
such  as  the  EU  Network  for  the  Implementation  and 
Law (210), 
Enforcement 
EnviCrimeNet (211), 
European  Network  of 
Prosecutors  for  the  Environment (212)  and  the  EU 
Forum  of  Judges  for  the  Environment (213).  The 
for  Law  Enforcement 
European  Union  Agency 
Cooperation and European Union Agency for Criminal 
Justice  Cooperation  mechanisms  for  cooperation  on 
cross-border cases should be used more systematically 
for environmental offences. 

Environmental 

the 

of 

Environmental Liability Directive 

The Environmental Liability Directive (ELD) (214) aims to 
ensure  that  environmental  damage  is  remediated  in 
kind at the expense of those who have caused it, in line 
with the polluter-pays principle. It helps to halt the net 
loss in biodiversity, as well as reducing the number of 
contaminated sites and protecting the environmental 
quality of groundwater and surface waters. The ELD is 

(210)  https://www.impel.eu/en. 
(211) 

LIFE+SATEC 
(https://webgate.ec.europa.eu/life/publicWebsite/project/LI
FE20-PRE-ES-000001/fight-against-environmental-crime-at-a-
strategic-level-through-the-strengthening-of-envicrimenet-
network-of-experts-in-environmental-criminal-
investigations). 

project 

(212)  https://www.environmentalprosecutors.eu. 
(213)  https://www.eufje.org/index.php?lang=en. 
(214 ) Directive 2004/35/EC on environmental liability with regard to 
the  prevention  and  remedying  of  environmental  damage, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02004L0035-20190626. 

Environmental Implementation Review 2025 – Sweden 

 
 
 
a  cross-cutting  tool  and  a  key  enabler  for  better 
implementation of EU environmental law. 

The  ELD  addresses  cases  of  significant  environmental 
damage to protected species and natural habitats, and, 
when  caused  by  operators  carrying  out  certain 
potentially hazardous activities, also damages to water 
and to soil. The Commission has the legal obligation to 
periodically evaluate the ELD. The ELD has undergone 
the  second  evaluation (215),  which  will  be  finalised  in 
2025,  and  which  was  supported  by  an  external 
study (216),  containing,  among  other  things,  evidence, 
views, reports and other relevant information gathered 
from different  stakeholder groups, including Member 
States. 

One  of  the  most  relevant  indicators  in  assessing 
implementation  and  enforcement  of  the  ELD  is  the 
number of environmental damage cases handled under 
the ELD, especially when this number is compared with 
the  previous  reporting  period.  Fewer  ELD  cases  were 
reported  in  the  second  reporting  period  (2013–2022) 
than  in  the  first  one  (2007–2013).  However,  the 
downward tendency in the number of ELD occurrences 
and their overall low number do not necessarily mean 
that the ELD has achieved its objectives, as it needs to 
be 
the  overall  number  of 
environmental damage cases, some of which may have 
been handled under the other liability instruments. 

compared  with 

The ELD has not always been effective in ensuring that 
the  polluter  pays,  because  the  liable  operators  often 
lack  financial  capacity  to  carry  out  remediation 
measures.  While  the  ELD  does  not  provide  for  a 
mandatory  financial  security  system,  it  explicitly  calls 
for Member  States to encourage the development  of 
financial  security  instruments  and  markets,  with  the 
aim of enabling operators to use financial guarantees 
to cover their responsibilities under this directive. 

From  1 May  2013  to  31 December  2021,  Sweden 
reported  two  occurrences  of  environmental  damage 
under  the  ELD  (both  concerning  land  and  water 
damage). In the previous reporting period, there were 
four  occurrences  of  environmental  damage  reported 
under the ELD. 

Sweden does not impose mandatory financial security 
for ELD liabilities. However, insurance for ELD liabilities 
is  available  in  environmental  insurance  policies.  Such 

Sweden  52 

policies provide cover for pollution and other types of 
environmental damage, and gradual as well as sudden 
and  accidental  damage.  However,  demand  for  the 
policies is moderate. 

The 2022 EIR recommended in relation to the ELD that 
Sweden develop a national database of environmental 
damage  cases,  highlighting  cases  under  the  ELD  and 
financial 
providing 
sanctions. There is no information available about the 
progress  made  on  this  priority  action  and,  therefore, 
efforts  to  implement  it  should  continue  along  with 
those addressing the 2025 priority actions. 

information  on  relevant 

full 

2025 priority action 

• 

the 

Encourage  the  use  of  training  programmes 
provided by the Commission (or developed at the 
national level) covering the ELD and its interactions 
other 
with 
liability-related 
to  ensure  more  efficient  ELD 
instruments, 
implementation, 
the 
improve  expertise  of 
competent authorities and raise awareness among 
all stakeholder groups. 

national 

EU-supported environmental capacity 
building 

The  Commission’s  2023  Compact (217)  initiative  to 
identifies  the 
enhance  the  administrative  space 
capacity to lead the green transition as one of three key 
pillars,  along  with  the  public  administration  skills 
agenda  and  the  capacity  for  Europe’s  Digital  Decade. 
Compact also recognises the role of the EIR reporting 
tool in improving environmental governance. The two 
main 
the 
environment  provided  by  the  TAIEX-EIR  PEER  2  PEER 
tool (218).  The  technical  assistance  available  through 
the cohesion policy is subject  to shared management 
and is not dealt with in this subsection. 

capacity-building 

opportunities 

for 

The Commission’s technical support instrument 

The  TSI  provides  Member  States  with  tailor-made 
technical expertise on the design and implementation 
of reforms. The support is demand driven and does not 
require national co-financing. 

(215)  Commission  staff  working  document  -  Evaluation  of  the 

(217)  See  the  European  Commission  web  page  on  Compact 

Environmental Liability Directive, forthcoming 2025. 

(216)  European  Commission:  Directorate-General  for  Environment 
and  Fogleman,  V.,  Study  in  support  of  the  evaluation  of  the 
Environmental  Liability  Directive  and  its  implementation – 
Final  report,  Publications  Office  of  the  European  Union, 
Luxembourg,  2024,  https://op.europa.eu/en/publication-
detail/-/publication/006d90e5-980a-11ef-a130-
01aa75ed71a1/language-en. 

(https://reform-support.ec.europa.eu/public-administration-
and-governance-coordination/enhancing-european-
administrative-space-compact_en). 

(218)  See  the  European  Commission  web  page  on  the  TAIEX-EIR 
PEER  2  PEER  tool  (https://environment.ec.europa.eu/law-
and-governance/environmental-implementation-
review/peer-2-peer_en).  TAIEX:  Technical  Assistance  and 
Information Exchange. 

Environmental Implementation Review 2025 – Sweden 

 
 
 
Sweden  53 

• 

Future  challenges  in  the  air  protection  in  Europe 
(24 November  2022)  with 
the  Czech  EU 
Presidency; 

•  Circular  economy  (in  the  Irish  Midlands)  (4–

6 October 2022); 

•  Climate  adaptation  and  blue 

infrastructures: 
Examples across European regions (30 May–1 June 
2022). 

On  18–21 September  2023,  Sweden  hosted  a  study 
visit  for  Estonian  authorities  on  best  practice  in 
applying  Article 6(3)  of  the  Habitats  Directive  on 
renewable  energy  planning  and  assessment.  France 
(Occitanie)  hosted  a  study  visit  from  the  Västra 
Götaland region in Sweden on Integrating biodiversity 
in  regional  land-use  planning:  data,  decision  making 
and local action in Montpellier, 29 - 31 January 2025. 

2025 priority action 

• 

overall 

national 

Improve 
environmental 
governance,  in  particular  administrative  capacity 
to support the green transition and coordination at 
the regional and local levels. 

capacity  of 

Under  the  TSI  2022,  Sweden  was  granted  technical 
support  for  a  shared  project  with  Finland  on  the 
implementation 
sustainable  green 
development  in  European  Arctic  northern  sparsely 
populated  areas (Northern Sweden Office). In the  TSI 
2024, the Swedish Agency for Economic and Regional 
Growth was granted support for the project ‘Pathway 
to  net  zero:  Driving  Swedish  manufacturing  SMEs 
towards  sustainability  and  competitiveness  in  the 
green and digital economy’. 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

The Commission launched the TAIEX-EIR PEER 2 PEER 
tool in 2017. It aims to facilitate peer-to-peer learning 
among  Member  States’  environmental  authorities 
through  workshops  (single  or  multi-country),  expert 
missions (where a delegation of experts travels to the 
requesting 
institution)  and  study  visits  (where  a 
delegation from the requesting institution travels to a 
host  country).  Flagship  multi-country  workshops  are 
those  requested  by  the  European  Commission  to 
present  new  and  upcoming  environmental  legislation 
and policy in all Member States (219).  

Workshops involving Sweden are as follows: 

•  New  aspects  in  the  cross-border  cooperation 
against  environmental  crime  (19–20 November 
2024); 

•  Online  platforms:  EU  Batteries,  Packaging  and 
(28–29 October 

Packaging  Waste  Regulation 
2024); 

•  Biodiversity,  nature  conservation  and 

large 
predators: Examples across European  regions (4–
6 June 2024); 
•  Best  practice 

in  applying  Article 6(3)  of  the 
Habitats Directive: Practical solutions to carry out 
(25–
impact  assessments  effectively 
Natura 
27 October 2023); 

•  Make  space  for  biodiversity:  Regional  action  to 
empower 
biodiversity 

mainstream 
stakeholders (21–23 March 2023); 

and 

(219)  Flagship multi-country workshops in the reporting period are: 
Recast Drinking  Water Directive (3 April 2025); Environmental 
compliance  and  governance  (18  March  2025);  Planning  of 
Renewable  Energy  Projects  (20  February  2025);  Air  Quality: 
Implementation  of  the  revised  Air  Quality  Directive  (16 
Industrial  safety:  awareness  raising  of 
January  2025); 
emerging risks linked with climate change and decarbonation 
(12 December 2024); Air quality: implementation of the NEC 
Directive  to  further  mainstream  air  and  broader  pollution 
reduction 
(25 September  2024); 
Industrial emissions transposition and implementation of the 
revised  directive  (12 September  2024);  Noise:  progress 
towards  meeting  Member  States’  noise  limit  values  and  EU 
reduction  targets  (5 June  2024);  Best  practice  use  of 

in  agricultural  policy 

environmental footprint methods on the EU market (30 May 
2024); Sustainable finance (9 November 2023); Textile waste 
separate collection, treatment and markets (3 October 2023); 
EU  environmental  funding  and  support  (13 June  2023); 
Advisory service for businesses to go circular (24 April 2023); 
Digital product passport implementation (6 December 2022); 
Public  involvement  in  planning  and  approval  of  renewable 
energy  projects 
(17 November  2022);  Environmental 
compliance  and  governance  (14 November  2022);  Biowaste 
management  (19–20 September  2022);  and 
  Renewable 
energy projects: permit granting processes (13 June 2022). NB: 
The first flagship workshop on zero pollution for air, water and 
soil took place 9 February 2022. 

Environmental Implementation Review 2025 – Sweden 

 
 
 
  
Sweden  54 

Environmental Implementation Review 2025 – Sweden 

 
 
 
 
Sweden  55 

Annex 

2025 priority actions 

Circular economy and waste management 
Transitioning to a circular economy 

• 

 Adopt measures to increase the circular material use. 

• 

• 
• 
• 
• 

• 

• 

Waste management 

Further shift reusable and recyclable waste away from incineration, including through economic 
instruments.  
Improve municipal waste preparation for reuse and recycling.  
Increase the collection and recycling rate of electronic and electric equipment waste.  
Invest in waste prevention measures to reduce the total amount of waste generated.  
Ensure the achievement of the 2025 waste targets, following the recommendations made by the Commission 
in the early warning reports where applicable.  

Biodiversity and natural capital 
Nature protection and restoration – Natura 2000 

Complete the Natura 2000 site designation process.  

Recovery of species  

Strengthen  the  integration  of  biodiversity  actions  into  other  policies  (e.g.  on  energy,  agriculture,  fisheries, 
forestry, urban and infrastructure planning, and sustainable tourism), and promote communication between 
stakeholders.  

•  Reinforce action for habitats and species in unfavourable conservation status, for example through restoration 

measures, increased connectivity, better policy coordination and integration, and increased funding.  

• 

• 

• 

• 

Recovery of ecosystems 

Implement eco-schemes and agri-environmental measures and practices to address the environmental needs 
of Sweden. 
Improve the conservation status of forests by promoting sustainable forest management and ensuring 
compliance with the Habitats Directive before granting/renewing permits for forest logging.  
Implement peatland conservation and restoration measures and include such measures and objectives in the 
national restoration plans.  

Prevention and management of invasive alien species  
Step up implementation of the IAS Regulation, including with regard to enforcement and capacity of 
inspection authorities. 

Zero pollution 
Clean air 

•  As part of the NAPCP, take action to reduce emissions of air pollutants. 
• 

Ensure full compliance with the current AAQD standards, also in light of future stricter requirements under 
the revised AAQD. 

Industrial emissions 

Environmental Implementation Review 2025 – Sweden 

 
 
 
 
Sweden  56 

•  Reduce industrial air pollution damage and intensity. 
•  Reduce industrial releases to water and their intensity. 
• 

Engage with industry and environmental NGOs to ensure proper contribution to and implementation of BAT 
conclusions and ensure timely updates to permits following the publication of BAT conclusions. 
Ensure effective public participation and access to justice in relation to the IED. 

Major industrial accidents prevention – Seveso 
Strengthen compliance with requirements on safety measures to prevent major accidents and ensure 
appropriate preparedness and response in relation to UTEs, in particular as regards reviewing, testing and 
updating EEPs, at intervals of no more than three years. 

• 

• 

•  Complete and implement action plans on noise management. 

Noise 

Water Framework Directive  

Water quality and management 

• 

• 

Improve river continuity and ecological flows, boosting efforts on nature-based solutions to reduce 
hydromorphological pressures. 
Ensure periodic reviews of permits for discharges, abstractions and other water uses, including hydropower 
pressures. 

•  Reduce pollution from nutrients, chemicals,  metals and saline discharges. 
•  Better justify exemptions to the achievement of good status. 
• 
•  Develop more robust programmes of measures, tackle obstacles identified in the implementation of 

Improve the classification of water bodies and strengthen monitoring systems. 

measures and ensure adequate financing for implementation, including through better use of the cost 
recovery and polluter pays principle. 

Floods Directive  

• 

FRMPs should provide details on how the FHRMs were used in the choice of measures and how to consider 
pluvial flooding. 

•  Better explain the choice and implementation of flood prevention and protection measures (prioritisation, 

monitoring, costs of measures). 
Improve public consultation and stakeholder involvement.  

• 

Drinking Water Directive  

• 

Take actions to ensure full compliance with the Drinking Water Directive.  

Nitrates Directive  

• 

Tackle nutrients pollution, especially nitrates from agriculture, through the implementation of the Nitrates 
Directive.  

Urban Wastewater Treatment Directive  

• 

Take  the  necessary  measures  to  ensure  full  implementation  of  the  current  urban  wastewater  treatment 
directive, taking into account the new requirements of the recast directive. 

Chemicals 
•  Upgrade the administrative capacities in implementation and enforcement to move towards a policy of zero 

• 

• 

tolerance of non-compliance. 
Increase customs checks and checks of products sold online with regard to compliance with chemicals 
legislation. 

Climate action 
Implement all polices and measures that are needed to achieve targets laid down in the Effort Sharing 
Regulation (ESR) and the Land Use and Land-Use Change and Forestry (LULUCF) Regulation. More detailed 
priority actions are set out in the assessment of the final National Energy and Climate Plan (NECP).  

Financing 

Environmental Implementation Review 2025 – Sweden 

 
 
 
Sweden  57 

•  Use more national funding (for instance by increasing taxes in favour of the environment and reducing 
environmentally harmful subsidies), EU funding and private funding to help close the investment gap. 

Information, public participation and access to justice  

Environmental governance 

•  Make spatial data more widely accessible and prioritise environmental datasets in implementing the Inspire 
Directive, especially those identified as high-value spatial datasets for implementing environmental legislation. 
Ensure correct transposition of the revised EIA Directive. 
Improve  access  to  courts  in  national  environmental  cases  by  the  public  concerned  and  eliminate  practical 
barriers, such as length of proceedings and excessive costs in some Member States. 

• 
• 

Compliance assurance  

• 

Encourage the use of training programmes provided by the Commission (or developed at the national level) 
and covering the ELD and its interactions with the other national liability-related instruments, to ensure more 
efficient ELD implementation, improve the expertise of the competent authorities and raise awareness among 
all stakeholder groups. 

EU-supported environmental capacity building 

• 

Improve overall national environmental governance, in particular administrative capacity to support the green 
transition and coordination at the regional and local levels. 

Environmental Implementation Review 2025 – Sweden