Additional comments to the replies to the Commission public consultation’s questionnaire and free text replies

The Confederation of Swedish Enterprise (CSE) strongly supports the EU’s goal of reaching climate neutrality by 2050, as well as the 2030 interim emission reduction ambitions set out through the Fit for 55 legislative package. In the process of reaching this goal, the businesses will – and must – play an essential role in delivering the required capital, technologies, products, and innovations needed. While the Swedish Enterprise sees big opportunities for businesses in the transition to climate neutrality, it is also important that the fundamental principles of cost efficiency and competitiveness enshrined in the EU Climate Law and the European Green Deal guide the EU process going forward. Ambitious climate actions can be combined with high level of competitiveness of European industry, and with continued prosperity and growth of the EU market. These are key components in a sustainable transition.

This consultation will, as stated by the European Commission, start a process to establish a 2040 climate target putting the EU firmly on a path towards climate neutrality by 2050. It will also be supported by an in-depth impact assessment, which will inform a draft law setting the 2040 target. We welcome the possibility to give the views of the Confederation of Swedish Enterprise concerning the 2040 climate target.

The Confederation of Swedish Enterprise welcomes the foresight in establishing a new interim target for 2040 – a long-term approach and forward planning is decisive for businesses work towards climate neutrality. However, current targets for 2030 and supporting Fit for 55 regulatory and economic instruments guiding the transition towards climate neutrality by 2050 are due to be implemented in practice this year and onwards during the next few years to come. Consequentially, thorough impact assessment of the effects of the new target and supporting regulatory and economic instruments must run parallel to the process of establishing new interim targets for 2040. Where needed, the EU Commission and the Member States must also put forward appropriate better regulation reforms and new actions to create the right conditions for the EU to reach the already established targets for 2030. In particular, access to fossil free and reliable energy at an internationally competitive price level is crucial to enable the transition and fulfillment of the 2030 objectives.

Below, we list the main principles needed to take into consideration when realizing the 2040 climate target and supplementary measures.

• An energy and climate framework 2040 and supplementary measures to reach its objective should be technology neutrality, cost-efficient and market based. Sub-optimization in the choice of measures and use of overlapping instruments should be avoided.
• European businesses are at the forefront globally in providing solutions to reduce emissions and provide new innovative solutions to improve sustainable production. The demand for such solutions is growing and this means opportunities for European businesses.
• While promoting ambitious climate policy targets, it is essential to promote competitiveness of European businesses and continuously assess the established policies to that end. Only by demonstrating that sustainable transition can harmoniously coexist with competitiveness, growth and prosperity, will the EU effectively inspire others to accelerate their contribution to the Paris agreement.
• The transition to climate neutrality still needs both the development of new innovations and the operationalization of new technologies. This requires effective use of both public and private investments.

In Annex 1 below, we are also providing some supplementary comments to some of the sections/specific questions in the consult: