The Confederation of Swedish Enterprise supports the goal of the EU achieving net zero by 2050, and we actively contribute to discussions on how the EU can best achieve the tougher 2030 goal. The cornerstones of Sweden’s and EU-wide climate policy must be based on cost-effectiveness and policies that strengthen competitiveness and avoid carbon leakage. It is therefore vital to ensure that the Renewables Directive also contributes to these goals in the most cost-effective ways possible.
Swedish Enterprise is critical of the Commission presenting proposals for a revised directive, including sustainability criteria for bioenergy, when the previous version of the directive in the process of being implemented. It would have been preferable to evaluate the changes that are currently being introduced before proposing new changes. In addition, Swedish Enterprise wishes to express the following views on the European Commission’s proposals for the energy efficiency directive:
• It is undesirable for the EU to regulate member states’ energy mix beyond encouraging the use of fossil-free energy as this results in considerable challenges to security of supply and reduces the cost-effectiveness of transition.
• Swedish Enterprise believes that all fossil-free energy resources will be needed to meet increased demand for electricity and that it is therefore unwise to create different conditions for different types of fossil-free energy. EU regulations should have a technology-neutral starting point.
• The introduction of requirements regarding the types of energy sources that users must consume risks increasing costs for consumers without these types of production increasing.
• The proposal for new sustainability criteria and rules for bioenergy is too detailed and entails reduced scope to use bioenergy; and where its use remains possible, it will be more expensive, thereby undermining business’ capacity to transition.