Publications and Position papers

The Confederation of Swedish Enterprise on the revision of the Ambient Air Quality Directives

The Confederation of Swedish Enterprise’s views on proposed changes to the General State Aid Block Exemption (GBER) to support green and digital transition

Main points regarding the anti-coercion instrument

The Confederation of Swedish Enterprise´s detailed position on digital product passports

Letter to the Commission on the delegated regulation on establishing a RRF Scoreboard

Comments on the delegated regulation on establishing a Recovery and Resilience Facility (RRF) Scoreboard

European business on current competition issues.pdf

Referral response – Modification of the greenhouse gas emissions trading scheme

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 tightened 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. Swedish Enterprise therefore believes that greater focus on cost efficiency would have been welcome when the European Commission allocated emission reduction targets between trading and non-trading sectors. The significant increase in the burden on the trading sector means that it will be unnecessarily costly to achieve the 55 per cent. Swedish Enterprise has also previously expressed strong support for the introduction of a national minimum tax on CO2 across the Union. The European Commission has chosen instead to proceed with a proposal for a new emissions trading system for heating buildings and for transport. This new system risks creating significant difficulties for Sweden, not least by adding another instrument to the wide range of instruments that already regulate the Swedish transport sector. Furthermore, we see a risk that costs are stacked on top of each other. Finally, Swedish Enterprise believes that the design of the proposed social climate fund should be changed. In its current form, Swedish companies and households will have to bear a significant burden to finance the transition not only in economically weaker parts of the Union but also in countries such as France.

The Arctic’s importance in climate change mitigation and sustainable economic development rightly recognised in the EU’s new Arctic policy

Consultation response to the Platform’s proposals for technical screening criteria linked to environmental objectives 3–6