The Confederation of Swedish Enterprise’s position on the proposed Directive on Soil Monitoring and Resilience

Swedish Enterprise wishes to present the following opinions, which are described in more detail below.

• Risk of a non-deterioration principle when one unfulfilled criteria leads to unhealthy soil

• Upholding the principle of subsidiarity and limiting the use of Delegated Acts

• Spatial planning risks being jeopardised if demarcations are not made

• Giving due consideration to naturally high background levels

• The Aarhus Convention provides sufficient protections for environmental organisations to express opinions

• Unclearness regarding sanctions against natural and legal persons

• Respecting all sustainability aspects of land use and placing a greater focus on increasing knowledge of soil health