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Energiföretagen / Swedenergy

Swedenergy represents 400 Swedish companies involved in electricity, heating, cooling supply, distribution and storage.

Lobbying Activity

Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen) and Finnish Energy - Energiateollisuus ry

4 Dec 2025 · Nuclear energy

Meeting with Tomas Tobé (Member of the European Parliament, Shadow rapporteur)

4 Dec 2025 · Research Policy

Meeting with Jessica Polfjärd (Member of the European Parliament)

16 Oct 2025 · 2040 climate target and climate policy

Swedenergy backs 90% climate target but urges credit flexibility

12 Sept 2025
Topic — Proposal to amend the European Climate Law to include the 2040 climate target.
Message — Swedenergy supports the 90% target while recommending the integration of high-quality international emission credits. They also propose separate targets for gross reductions and carbon removals to ensure steady technological scaling.12
Why — A robust target provides regulatory stability and incentivizes investment in domestic energy and industrial adaptation.3
Impact — Fossil fuel industries lose market share as domestic production expands and carbon costs increase.4
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Meeting with Jens Geier (Member of the European Parliament) and Finnish Energy - Energiateollisuus ry

10 Sept 2025 · Exchange on Grid Action Plan

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament) and Finnish Energy - Energiateollisuus ry

10 Sept 2025 · Decarbonation & EU competitiveness

Meeting with Eero Heinäluoma (Member of the European Parliament) and Finnish Energy - Energiateollisuus ry

2 Jul 2025 · Future of Europe's Power System

Swedenergy urges carbon removal integration in EU emissions market

18 Jun 2025
Topic — The European Commission is reviewing the emissions trading system and market stability reserve.
Message — The group calls for integrating permanent carbon removals into the carbon market. They want waste incineration included to create a level playing field. Finally, they demand abolishing rules that penalize companies using bioenergy.123
Why — This would ensure market liquidity and protect the competitiveness of energy producers.45
Impact — Non-recycling waste handlers and landfills would face new, harmonized carbon pricing costs.6
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Meeting with Tomas Tobé (Member of the European Parliament)

12 Jun 2025 · Sustainable Transport

Meeting with Jessica Polfjärd (Member of the European Parliament)

11 Jun 2025 · 2040 climate target

Meeting with Tomas Tobé (Member of the European Parliament)

3 Jun 2025 · Energy Policy

Meeting with Jörgen Warborn (Member of the European Parliament)

21 May 2025 · Energy

Meeting with Pär Holmgren (Member of the European Parliament)

24 Apr 2025 · Meeting with trainees from Swedish Regional Offices to talk about Pär's work in EP

Meeting with Emma Wiesner (Member of the European Parliament)

28 Mar 2025 · Energi 2025 - konferens

Meeting with Jörgen Warborn (Member of the European Parliament, Shadow rapporteur) and Ledger SAS

10 Mar 2025 · Digital Infrastructure

Meeting with Aleksandra Baranska (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Terhi Lehtonen (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Thomas Woolfson (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and

4 Mar 2025 · To hear interest representatives’ view on the Clean Industrial Deal and Affordable Energy Action Plan.

Meeting with Tomas Tobé (Member of the European Parliament)

17 Feb 2025 · Energy Policy

Meeting with Sofie Eriksson (Member of the European Parliament)

13 Nov 2024 · Diskussion om framtidens energipolitisk i EU

Meeting with Karin Karlsbro (Member of the European Parliament)

11 Oct 2024 · Aktuella frågor kring energiomställningen

Meeting with Sofie Eriksson (Member of the European Parliament)

27 Sept 2024 · Energipriser i Sverige och prissättningsfrågor

Meeting with Tomas Tobé (Member of the European Parliament)

30 Nov 2023 · Energy Policy

Meeting with Silvia Modig (Member of the European Parliament) and Finnish Energy - Energiateollisuus ry

21 Nov 2023 · Climate & Energy policy (staff level)

Swedenergy urges separate EU sector for permanent carbon removals

30 Aug 2023
Topic — This consultation assesses the role of carbon capture technologies in decarbonising the EU economy.
Message — Swedenergy proposes creating a separate climate policy sector for permanent carbon removals with its own ambitious targets. They recommend a dual-certificate system for companies and nations to facilitate trade without double counting. The group also advocates for financial incentives to support carbon capture at waste-to-energy facilities.123
Why — These proposals would establish new markets and subsidies to make expensive carbon capture projects profitable for energy companies.45
Impact — Proponents of nature-based solutions might see reduced priority as the industry pushes for technology-based removals.6
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Meeting with Emma Wiesner (Member of the European Parliament)

28 Jun 2023 · talare: Fjärr- och kraftvärmens kritiska roll i ett robust och hållbart energisystem i Sydsverige

Swedenergy urges inclusion of nuclear and bioenergy in NZIA

27 Jun 2023
Topic — The European Union's proposed regulation for strengthening net-zero technology manufacturing ecosystems.
Message — Swedenergy urges including conventional nuclear and bioenergy as strategic technologies. They recommend extending the regulation's scope to 2050 to support long-term investments. The group also advocates for market-driven technology choices over top-down subsidies.123
Why — This would secure investment incentives and maintain European leadership in existing energy sectors.45
Impact — International suppliers of renewable components lose priority to domestic nuclear and bioenergy solutions.6
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Swedenergy urges technology-neutral approach to European heating decarbonization

26 May 2023
Topic — The Commission is developing an action plan to accelerate heat pump deployment.
Message — Swedenergy requests a level playing field for all heating technologies to ensure system stability. They argue the plan should include district heating and industrial waste heat.12
Why — This approach avoids market distortion and prevents excessive new demands on electricity grids.34
Impact — Fossil-dependent countries could lose access to electricity exports if domestic demand spikes.5
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Swedenergy warns against mandatory hedging in electricity reforms

23 May 2023
Topic — Revision of EU electricity market rules to increase resilience and lower consumer costs.
Message — Swedenergy supports short-term market improvements but opposes mandatory hedging. They caution against rushed measures that lack a thorough impact analysis. The group requests optional implementation and alternatives to transmission rights.123
Why — Avoiding mandatory hedging preserves the commercial flexibility and competitive position of Swedish suppliers.4
Impact — Smaller suppliers could face market consolidation and reduced competition under compulsory hedging rules.5
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Swedenergy urges inclusion of waste incineration in EU taxonomy

2 May 2023
Topic — The initiative defines environmentally sustainable activities for investment purposes within the EU.
Message — Swedenergy requests that the incineration of non-recyclable, non-hazardous waste be recognized as a sustainable activity. They propose using energy recovery to prevent landfilling and support the circular economy.12
Why — Including these activities would secure sustainable financing for energy recovery infrastructure and carbon capture.34
Impact — Landfill operators face increased competition as waste is diverted to energy recovery plants.5
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Meeting with Emma Wiesner (Member of the European Parliament)

28 Apr 2023 · Aktuellt i energipolitiken

Meeting with Johan Nissinen (Member of the European Parliament)

19 Apr 2023 · electricity market design

Meeting with Pär Holmgren (Member of the European Parliament, Shadow rapporteur for opinion)

28 Mar 2023 · Carbon Removal Certification

Meeting with Jakop G. Dalunde (Member of the European Parliament)

15 Mar 2023 · Energy Market Design

Meeting with Emma Wiesner (Member of the European Parliament) and Vattenfall

8 Mar 2023 · Elmarknadsdesign

Meeting with Erik Bergkvist (Member of the European Parliament)

7 Mar 2023 · Möte

Swedenergy urges separate, faster certification for industrial carbon removals

28 Feb 2023
Topic — The European Commission is developing a regulatory framework to certify and monitor carbon removals.
Message — The group suggests separating industrial removal from carbon farming to avoid delays. They also advocate for higher 2030 targets and including funding information in certificates.123
Why — Faster certification helps energy companies secure investment and launch large-scale carbon capture projects.4
Impact — Environmental groups lose protections if the industry successfully lobbies to weaken project sustainability criteria.5
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Meeting with Erik Bergkvist (Member of the European Parliament)

31 Jan 2023 · Middag

Meeting with Emma Wiesner (Member of the European Parliament)

31 Jan 2023 · Diskussion om elmarknadsöversyn

Meeting with Jakop G. Dalunde (Member of the European Parliament)

23 Jan 2023 · Transport Policy

Response to Fitness check of how the Polluter Pays Principle is applied to the environment

2 Dec 2022

The Polluter-Pays-Principle (PPP) should be at the core of the EU environmental policy. However, it is badly applied when it comes to plastic pollution. The environmental damage of plastic pollution is not included in the price of plastics and plastics are still far too cheap compared to its impact on the environment. In Sweden, the customers pay a fee for collection and recovery of some types of plastic packages. It has to a certain degree helped push towards better collection and material recovery for these specific packaging plastics (34 percent are recovered). However, most plastics (90 percent, including single plastic packaging with a fee) end up in energy recovery when they could have been reused or ended up in material recovery. The main reason for this is that PPP is not applied to plastic production. Instead, we have policy instruments for waste incineration (taxes and carbon price) without impact on material recovery, which has resulted in an increase of waste crime. The driving force for the criminals is money. When waste is to be recycled or reused, it must first be sorted, disassembled, or otherwise handled. Most of this is done manually, resulting in a high personnel cost. There is thus much to be gained for those who ignore the decisive steps in the circular economy. The cost of handling wastes after criminal activity is often 4-5 times higher than if it were to be handled according to the law. EU is currently focusing on plastic waste collection and recycling which is insufficient when it comes to reducing the high growth rate of plastic production and the volumes of oil and gas that feed the plastic industry. Plastic producers and those who put plastic products on the market currently only pay for the emissions during production while there is no policy to take care of the waste streams in the product chain, especially when the plastic ends up as waste. According to recent research, most plastics produced since 1950 have been discarded (4.9 billion tonnes of 8.3 billion tonnes). Lack of policy instruments according to PPP is seen as the main reason of this. Researchers have also recently shown the nature of carbon lock-in of the plastic industry, and how key actors in the industry are actively pursuing a continued and deeper entrenchment into fossil resource use and dependency. Swedenergy suggest that production of plastics must be among key issues where the PPP is applied. This will force the plastic producers to take actions for solving plastic pollutions, reduce use of fossil fuels and make plastics more reusable and recyclable. That is the best way to force plastic producers to design plastic products which use less fossil fuels, are free of toxins, have a longer lifetime, and can be reused and recycled. Swedenergy suggests that actors who put a plastic product on the market has to pay a fee, enabling to cover costs for sorting systems, material recovery and CCS/CCU. https://www.science.org/doi/10.1126/sciadv.1700782 https://www.sciencedirect.com/science/article/pii/S0301421521002883?via%3Dihub
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Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager) and Finnish Energy - Energiateollisuus ry and

15 Jul 2022 · EU regulation on digital transformation and its impact on the energy sector.

Swedenergy urges fast-tracked certification for industrial carbon removals

2 May 2022
Topic — The European Commission is proposing a regulatory framework to certify sustainable carbon removals.
Message — Swedenergy requests that the certification framework is implemented by 2026 to support early industrial projects. They advocate for separating industrial removals from carbon farming to ensure a quicker certification process.123
Why — This framework would enable member companies to access essential funding and private markets.45
Impact — The carbon farming sector may face slower regulatory progress if decoupled from industry.6
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Response to Methodology for calculating the quantity of renewable energy used for cooling and district cooling

25 Nov 2021

Swedenergy is a non-profit business association for companies that supply, distribute, sell, and store energy - mainly electricity, heating, and cooling. The association has a total of 400 members, which includes state-owned, municipal, and private companies as well as associations within the energy sector. Swedenergy represents more than 35 energy companies that provides district cooling in more than 40 cities throughout Sweden with more than 1 TWh of district cooling deliveries annually. I Swedenergy would like to underline the need of technology neutral methods for calculating the amount of renewable energy used for cooling and district cooling and to achieve an equal level playing field for different actors and cooling technologies in the cooling market. The proposed methodologies do not provide this equal level playing field. Swedenergy has detailed comments on the proposal to the Annex to Commission Delegated Regulation in the attached file.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

24 Jul 2021

Article 3.2 clarify that the focus on the certification should be to fulfil the legislation. Voluntary schemes are an important tool in providing sustainable bioenergy which in turn is important for climate change mitigation. They will however bring significant costs for the economic operators, and this cost must be minimized. With that in mind, it is important that stakeholders do not use the governance structure to promote other agendas and policy goals. It is important that the regulations surrounding the schemes are balanced and cost efficient. The regulation needs to be revised to minimize unnecessary administration and restrictions for certification bodies and economic operators. The certification must be based on legislation, and it should not be over implemented. According to Article 21.3 and 21.4 and Annex IV, nearly all waste and residues from forestry and forest industry have been removed from the list of waste and residues. This will hinder and limit the use of sustainable biomass from the forest value chains that are essential in current and future climate mitigation strategies. It will not only hamper new investment in advanced biofuels but will also halt existing investment, thereby undermining confidence in EU rules. The industry needs sustainable and long-term conditions. Swedenergy urges the European Commission to align the proposed regulation to the agreements in RED II. The European Commission should not go beyond their mandate with regard to implementing rules, as this could damage investors and Member States' confidence in renewable technologies. The proposed list of waste and residues is not in line with RED II. It contains important new elements that go beyond RED II and the European Commission's mandate. The attempt to create a new list of waste and raw materials beside the RED II will cause severe uncertainty for existing and new investments on bioenergy. Swedenergy urges the European Commission to include a comprehensive list of all relevant waste and residues from forestry and forest industry. In short, it is the forest biomass that, for different reasons, is not suitable for industrial use. That includes, but is not limited to, the materials listed in Annex IX, A in RED II. Articles 19 (2.b and 2.m) suggests changes to practically applicable mass balance systems. The limitation on the use of mass balance systems will increase the administrative burden and severely limit the possibility of using more non-food lignocellulosic material. Many production systems handle several types of product groups in a sustainable way, and thus, their operation should not be excluded from certification. Furthermore, the time to achieve mass balance should be one year for all economic operators as 3 months is a very short and unrealistic timeline. The purpose for such a short time is not clear. Article 10.4 clarify that it covers fraudulent process modifications. However, energy efficiency measures can lead to additional residue materials. That should be stated as an exemption in this paragraph. Swedenergy suggests that proper time for implementation must be given. An extensive regulation affecting several levels of actors cannot be implemented immediately. A transition period for voluntary schemes to implement standard is needed.
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Meeting with Kadri Simson (Commissioner)

2 Jul 2021 · Overview on the latest concerning Swedish energy market.

Meeting with Asa Webber (Cabinet of Commissioner Ylva Johansson), Brian Synnott (Cabinet of Commissioner Ylva Johansson)

25 May 2021 · Red II, Climate targets, Energy Efficiency Directive

Response to Guidance on REDII forest biomass sustainability criteria

23 Apr 2021

Swedenergy acknowledges the importance of the guidance to enable robust and harmonised implementation of the new sustainability criteria for forest biomass by Member States and economic operators. However, we are concerned that the draft goes beyond the directive itself. All the parts which do not only specify the directive but takes the regulation further should be removed from the guidance or changed to meet the level of the directive. Due to the detailed and extensive new criteria, it is difficult to confirm that any national legislation is sufficient in all details, and it leaves room to question the fulfilment of the criteria. This sidelines the intention of the risk-based approach, which was the main pillar of the agreement on sustainability criteria legislated in the Renewable Energy Directive. The directive is clear on how the criteria shall be considered in the national legislation. According to the directive, when some of the criteria are noted in the national legislation, it is sufficient. If some of the criteria are not regulated in national laws, it could be concluded that the criteria have not been taken into consideration and that specific criteria must be proved in some other way by the operator. The adequate required level of monitoring is also regulated in implemented national laws and therefore the operators should not be obligated to assess the level by themselves. Forest biomass from areas where Article 29.6(a) does not apply should not per se be declared as ‘high-risk’ as Art. 29.6(b) specifically has been created for these cases to allow for another way of providing evidence of the sustainability of the biomass used on forest sourcing area level. The guidance should be restricted to clarify the criteria on sourcing area-level (Art. 29 6(b)) by giving advice on good practices on how to fulfil the requirements (voluntary certificates, existing reporting systems etc.), not to widen the criteria set in the directive. Some parts of the guidance are defined contrary to how they are defined on the directive. It risks inconsistencies between EU legislations and does not contribute to transparency nor stakeholder confidence in bioenergy. Swedenergy suggests that the inclusion of the following targeted recommendations would improve the document and ease operationalisation of sustainability criteria. Article 4.1(b)(ii) Forest management activities are not driven by the bioenergy sector; for this reason, it is important to specify that the possible negative impacts on biodiversity or soil quality should not be provoked directly by the sector that is regulated by the REDII and present guidance. To precise it, Swedenergy suggest that this must be clarified. Revise the text according to the following suggestion: “forest regeneration is carried out in a manner that at least maintains the quality and quantity of the harvested forest areas, including by ensuring that the forest is allowed a regeneration period of at least five years after the harvesting operation; and there is no biodiversity degradation in the regenerated forest area, including that primary forests and natural or semi-natural forests are not degraded to or replaced with plantation forests”, as a consequence of management activities carried out for the bioenergy sector. Article 4.1(b)(iv) Biotic and abiotic risks must be considered. Removal of residues could be motivated by the need to avoid wildfire or biotic risk. In addition to facilitate the regeneration of forest. The removal of forest residues is often a prerequisite for subsequent soil preparation and planting to be carried out in a good way. Remaining forest residues make it difficult to prepare soil and to find enough good planting points. Art. 8: should be amended with a transitional period to reflect the delays in the publication of the guidance and related delays in national implementation.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

General remarks Electrification driven by high climate ambitions will lead to investments in the energy sector far above 100 bn € until 2045 in Sweden. This indicates large future capital costs. Thus, the taxonomy regulation may assist the transition of the Swedish energy sector. However, since DNSH criteria are set too high, a large part (87%) of the practically fossil-free electricity production and low-carbon heating will fall outside the taxonomy. The proposed criteria put access to green financing at risk and will thus not support the high climate ambitions of Sweden. Instead, the proposal may counter-act its purpose by introducing risk that lead to higher total investment costs. DNSH criteria in the proposal are generally defined without reference to existing legislation. Criteria often define stricter environmental requirements than existing legislation. That introduces a double standard and undermines the environmental relevance of existing EU and national legislation. Without the possibility to refer to decisions of competent authorities on requirement fulfillment, it will be impossible to prove fulfillment of DNSH criteria. It is our strongest advice that every criterion of the delegated acts must refer to relevant EU legislation. Otherwise, the taxonomy will be practically impossible to use. According to a study by Swedenergy, the effects of the taxonomy on the financial conditions for green investments are far reaching and impossible to quantify. The report is included in the attachment (in Swedish). Swedenergy fears that the proposal has much larger impact than intended, which leads us to the conclusion that the delegated act goes beyond the mandate of the Commission. Judging from the proposed technology-specific criteria, Swedenergy concludes that the principle of technology neutrality (Article 19.1.a) has not been respected. Hydropower Hydropower is an important resource to combat and adapt to climate change and it is unfortunate that the proposal will increase the costs for operation and modernization of hydropower. The detailed criteria listed under 4.5 DNSH#3 are particularly problematic, because the taxonomy users cannot be expected to assess relevant biological and hydromorphological mitigation measures. Such judgement requires comprehensive analysis both locally and on a system level and can only be made properly by an environmental court. Swedenergy strongly recommends that these criteria are replaced by references to relevant EU legislation, which is implemented in national law to assure long-term sustainability of European waters. Bioenergy Bioenergy must be considered a long-term renewable energy source that enables substantial contribution to climate mitigation. Bioenergy used in the Nordic countries are produced from waste and residues and is essential to deliver on climate neutrality. District heating and cogeneration are capital intensive activities that require long-term investment conditions. Defining heating, cooling and electricity from bioenergy as transitional causes a major risk for the lenders to bind its capital to an activity that requires long-term obligations. The criteria proposed by the Commission will go beyond provisions in the RED Directive. This will cause overlap and confusion between the Taxonomy and relevant EU law. Technologies outside the proposal The Commission has already underlined that waste-to-energy has a role to play in the circular economy. The Commission should further investigate, and invite the Platform on Sustainable Finance to consider, under what conditions waste-to-energy should be considered taxonomy-eligible. Swedenergy also notes that nuclear power is not included in the proposal since the investigation on DNSH-criteria for nuclear power has not been completed. Swedenergy regrets that not all relevant technologies that contribute substantially to climate mitigation are managed collectively in the same delegated acts. Please see attachment for details.
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Response to Updating the EU Emissions Trading System

24 Nov 2020

All feedback is given in the attached position paper.
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Meeting with Brian Synnott (Cabinet of Commissioner Ylva Johansson)

18 Nov 2020 · Taxonomy/Sustainable finance

Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

About Swedenergy Swedenergy is a Swedish association for about 400 companies producing, distributing, selling and storing energy. Our aim is from knowledge, a holistic approach on the energy system and in collaboration with our surrounding environment develop the energy sector – to the benefit for all. Swedenergy supports an ambitious increase of the climate goal for 2030 Swedenergy is a strong supporter of the 2050 climate neutrality target, and of an increased 2030 climate goal ambition of at least 55 per cent. Further expansion of climate-friendly electricity, heating and cooling is an indispensable path for the EU, since reducing GHG emissions requires urgent and far-reaching action. Swedenergy believes option 2 should be considered Swedenergy believes option 2 on the introduction of non-regulatory alternative policy instruments should be considered since we still are in an implementation phase of the latest revision of the energy efficiency directive from 2018. EU Commission should address the need of adequate implementation in Member States of the recent revision before proposing new regulatory measures. We are questioning more administrative burdensome detailed energy efficiency regulatory measures which lacks cost-efficiency. One such example is the rules on individual heat metering at apartment level in the present directive which is a counterproductive energy efficiency regulation and which lacks cost-efficiency. We believe further energy efficiency measures instead should focus on efficient measures such as ecodesign and energy labelling of products. Any further energy efficiency measures must also be better linked to present regulations and policy tools where there is a lack of coordination between such as energy performance certificates for buildings, energy mapping regulations and inspection requirements. Maintain present energy efficiency targets Swedenergy believes that target levels of the 2018 directive on energy efficiency should be maintained and that the increased climate ambition should be borne by the climate legislation, i.e. the Effort Sharing Regulation (ESR) and the EU ETS. We are against roof targets for energy efficiency which limits the energy use as such and believe that an energy intensity target gives better conditions to take into account energy efficiency in the energy system in a holistic way. Swedenergy believes carbon pricing to be the most efficient tool to foster energy efficiency and renewable energy. Therefore, we also propose that the EU ETS should be extended to cover more sectors, inter alia by including the entire heating sector. We also think it is necessary to have a coherent framework where the different legal frameworks on energy efficiency, energy performance of buildings, renewable energy and emission trading are better aligned to each other. Further energy renovation measures should include a district approach Swedenergy believes a “district approach” concept with an energy systems perspective should be introduced in further energy renovation measures. The district approach refers to the holistic renovation schemes which are applied to a number of buildings in a pre-defined spatial area, such as districts or neighbourhoods, which also includes finding the most viable efficiency measures from an energy systems perspective. Measures should also be based on more efficent use of the actual used energy not on "purchased energy", and be based on technology neutrality. On revision on primary energy factor (PEF) On Primary Energy Factor (PEF): any review of the values should be based on a solid assessment of the evolution of the power and energy mix. It should be in line with standard FprEN 17423 to determine PEF and CO2 emissions.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Finnish Energy - Energiateollisuus ry and Nordenergi

24 Apr 2020 · Green deal, taxonomy, carbon pricing

Meeting with Helena Hinto (Cabinet of Commissioner Kadri Simson), Laure Chapuis (Cabinet of Commissioner Kadri Simson) and Finnish Energy - Energiateollisuus ry

24 Apr 2020 · climate ambition, sustainable financing

Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

Swedenergy would like to take this opportunity to give some recommendations to the Commission’s future work with the pending delegated acts, in view of the proposals in the TEG report. TEG proposes a threshold of 100 gCO2/kWh, under which energy production does contribute significantly to climate mitigation. The threshold will be lowered every five years. This threshold is reasonable and will stimulate a development towards a climate neutral economy within the EU by 2050. TEG proposes a threshold of 262 gCO2/kWh over which energy production is considered causing significant harm to other environmental objectives. Between 100 and 262 gCO2/kWh, TEG considers energy production not contributing significantly to climate mitigation nor causing significant harm to other environmental objectives. This is surprising to Swedenergy since we believe that the emission levels in the interval of 100 to 262 gCO2/kWh will not be enough to reach EU’s climate targets. The level of 262 gCO2/kWh should be the same as, or very close to, the level for significant contribution to climate mitigation (100 gCO2/kWh). Although the TEG clearly state their ambition to use technology-agnostic screening criteria, a large part of their criteria is in fact technology specific. Swedenergy urges the Commission to express its technical screening criteria as technology neutral as possible. One example is that waste management is expressed to be an issue for some technologies but not for other. Recommendations for the future process: • General screening criteria should be developed based on the EU’s climate targets and the UN SDGs as boundary conditions. This is how the 100 gCO2/kWh has been defined. However, the DNSH criteria do not always follow such methodology, instead it starts from technology specific practices, policies and viewpoints. • When needed, technology specific screening criteria may be developed based on examples of best practice national regulation, considering that regulation often is defined as “no harm” rather than “no significant harm” criteria. • The exemption for hydropower facilities with a power density above 5 W/m2 to conduct the PCF or GHG Lifecycle Assessment should be kept. • In line with article 14.1.d) of the agreed taxonomy regulation, the technical screening criteria on bioenergy should, where relevant, refer to the existing definitions, concepts or criteria in Directive (EU) 2018/2001 (RED II). The Commission should thus disregard TEG’s proposed definition of waste heat and the proposal on cascading the use of biomass. Cascading use of resources may be a good principle, but a regulation would seriously risk inhibiting bioeconomy innovation. • The heat and electricity generated in waste-to-energy plants shall be regarded as waste energy, provided that the wastes have gone through collection, sorting and material recovery. We suggest development of an additional criteria to prohibit investments on new landfills for waste that have not gone through collection, sorting and material & energy recovery. • Nuclear power competence is included in the Sustainable Finance Platform to be established in the fall of 2020. Swedenergy proposes that competence from the nuclear waste management programs of the Nordic countries is included in the expert group. • Sustainability criteria for nuclear power should be developed through a graded approach. The sustainability of a once-through fuel strategy of a light-water reactor fleet can be described in a first stage, whereas the sustainability of closed fuel cycles and Generation IV systems etc. could be evaluated further on. • Criteria for heat pumps should also take into account the use of large-scale heat pumps installations in district heating systems and premises and not be limited to capacity thresholds set in the Ecodesign Directive.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Finnish Energy - Energiateollisuus ry and

4 Mar 2020 · Green Deal priorities

Response to Climate Law

31 Jan 2020

See feedback in attached file.
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Response to Fitness Check of the Water Framework Directive and the Floods Directive

17 Nov 2017

Swedenergy, representing just under 400 Swedish energy companies, welcomes the fitness check of the Water Framework Directive. We are very supportive of the approach to have quantitative assessments of actual costs and benefits including impact on businesses. Many businesses and other parts rely on electricity from hydropower and that perspective also needs to be taken into account. In any evaluation of the Water Framework Directive an analysis of the harmonisation with the various legislative EU initiatives regarding renewables and climate is necessary. Since in order for the EU to reach the renewable and climate target a significant contribution is needed from Europe’s hydropower plants. We therefore also think it is of outermost importance that the work of the European Commission on the Water Framework Directive is coordinated between the Directorate-General for Environment and for Energy.
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Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström) and Swedish Forest Industries Federation

26 May 2016 · New sustainability criteria for biomass

Meeting with Miguel Arias Cañete (Commissioner) and Confederation of Swedish Enterprise and

7 Mar 2016 · Round table : European Energy Transition from a Swedish perspective