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Swedish Association of Mines, Mineral and Metal Producers

Svemin

Svemin represents the Swedish mining and mineral industry to ensure competitive business conditions.

Lobbying Activity

Meeting with Stéphane Séjourné (Executive Vice-President) and

18 Nov 2025 · Exchange of views with industries in the raw materials value chain on current challenges and possible solutions to diversify and secure access to raw materials in view of the REsourcEU plan

Meeting with Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen) and European Association of Mining Industries, Metal Ores & Industrial Minerals and

3 Oct 2025 · Tripartite contracts – Affordable Energy Action Plan

Meeting with Petr Bystron (Member of the European Parliament) and International Copper Association Europe and

9 Apr 2025 · European single market

Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and European Association of Mining Industries, Metal Ores & Industrial Minerals

28 Jan 2025 · Swedish mining sector, mining in Europe

Meeting with Nicola Beer (Member of the European Parliament, Rapporteur)

21 Sept 2023 · Critical Raw Materials Act (meeting held by parliamentary assistant)

Meeting with Emma Wiesner (Member of the European Parliament)

29 Jun 2023 · talare:från gruvan till dig - gröna värdekedjor i en geopolitisk brytningstid

Meeting with Abir Al-Sahlani (Member of the European Parliament) and Confederation of Swedish Enterprise and

29 Jun 2023 · Samtal om viktiga EU-frågor för näringslivet

Response to 2040 Climate Target Plan

21 Jun 2023

A sustainable green transition requires sustainable metals and minerals. Sweden has long been Europes leading mining nation and accounts for a significant part of the EUs production of metals and minerals.To meet the goal of net-zero emissions globally, six times more metals and minerals will be needed compared with today and many times more for some specific metals critical to the clean energy supply. The demand for critical and strategic metals and minerals risks becoming a bottleneck and will set the pace for the green transition.The EU depends heavily on imports for the many metals and minerals needed for new, climate-smart technology such as wind turbines, solar panels, and electric cars many of these are produced in countries with low environmental standards and poor working conditions. Import dependence also poses a risk from a security policy perspective, which is reflected in the Critical Raw Materials Act. Sweden has the potential to mine many metals and minerals critical to the clean energy supply and innovation required for the green transition. Half of the metals and minerals on the EUs list of raw materials considered critical for our society and welfare have been found in the Swedish bedrock. The mining and mineral industry were among the first sectors to develop a Climate Roadmap in Sweden. The sectors climate roadmap describes developments within the sector and how the goal of fossil-free mining by 2035 and the goals of climate-neutral processes and fossil-free energy use by 2045 will be achieved. The report also outlines the obstacles, challenges, and needs in implementing the plans. Please find the Climate Roadmap attached as a complement to the consultation.
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Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur)

27 Apr 2023 · Breakfast event “How to secure a sustainable and resilient supply of raw materials for the EU – reflections on the CRM act”

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager) and European Association of Mining Industries, Metal Ores & Industrial Minerals and Boliden Group

19 Dec 2022 · Critical raw material

Meeting with Ylva Johansson (Commissioner) and Boliden Group and Luossavaara Kiirunavaara Aktiebolag

19 Dec 2022 · critical raw materials

Meeting with Asa Webber (Cabinet of Commissioner Ylva Johansson)

6 Dec 2022 · CRM

Response to Carbon Border Adjustment Mechanism

18 Nov 2021

Properly designed, a CBAM mechanism can be an important step towards levelling the playing field for European industry against competitors outside the EU. In addition, CBAM can play a role in the global climate transition needed to achieve the objectives of the Paris Agreement. For these reasons, Svemin is in favour of a CBAM mechanism. At the same time, the devil is in the details, and there are still many details of the Commission's proposals that are unclear. Cost increases can put companies at a competitive disadvantage from a value chain perspective. CBAM fails to address the risk of carbon leakage as long as exports outside the EU are not covered. More expensive European products on third-country markets are affecting the competitiveness of European companies and also the climate, as these products can often displace more carbon-intensive products from the market and thus contribute to global climate benefits. Making it difficult for European companies, not least Swedish companies, to export outside the EU is not good climate policy. In order to actually address the risk of carbon leakage and the risk of European climate-efficient products being outcompeted by more climate-intensive products on the world market, exports outside the EU must also be addressed in CBAM. Full evaluation of the system is required before free allocation starts to be phased out. CBAM is a completely new unproven system and can be expected to produce unexpected and/or undesirable effects, and it is necessary for the system to be thoroughly evaluated and any necessary adjustments to be made before the start of the phasing out of the free allocation. Different sectors have different emission reduction potential, so differentiation of the speed at which free allocation is phased out may be necessary from this perspective and a different competitive situation. Indirect costs need to be managed in CBAM. An important part of the industry's transition to reduce fossil emissions is electrification. Electricity demand will increase sharply as fossil energy is phased out. Sweden already has largely fossil-free electricity, but since the system is physically and market-linked to countries that have fossil electricity production, marginal pricing means that fossil electricity production in the system determines the price. As the price of emission allowances in the EU ETS is expected to continue to rise, the possibility of compensation for the indirect effect of the carbon price on the price of electricity is becoming increasingly important, and this needs to be addressed in CBAM. Risks and question marks about the methodology of emissions in third countries and exemptions for some countries need to be clarified. A big question mark is how emissions in third countries can be practically measured and here we see risks. Actual measurement of emissions risks leading to technical and administrative problems. Methodology for this needs to be developed properly and will take time The impact of the inclusion of electricity in CBAM on European industry needs to be analysed, with a particular focus on cost and security of supply. Revenue from CBAM should go to climate action. Contrary to the current proposal, we advocate that the funds raised by CBAM should go to climate action, not to the general budget of the European Union. This is in order to reinforce the climate impact of the instrument, but also to reduce the risk that the instrument is seen as protectionism in the outside world and thus reduce the risk of trade conflicts.
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Swedish mining industry urges EU to protect industrial tax breaks

18 Nov 2021
Topic — The consultation reviews energy taxation rules to align them with EU climate goals.
Message — Svemin calls for maintaining minimum tax levels for industrial energy and mineralogical processes. They also seek to avoid double taxation on fossil-free hydrogen production.123
Why — Maintaining these tax exemptions would lower operational costs and protect the industry's global competitiveness.4
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Swedish mining association warns energy caps hinder electrification

18 Nov 2021
Topic — The European Commission is revising the Energy Efficiency Directive to meet 2030 climate targets.
Message — Efficiency must support climate neutrality rather than imposing absolute energy caps. The association proposes formulating the target as a relative measure to enable electrification.123
Why — Removing absolute energy limits allows the industry to expand production through fossil-free electrification.45
Impact — Global climate goals suffer if EU restrictions increase reliance on unsustainable mineral imports from abroad.6
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Swedish mining industry urges technology neutrality in energy rules

18 Nov 2021
Topic — The European Commission is revising rules to increase renewable energy targets for 2030.
Message — They advocate for a technology-neutral approach that includes all fossil-free energy resources. The group opposes binding targets for hydrogen use and restrictive bioenergy limitations. Key regulations should stay in the main Directive rather than delegated acts.123
Why — Greater flexibility in energy choices would ensure more cost-effective operations for mines.45
Impact — Renewable energy developers may face increased competition from other non-fossil energy sources.6
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Ambitious climate targets dramatically increase the demand for metals and minerals for climate technologies. Good conditions for the European metal and mineral industry could increase the EU's self-sufficiency of sustainable metals and minerals, and reduce dependence on unsustainably sourced metals and minerals from geopolitically unstable countries. The EU ETS is the most important tool for reducing CO2 emissions from the power and process industry. In reviewing the EU ETS, it is important to focus on the international competitiveness of EU industries. Being competitive through the green transition is crucial - unprofitable companies will not be able to make the necessary investments to become climate neutral. The differences in climate policy between the EU and key competitor countries are already causing consequences for Swedish industries with carbon leakage. A review of the EU ETS and the introduction of CBAM still need to address the risk of carbon leakage, including for exporters to third countries. The raw material industry is highly exposed to a significant risk of both direct and indirect carbon leakage and cannot pass on costs to customers when prices are set on the global market. At present, there is no additional willingness to pay for green metal and mineral products. It is important for the EU ETS to ensure the basis for stable and coherent investment conditions for industry that allow the transition to low-carbon technologies, in order to achieve the climate goals. The link between free allocation and energy efficiency measures risks being counterproductive. CO2 emissions do not automatically decrease with reduced energy consumption – since electrification is the main key to decarbonise industry, reducing carbon emissions will rather require increased energy use. If free allocation is to be conditioned to certain types of measures, it should instead be related to emissions reductions. A thorough evaluation of CBAM is required before free allocation is phased out. Different sectors have different emission reduction potential, so differentiation of the speed at which free allocation is phased out may be necessary from this perspective, as well as different competitive situations. Technology-neutral product benchmarks are needed to benefit frontrunners in the climate transition. Product benchmarks should be reassessed to cover all relevant facilities and reflect the latest data, technological innovations and best available technologies. Svemin welcomes the Commission proposal in this regard, and underline the importance that all benchmarks are revised from this perspective, not only certain ones picked out by the Commission on arbitrary grounds like in the past. The system of indirect costs should be harmonised. To achieve the industry's climate targets, electrification is key. The current model of member states' ability to compensate for the indirect costs of certain sectors, but not others on arbitrary grounds, distorts the competitive situation between companies in the EU and risks hindering electrification as a means of climate neutrality. It is important to understand that fossil-free electricity is also affected by the price of emission allowances due to the marginal cost pricing of electricity. Indirect compensation should be also counted as a climate action. The carbon capture and storage (CCS) proposal needs to be recast with regards to transport by other means than through pipeline, in particular shipping, so as not to discourage the necessary investments in full-scale CCS technology. The proposed increase in funds for the Innovation Fund is positive, but there is a need to increase the funds even more to meet the innovation needs of the industry's climate transition. A more thorough analysis is needed for the inclusion of shipping in the current ETS, as well as the new ETS for road transport, with regards to the impact of competitiveness for industry located in the far north of the EU.
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Swedish Mining Industry Warns Taxonomy Criteria Threaten Green Transition

18 Dec 2020
Topic — The consultation defines technical screening criteria for environmentally sustainable economic activities within the EU.
Message — Svemin requests revising criteria for hydropower and biofuels to support their fossil-free mining targets. They argue that excluding Sweden's current energy mix jeopardizes the industry's ongoing transition to net-zero. The group also advocates for classifying advanced biofuels in transport as sustainable investments.12
Why — Ensuring current electricity sources are deemed sustainable protects the industry's access to green investment.3
Impact — Supporters of strict zero-tailpipe emission standards lose if biofuels are granted sustainable status.4
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Swedish miners urge sustainable land use over land take targets

10 Dec 2020
Topic — The European Commission is consulting on a strategy to restore degraded EU soils.
Message — Svemin suggests replacing 'no net land take' targets with 'sustainable land use'. They argue that member states should remain responsible for setting soil quality standards.12
Why — National standards allow the mining industry to avoid restrictive, one-size-fits-all EU regulations.3
Impact — Environmental groups lose a binding, uniform legal framework for soil protection across Europe.4
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Swedish miners demand flexible nature restoration targets

1 Dec 2020
Topic — The European Commission is proposing legally binding targets to restore degraded ecosystems.
Message — Svemin advocates for a system based on the sustainable use of land and water rather than strict conservation. They urge the EU to adopt flexible instruments like ecological compensation and avoid setting restoration baselines as pristine nature.123
Why — This approach would reduce legal uncertainty for mining permits and lower administrative costs for operators.45
Impact — Environmental groups lose strict legal safeguards if restoration targets are adapted to industrial land use.67
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Response to Arctic matters and the Northern Dimension - Update of the EU Arctic policy

1 Dec 2020

We take the opportunity to contribute with relevant information since Sweden is one of the Arctic states, and since Sweden is also one of the EU’s most significant mining countries and with the majority of the operating mines located in the Arctic region. The parts of Arctic policy that are most important to the Swedish mining industry concern indigenous peoples, climate change and biodiversity. Please see in the attached file.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

The EU-Commission has recently acknowledged the importance of critical minerals and metals for the green transition. Sweden has resources of more than 50% of the critical raw materials identified by the Commission. The Swedish Association of mining, minerals and metal producers, Svemin, has already adopted a roadmap to reach fossil-free mining operations by 2035 and climate neutral processing by 2045. We are ready to ensure a sustainable supply of raw materials. Climate transition and competitiveness must go hand in hand When considering a revision of the EU ETS, it is essential to highlight the international competitiveness of the EU industries. It is companies, not Member States, which will make the investments required to achieve the green transition. Unprofitable companies will not be able to make the necessary investments. Industry within the EU ETS is already responsible for a large share of meeting the overall reduction target. To reach net zero by 2050, all sectors–and all member states–must take an increased share of the responsibility. An increase of the 2030 target cannot be carried by the ETS sector alone, it must be distributed between ETS sectors and the non ETS sectors in a cost-efficient way. The risk of carbon leakage for exporters to third countries must be addressed The differences in climate policies between the EU and important competitor countries are already today causing consequences for the Swedish industries with carbon leakage. In a revision of the EU ETS Directive and the introduction of a CBAM, the risk of carbon leakage must still be handled, also for exporters to third countries. The raw materials industry is highly exposed to a significant risk of both direct and indirect carbon leakage and unable to pass through costs to customers as prices are set on the global market. The indirect costs for industry of a higher electricity price need to be considered To reach the industry’s climate targets, electrification is the key. We suggest the Commission explores the possibility to harmonize the system for compensation of indirect effects. The current system benefits member states which have yet to transform their power sector and those, who have already shifted from coal and gas lack the necessary funds to compensate for indirect costs. It is important to understand that on the electricity market, fossil-free electricity is also affected by the cost of emissions, due to the marginal cost pricing of electricity. Industry in e.g. Sweden still pays the price of the coal and natural gas in the system, even if the electricity is fossil free and this is not compensated in Sweden. A harmonization would rectify this. A need to revise the system’s own mechanisms of benchmark The ETS product benchmarks which are in the center of the ETS design, need an urgent redesign, taking into consideration product substitution and to prevent over-allocation of free allowances to polluting industries. An example from the Swedish mining industry, where despite being substitutes to sinter, LKAB’s pellets installations are prevented from entering the sinter benchmark. The ETS-system should favour the use of pellets over its more carbon-intensive substitute, sinter. To include new sectors in the EU-ETS needs a thorough impact assessment Considering inclusion of more sectors into the EU-ETS system needs a thorough impact assessment as it will likely impact the pricing of the allowances and have an indirect effect of cost for the industries and others, e.g cost of transport. These indirect effects and compensation need to be considered. The existing ETS-system must remain functional until, e.g. introduction of the CBAM, has been proved effective. If the free allowances are replaced by CBAM it will affect the costs of industries. A temporary weakening of competitiveness can lead to irreversible effects. The current allowances scheme must retain until the new system offers an effective and fair alternative.
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Swedish miners urge flexible, risk-based water pollution standards

20 Nov 2020
Topic — The European Commission is revising lists of pollutants for surface and groundwaters.
Message — Svemin requests a risk-based approach that accounts for local background concentrations of naturally occurring metals. They advocate for updated methodologies to prevent overestimating the biological impact of minerals. They also emphasize balancing environmental benefits with the economic costs of industrial operations.123
Why — Mining companies would avoid restrictive project bans and reduce their overall compliance costs.45
Impact — Environmental ecosystems may lose protection if safety margins from the precautionary principle are reduced.6
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Response to Climate Law

30 Apr 2020

Minerals, metals and advanced materials have a central role in the green transition, for example in the energy and transport sector. Ensuring a sustainable supply of raw materials in Europe is crucial for Europe's industrial leadership and to achieve a climate-neutral, resource-efficient and competitive economy. Svemin welcomes the Commission's proposal on a new 2050-target, ensuring that the EU will be the world's first climate neutral continent. This is in line with the Swedish mining and mineral industry's climate targets and roadmap to achieve fossil-free mining operations by 2035 and climate-neutral refinement processes by 2045. The mining and minerals industry is optimistic that the climate transition will be successful. However, the devil is in the details, and policy design will be crucial in order to support, not undermine, this transition. In this context Svemin would like to highlight certain key aspects that need to be addressed in the Climate Law: 1) Climate transition and competitiveness must go hand in hand. It is crucial, both for the climate and economy, that in the transition to become climate neutral, the industry can maintain and even improve competitiveness. Boosting the European economy will be of utmost importance considering the ongoing pandemic and the steep economic downturn which follows in its tracks. 2) The 2050-target must be reached in a fair and cost efficient way. In the current proposal, the aim is to reach the climate neutrality goal collectively at European level, which creates a serious risk for free riding among member states. This also contradicts the principle of not punishing first movers – to get the incentives right to benefit the first movers, not holding them back and/or punishing them, is crucial for the green transition and to achieve the EU climate targets. In the spirit of fairness and solidarity, all member states should reach climate neutrality by 2050. 3) The Commission proposes that assessments on how to adapt current climate legislation to a more ambitious 2030-target shall be made by June 2021. In this context it is crucial to factor in the consequences of the economic downturn in the wake of the ongoing pandemic. Therefore, the impact assessment should include a thorough assessment of the EU economy post Covid-19. It is crucial that changes to the ETS Directive followed by changes to the 2030 target address the risk of carbon leakage for companies with export to third countries. The indirect costs for industry of a higher electricity price also need to be taken into account, since electrification is key for the industry to be able to reach the climate targets. This requires access to fossil-free electricity at competitive prices. It would be unacceptable to lower European emissions by moving them or investments abroad – this would not benefit the climate nor the European economy. If we are to inspire the rest of the world to follow in our tracks, and achieve lasting emissions reductions at a global level, we must ensure the competitiveness of European businesses in the climate transition. 4) It is a reasonable principle that the EU Climate Law is aligned with the stock takes in the Paris Agreement. However, there is still the need for predictability of businesses and investments in Europe. Therefore, it is worrying that the proposal mandates the Commission to change the trajectory towards climate neutrality by using delegated acts. With regards to this, Svemin encourages the Commission to listen to European Parliament legal service which claims that such a proposal is not in line with the treaty. Hence, the ordinary legislative procedure should apply. 5) Lastly, the lack of proper definitions in the proposal creates unnecessary uncertainty and should be dealt with.
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Response to 2030 Climate Target Plan

15 Apr 2020

Minerals, metals and advanced materials have a central role in the green transition, for example in the energy and transport sector. Ensuring a sustainable supply of raw materials in Europe is crucial for Europe's industrial leadership and to achieve a climate-neutral, resource-efficient and competitive economy. Svemin welcomes the Commission's proposal to raise EU climate policy targets to 50-55% by 2030, and climate neutrality to 2050. This is in line with the Swedish mining and mineral industry's climate targets and roadmap to achieve fossil-free mining operations by 2035 and climate-neutral refinement processes by 2045. The mining and minerals industry is optimistic that the climate transition will be successful. However, the devil is in the details, and policy design will be crucial in order to support, not undermine, this transition. In this context Svemin would like to highlight certain key aspects that need to be addressed in a 2030 Climate Plan: Climate transition and competitiveness must go hand in hand. A holistic and long-term approach in political decisions is essential if the industry is to retain its global competitiveness. It is crucial that in the transition to become climate neutral, the industry can maintain and even improve competitiveness. For this reason, an increase of the 2030 target cannot be carried by the ETS sector alone, it must be distributed fairly between ETS sectors and the Effort Sharing Regulation. It is crucial that changes to the ETS Directive followed by changes to the 2030 target address the risk of carbon leakage for companies with export to third countries. The carbon and investment leakage that we already see today, i.e. that investments are prioritized in other countries with lower climate ambitions and higher CO2 emissions in production, already has consequences for the Swedish mining, mineral and metal industries today in favour of more carbon intensive production outside the EU, which does not benefit the climate nor the European economy. The indirect costs for industry of a higher electricity price need to be taken into account. In order to reach the industry’s climate targets, electrification is key. This requires access to fossil-free electricity at competitive prices. Svemin’s member companies are mainly established in the Nordic countries, with a very high degree of fossil free electricity. Due to the marginal cost pricing of electricity, the industry still pays the price of the coal, natural gas and oil in the system, even if the electricity is fossil free. The consequence is that switching from fossil fuels to fossil free electricity does not give any price incentives and competitive advantages for the first movers, but rather increased costs due to the increased electricity consumption that follows from moving away from fossil fuels and thus a competitive disadvantage compared to the slow movers. To get the incentives right to benefit the first movers, not holding them back and/or punishing them, is crucial for the green transition and to achieve the EU climate targets. Both the development of existing technologies and a shift to new technologies and processes will be required for industry to become climate neutral. A linear trajectory to the 2030 target therefore risks being counterproductive. A stepped approach taking technology shifts for different sectors into account is crucial. For the same reason investments in research, development and innovation for fossil-free production processes and CCS, including test and demonstration facilities, is important. Development of bio-based, electricity-based, and hydrogen-based processes for producing iron, copper, and other metals and minerals is an urgent priority. A thorough assessment of the EU economy post Covid-19 should be included in the European Commission's impact assessment of the 2030-target. We believe this would benefit the 2030 climate discussion.
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Swedish mining association opposes Energy Tax Directive revision

1 Apr 2020
Topic — The European Commission is revising energy taxation rules to meet climate goals.
Message — The association claims the current directive is effective and opposes a revision. They argue minimum tax rates should stay the same to protect global competitiveness. They also request automatic approval for tax exemptions under state aid rules.123
Why — Retaining current rules would minimize administrative burdens and protect the industry's market position.45
Impact — Households may continue to pay higher energy taxes compared to the industrial sector.6
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

Minerals, metals and advanced materials have a central role in the green transition, e.g. in the clean energy and transport sector. Ensuring a sustainable supply of raw materials is crucial for Europe's industrial leadership and to achieve a climate neutral, resource efficient and competitive European economy. Large investments are needed in industrial transformation, and it is of major importance for economic, employment as well as environmental and climate reasons that European industry remains competitive in the green transition. The fact that a limitation and/or a price on CO2 is missing in important competitor countries outside the EU already has consequences for the Swedish mining, mineral and metal industries today in favor of more carbon intensive production outside the EU, which does not benefit the climate nor the European economy. Against this background, Svemin welcomes the fact that a Carbon Border Adjustment Mechanism (CBAM) is further considered at EU level. However, the devil is in the details, and in this context Svemin would like to highlight certain key aspects that need to be addressed in the design of a CBAM: Climate transition and competitiveness must go hand in hand. It is crucial that in the transition to become climate neutral, the industry can maintain and even improve competitiveness. A CBAM must be designed with the overall objective to contribute efficiently to reducing CO2 emissions in a way that is administratively manageable for companies and causes as little trade friction as possible. It is crucial that the risk of carbon leakage for companies with export to third countries is addressed. The carbon and investment leakage that we already see today, i.e. that investments are prioritized in other countries with lower climate ambitions and higher CO2 emissions in production, must be addressed. This leakage is likely to increase over time if the EU increases its climate ambitions while other countries do not. Therefore, if the instrument of free allowances in the EU ETS is not compatible with a CBAM, another instrument that tackles the risk of carbon leakage must be developed. The indirect costs for industry of a higher electricity price need to be taken into account. The mining and minerals industry in Sweden has adopted a roadmap in order to reach fossil-free mining operations by 2035 and climate neutral metals and mineral processing by 2045. In order to reach these climate targets, electrification is key. This requires access to fossil-free electricity at competitive prices. Svemin’s member companies are mainly established in the Nordic countries, with a very high degree of fossil free electricity. Due to the marginal cost pricing of electricity, the industry still pays the price of the coal, natural gas and oil in the system, even if the electricity is fossil free. The consequence is that switching from fossil fuels to fossil free electricity does not give any price incentives and competitive advantages for the first movers, but rather increased costs due to the increased electricity consumption that follows from moving away from fossil fuels and thus a competitive disadvantage compared to the slow movers. To get the incentives right to benefit the first movers, not punishing them, is crucial for the green transition and to achieve the EU climate targets. It is crucial that the existing system remain functional until another solution has been tested and proved effective. A temporary weakening of competitiveness can lead to non-reversible effects that have a negative impact on the economy, the environment and the climate. Particular attention must be taken to ensure that no distorting effects are created between sectors and value chains in cases where different protection mechanisms would be applied to different sectors, e.g. free allocation of allowances for one sector and a CBAM for another. Ensuring a level playing field is essential for the functioning of the internal market.
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Response to Climate Law

6 Feb 2020

Svemin, the national business organization for mining, mineral in metal producers in Sweden, supports the goal of reaching climate-neutrality by 2050 and believes that it is essential that the EU stays at the forefront of the fight against climate change. The European Commission has announced that a proposal for a climate law will be put forward in March 2020 and with regards to this Svemin would like to submit the following feedback. The mining and minerals sector have an important role to play in the transition to a sustainable future. Fossil-free systems for energy and transportation, climate-friendly buildings and increased recycling all depend on sustainably produced, high-quality metals and minerals – not least those metals and minerals in modern batteries and infrastructure. The Swedish mining sector is a world leader in the production of raw materials, intermediate products and equipment with a low carbon- and environmental footprint. Minerals, metals and advanced materials are the key enablers for the transition in the clean energy and mobility sector. The sustainable management of natural resources and the shift to a green economy, securing sustainable supply of raw materials are essential in achieving a resource-efficient and competitive economy in Europe. In order to reach climate neutrality by 2050, EU climate policy must ensure a competitive industry sector and prevent carbon leakage throughout the green transition. The mining and minerals sector is exposed to global competition. Since CO2-emissions do not know national borders, it would not be beneficial for the global fight against climate change if production is transferred from the EU to other countries with lower ambition for emission reduction, or if EU products are replaced by more carbon-intensive imports. At the core of a successful combat against climate change lies ensuring a competitive industry sector that can provide climate solutions globally. As part of its efforts to transition to fossil-free production the Swedish mining and minerals sector has jointly developed a Roadmap to a Competitive and Fossil-free Mining and Metals Sector. The following points are crucial factors where the public sector will have a crucial impact: • Effective and fair permitting processes so that new and necessary, climate-efficient investments can be realized • A holistic European approach to political decision-making that avoids suboptimal instruments that would weaken competitiveness and make fossil-free operations more difficult • Investments in research and development for fossil-free production processes and CCS, including test and demonstration facilities • Access to fossil-free electricity and bioenergy with high reliability at competitive prices
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Swedish mining industry urges sustainable use over strict conservation

20 Jan 2020
Topic — The EU 2030 Biodiversity Strategy aims to curtail biodiversity loss and restore ecosystems.
Message — The association demands that the strategy prioritize sustainable use over strict conservation. They call for flexible regulations that balance biodiversity protection with the economic need for mineral extraction.123
Why — This would allow companies to avoid land-use bans and maintain access to mineral deposits.45
Impact — Conservation efforts are weakened if industrial development is prioritized over protecting undisturbed land.67
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Response to Sustainability requirements for batteries

5 Feb 2019

On behalf of the Swedish Association of mines, mineral and metal proudcers, SVEMIN, we would like to address following: Svemin - Welcomes the initative from the Commission regarding sustainability requirements for batteries and the ambition to improve the sustainability, energy and environmental performance of batteries placed on the EU’s internal market. - Emphasizes that EU must secure and promote EU-domestic responsible production and recycling of Battery Raw Materials and that it may be necessary to adjust to other policy documents and legislation to accomplish this. - Supports development of criteria on ethical sourcing of raw materials for the production of batteries (Option 5), presumably in combination with one or more of other suggested options. - Emphasizes the importance not to introduce detailed control or regulation on the technical design of batteries regarding the metal content that could obstruct important and desired continued product development of batteries. Preferably any regulation should aim to support and enable continuous achievement in functionality and sustainability rather than to impose limitations on design and use.
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