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Swedish Society for Nature Conservation

SSNC

The Swedish Society for Nature Conservation is Sweden's oldest and largest environmental organization, working to protect nature, promote human health, and advance global environmental justice.

Lobbying Activity

Swedish conservationists back ban on toxic long-chain acids

24 Nov 2025
Topic — Amending the EU regulation to include long-chain perfluorocarboxylic acids as restricted pollutants.
Message — The SSNC supports including these toxic acids in the POPs Regulation. They believe this step is necessary to protect health and environment.12
Why — The organization gains progress toward its goal of a chemical-free environment.3
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Swedish Society for Nature Conservation Urges Science-Based Resource Targets

6 Nov 2025
Topic — The consultation addresses legislative proposals to accelerate the EU's circular economy transition.
Message — The organization calls for science-based targets to keep material footprints within planetary boundaries. They argue legislation should prioritize reuse and repair over recycling to maximize environmental benefits. Additionally, they demand full traceability of chemicals to ensure safe material circulation.123
Why — This would advance their mission of reconciling the economy with environmental boundaries.4
Impact — Companies using toxic additives lose as harmful chemicals face swift removal from products.5
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Meeting with Pär Holmgren (Member of the European Parliament)

1 Oct 2025 · CAP simplification

Meeting with Heléne Fritzon (Member of the European Parliament)

16 Sept 2025 · CAP

Meeting with Heléne Fritzon (Member of the European Parliament)

27 Aug 2025 · Klimatmål 2040, kemikalier

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

16 Jun 2025 · Forest Monitoring Law

Meeting with Isabella Lövin (Member of the European Parliament)

22 May 2025 · Discussions on current environmental and climate legislation and SSNC's priorities

Meeting with Karin Karlsbro (Member of the European Parliament)

21 May 2025 · Miljö- och klimatlagstiftning

Meeting with Costas Kadis (Commissioner) and

27 Mar 2025 · Baltic Sea fisheries and challenges

Meeting with Emma Wiesner (Member of the European Parliament, Shadow rapporteur) and BalticWaters

27 Mar 2025 · möte med Civilsamhället om Östersjön

Swedish nature group urges stricter hazardous chemical reporting rules

26 Mar 2025
Topic — Amendments to simplify EU Taxonomy reporting requirements for companies' sustainability disclosures.
Message — SSNC advocates for the original text in Appendix C to ensure sustainable investments avoid hazardous chemicals. They argue that narrowing substance definitions would fail to protect health and environment.12
Why — Maintaining stricter rules ensures the organization's environmental protection goals are met without compromises.3
Impact — Human health and the environment are endangered by allowing hazardous substances to bypass scrutiny.4
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Swedish Society for Nature Conservation urges strict PFAS bans

4 Mar 2025
Topic — The European Water Resilience Strategy establishes a multi-annual plan to achieve water resilience.
Message — The group calls for the full implementation of water laws and universal PFAS restrictions. They advocate for ending agricultural subsidies for water-intensive crops and land drainage.12
Why — Stricter protections would ensure healthy ecosystems continue providing essential services and clean water.3
Impact — Farmers in water-stressed areas would lose subsidies for irrigation and drainage projects.4
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SSNC Urges Mandatory Green Rules for EU Public Procurement

4 Mar 2025
Topic — The EU is evaluating directives governing public procurement and concession contract awards.
Message — SSNC calls for mandatory environmental criteria in all procurement to replace voluntary approaches. They urge the EU to allow full usage of ecolabels and promote circular business models.123
Why — This would increase the market relevance and adoption of SSNC's own ecolabel.45
Impact — Suppliers of cheap, single-use goods would lose their price-based competitive advantage.67
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Response to Persistent organic pollutants – PFOA limits and exemptions

6 Dec 2024

Swedish Society for Nature Conservation (SSNC) oppose the proposed changes in the Regulation (EU) 2019/1021 on Persistent Organic Pollutants regarding Perfluorooctanoic acid (PFOA), its salts and PFOA-related substances. General comment: PFOA is very persistence and toxic and as little as one gram diluted in 175 Olympic swimming pools is enough to exceed the Swedish limit of 4 ng/L for PFAS-4 in drinking water. Further release of PFOA to nature will be costly for the society and industry. Contaminated drinking water need to be cleaned. Food (e.g. fish) lose its value if contaminated. Polluted areas need to be cleaned and that is very costly! Therefore, the derogations should be given with caution and limits for contaminants should be set as low as analytically possible. The proposed insertion of 4a and 4b, about the unintentional trace contaminant (UTC) limit is set 10 times higher for fluorine-free fire-fighting foam and related equipment compared to the general contamination limit in point 2 of the PFOA entry. A higher UTC will lead to prolonged release of PFOA even though fluorine-free foam is used. Cleaning of fire-fighting systems and equipment is tricky and often the whole system need to be exchanged which can be costly but not as costly as cleaning water and soil from PFOA. SSNC oppose the proposed changes. The proposed elongation of the exemption in point 6, using PFOA in fire-fighting foam 6 months more, will cause unwanted releases of PFOA to nature and may affect drinking water and food with high costs for society. The fire extinction companies have had plenty of time to change to readily available fluorine free fire-fighting foams. SSNC oppose the proposed change. The proposed insertion of point 11, is about allowing PFOA-containing articles already in use within the areas of 5(a) photolithography or etch processes in semiconductor manufacturing, 5(b) photographic coatings applied to films, 5(c) textiles for oil- and water-repellency for the protection of workers from dangerous liquids that comprise risks to their health and safety, and 5(d) invasive and implantable medical devices to be continued used after 4th of July 2025. Already in use PFOA-containing articles that still fulfil the technical requirements, should not be discarded only because a certain date has passed. In general, it is the production and end of lite stages where most PFAS are released to nature. Because of this, SSNC would like the proposed legal text to cover the waste stage in order to reduce the emission of PFOA to nature. Therefore, SSNC suggest following addition to point 11: if at end of life the articles are treated as hazardous waste.
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Meeting with Pär Holmgren (Member of the European Parliament, Shadow rapporteur)

20 Nov 2024 · Forest Monitoring

Meeting with Karin Karlsbro (Member of the European Parliament)

25 Sept 2024 · Miljö- och klimatpolitik kommande mandatperiod

Swedish Society for Nature Conservation rejects manure fertilizer limit increase

17 May 2024
Topic — This consultation addresses proposed changes to nitrogen load limits for manure-based fertilizers.
Message — The organization opposes increasing nitrogen load limits and argues against granting further derogations. They state that allowing manure-derived products above current thresholds creates a legislative loophole.123
Why — Stricter enforcement supports the organization's mission to reduce nitrogen leakage into aquatic systems.4
Impact — Intensive animal husbandry businesses would lose the ability to expand livestock density and fertilizer application.5
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SSNC urges full transparency in EU chemical data platform

4 Apr 2024
Topic — The EU is establishing a common platform to centralize and share chemical safety data.
Message — SSNC requests including peer-reviewed scientific data and chemicals' entire life cycles. They advocate for deleting exemptions for internal documents to allow for independent oversight.123
Why — Enhanced transparency would allow the group to verify the accuracy of safety assessments.4
Impact — Chemical manufacturers may lose confidentiality over internal studies that must be shared.5
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Swedish Nature Society urges stricter ban on all bisphenols

8 Mar 2024
Topic — EU consultation on banning bisphenol A and similar substances in food contact materials.
Message — The group welcomes the ban but demands it includes bisphenols classified as category 2 CMRs and EDCs. They also insist the restriction must cover all food contact materials, including plastics.12
Why — Expanding the ban fulfills their mission to better protect human health and the environment.3
Impact — Plastic manufacturers would lose the ability to use substances currently on their specific positive lists.4
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Response to Revision of the definition of engineered nanomaterial in food

12 Jan 2024

The Swedish Society for Nature Conservation (SSNC) welcomes the opportunity to provide feedback on the draft delegated regulation updating the definition of engineered nanomaterials in the Novel Food Regulation (EU) 2015/2283. The new definition raises several concerns for the protection of human health and consumers right to know. Exclusion of all materials/substances with less than 50 % particles smaller than 100 nm, is to narrow down the definition of nanomaterials too much. Preferably, all materials/substances containing nano particles should be defined as nanomaterial, as does the current definition, to secure human health and the consumers right to know (since the nano-labelling is dependent on the definition). But to be a good definition it also must be able to be enforced legally, and thus the threshold should be set as low as analytical methods allow. Exclusion of single molecules in the nano-size is also to narrow the definition too much. It will open up for engineering of macromolecules, like dendrimers and larger polymers, to be used as food additives without notice by authorities or for the consumer to be able to make an active choice. Nano-size particles and molecules can be taken up by the body and have been found in most organs including the brain. Therefore, caution must be taken as not to endanger human health.
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Response to Revision of the Toy Safety Directive

30 Oct 2023

Swedish Society for Nature Conservation (SSNC) welcomes the Toy Safe Regulation, with ambition to make toys safer for children. The draft includes some positive changes compared to the Toys Directive, while other changes are missing to protect children as much as possible. SSNC welcomes following changes: Inclusion of endocrine disrupting chemicals (known and suspected) Inclusion of respiratory sensitisers (known and suspected) Inclusion of organ damaging chemicals (STOT) Inclusion of Bisfenol A Inclusion of combination effects Information of Substances of Concerns in a product passport That concentration limits now applies to toys aimed for all children and not only for those under 3 years of age. SSNC promotes addition of following changes: Inclusion of environmental hazardous chemicals (PBT, vPvB, PMT, vPvM) to enable recycling of the materials. Banning of bisfenols as a group. When Bisfenol A is banned, other bisfenols, being equivale harmful, will be used instead. Time limit for all derogations. New knowledge on hazards and alternatives emerges with time and derogations need to be evaluated regularly. Products with derogation shall be labelled with the identity of the derogated chemical(s), to enable informed decision by purchasers and to avoid contamination of legal chemicals in recycled materials. Recycled materials shall have the same limits of regulated chemicals as virgin materials, even though the hazardous chemical may not be intentionally added. This will secure that all toys will fulfil the expected requirements for protection of children, whether or not recycled materials are used.
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Meeting with Jakop G. Dalunde (Member of the European Parliament)

12 Oct 2023 · General meeting about environmental- and climate policy (staff level)

Meeting with Jakop G. Dalunde (Member of the European Parliament) and Greenpeace European Unit and Världsnaturfonden WWF (WWF Sweden)

31 Aug 2023 · Fit for 55 and the future of Swedish Climate politics

Swedish environmentalists urge equal status for national eco-labels

3 Jul 2023
Topic — This consultation addresses the substantiation and communication of explicit environmental claims.
Message — The organization requests that officially recognized Type I labels receive status equivalent to the EU Flower label. They propose that businesses using these labels be exempt from additional pre-approval for green claims. Existing labeling systems must also be allowed to expand into new product areas.123
Why — Equal status would protect their labeling scheme and reduce administrative costs for businesses.4
Impact — Public authorities lose vital verification tools needed for environmentally responsible procurement.5
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Swedish Society for Nature Conservation urges net zero by 2040

21 Jun 2023
Topic — The European Commission is consulting on setting a climate target for the year 2040.
Message — The organization demands net zero emissions by 2040 and a 100% renewable energy system. It also calls for five-year policy cycles and a 2035 climate target.12
Why — Stricter targets would help the group achieve its core goal of protecting global ecosystems.3
Impact — Bioenergy producers would face higher costs through stricter accounting of land-use and biodiversity impacts.4
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Meeting with Malin Björk (Member of the European Parliament, Shadow rapporteur for opinion) and European Environmental Bureau

26 May 2023 · Critical Raw Material

Meeting with Emma Wiesner (Member of the European Parliament)

25 May 2023 · avtackning ordförande

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

1 Mar 2023 · Paneldiskussion skogspolitik

Meeting with Pär Holmgren (Member of the European Parliament)

25 Jan 2023 · Corporate Sustainable Due Diligence (staff level)

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

9 Dec 2022

The SSNC is positive to the fitness check of the Polluter Pays Principle. Currently, only a very few polluters pay. They can be divided into two groups, the ones that are responsible for visible pollution for example large oil spills or waste, and the ones releasing pollutants that are legally required to be reported, such as CO2, NOx and SOx. There is a large hidden number of polluters, polluters releasing pollution with no current legislation and where it is difficult and costly to prove the polluter in court, or that the polluter no longer has the financial opportunity to pay. This needs to be highlighted during the evaluation of the Polluter Pays Principle. PFAS an example when the polluter does NOT pay. Reducing PFAS in drinking water comes at a cost, that is paid by the consumers, the citizens. The process should be paid by the PFAS polluter but is has been shown hard to prove who has released what and how much. Even though several contamination sources are well known such as the release of FFF containing large amounts of PFAS into the environment, the polluters, the military and the fire departments, have not paid for the decontamination in Sweden. Industries that have used PFAS, eg the electronic industry and paper and wood industry have contaminated the adjacent environment. Waste incinerators pay for fossil CO2 released, but not for spreading other pollutants, eg PFAS. Consumer products that contain PFAS, release PFAS throughout the products life cycle, during production, use (eg though waste water) and waste. Taxes on hazardous chemicals in certain products in Sweden a good example on how the polluter actually can pay. In Sweden there is a specific tax on electronics since all electronic products can be expected to contain hazardous chemicals like flame retardants. If the company putting a electronic product on the market can show that the flame retardants used are non-hazardous, the tax level is lowered. This is a robust source of income for the state to be used when taking care of future electronic waste. The tax could be extended to all products put on the market, therefore shifting the burden of evidence to the company selling the product. The SSNC would like to see a tax on all products that contain SVHC (SIN-list) or substances not yet evaluated by REACH. A lower tax level for the products with evaluated and proven non-hazardous substances could be applied.
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Response to Introducing new hazard classes–CLP revision

18 Oct 2022

Swedish Society for Nature Conservation (SSNC) comments on the Commission’s proposal for an Amending Regulation (EC) No 1272/2008 as regards adding new hazard classes and criteria for CLP General comments SSNC strongly recommend inclusion of the new hazardous classes, as proposed in the delegated regulation draft, with a few changes. The new hazardous classes are necessary for adequate protection of both human health and the wildlife, as well as to enable a toxic free circular economy as laid out in the Green Deal. Comments on transition time The 18-month time interval, from entry into force to application, should apply to both substances and mixtures. Also, the prolonged time for substances and mixtures already on the market should be limited to 12 months and be the same for both substances and mixtures. Changes accordingly should be made in Annex I, paragraph 3.11.2.5., 3.11.3.4., 3.11.4.2., 3.11.4.3., 4.2.2.5., 4.2.3.4., 4.2.4.2., 4.2.4.3., 4.3.2.5., 4.3.3.2., 4.3.4.2., 4.3.4.3., 4.4.2.5., 4.4.3., 4.4.4.2. and 4.4.4.3. Comments on Endocrine disruptor criteria SSNC welcomes the proposal of two categories of endocrine disruptors for both humans and the environment. Nevertheless, since the burden of proof is very high for both categories 1 and 2, there is room for a third category triggering an in-depth ED assessment process, including if needed additional studies. Definitions in 3.11.1.1. and 4.2.1.1. need to include behavioural effects as ED-induced adverse effects. Classification criteria in Table 3.11.1. and Table 4.2.1. need to be in line with the definitions in the same annex. Category 1 (b) an adverse effect in an intact organism, its offspring or future generations; Category 2 (a) there is evidence of an endocrine activity and an adverse effect in an intact organism, its offspring or future generations; There should be no concentration limits for when a mixture should be classified as endocrine disruptor. Paragraphs 3.11.3.1 and 4.2.3.1.1, as well as Table 3.11.2 and Table 4.2.2. should be dismissed. 4.2.2.3. All data used to evaluate a substance must be publicly available. (c) any additional public acceptable data. 4.2.2.3.2. Coherence and consistency in exposure effects is not always expected across different species and taxonomic groups. (h) Dismiss the whole sentence. Comments on PBT/vPvB criteria SSNC welcomes the inclusion of PBT and vPvB criteria in the CLP regulation. 4.3.2.1.2. Classification criteria should also include in vitro and in silico criteria to avoid animal tests for low tonnage substances. 4.3.2.3.3 The information to be considered for the assessment of toxicity properties, should include (d) CMR Category 2 and (e) ED Category 2. 4.3.3.1 There should be no concentration limits for when a mixture should be classified as PBT or vPvB. The whole paragraph should be dismissed. 4.3.4.1 The hazard statement should be revised to also include information about persistence. Comments on PMT/vPvM criteria SSNC welcomes the inclusion of PMT and vPvM criteria in the CLP regulation. 4.4.2.1.2 The mobility criterion should be changed to: “A substance shall be considered to fulfil the mobility criterion (M) when the log Koc is less than 4.” 4.4.2.2.2 The ‘very mobility’ criterion should be changed to: “A substance shall be considered to fulfil the ‘very mobile’ criterion (vM) when the log Koc is less than 3.” 4.4.2.3.2 The information to be considered for the assessment of toxicity properties, should include (d) CMR Category 2 and (e) ED Category 2. 4.4.3.1 There should be no concentration limits for when a mixture should be classified as PBT or vPvB. The whole paragraph should be dismissed. 4.4.4.1. The hazard statement should be revised to also include information about mobility.
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Response to Communication on the functioning of the Common Fisheries Policy

23 Sept 2022

The objectives of the CFP and the details of the legal text in the Basic regulation have not been fully implemented. However, this is more a result of poor implementation than a problem with the legal text itself. The current core intentions of the CFP remain the relevant ones: setting strict fishing limits under MSY, using regional management plans, having adaptable rules under regionalization, stopping harmful fishing activities, avoiding adverse negative impacts on the wider environment, and implementing an ecosystem-based management. However, the reformed CFP has unfortunately not led to a matching reform of the underlying scientific advice, the organizational structures and the decision-making framework and herein lies some key problems: 1. Fish and fishing are still being managed separately, instead of as an integral part of the ecosystem, taking into account ecosystem needs as well as all the activities affecting it. Ecosystem effects emanating from largescale biomass extraction and harmful fishing practices are not being fully considered. Only rarely are fish subpopulations being considered in management and the TACs being set at precautionary levels to safeguard weak populations. 2. The EU system was not prepared for a changed regional approach, making decision-making more difficult, or at the very least more confused, rather than quicker. 3. We have not seen the needed move towards more shared responsibilities between fisheries and environmental management that can be facilitated by the regionalization in both fisheries (CFP) and environment (MSFD). For example, reaching agreement on fisheries regulations in Marine Protected Areas, adhering to provisions of environmental legislation, is complex and time-consuming 4. The CFP blocks needed efforts to reduce negative species and environmental impacts using socio-economic arguments in unintended ways, and the member states have not sufficiently steered towards low-impact fisheries. 5. The current scientific advice is not sufficient to be able to take more informed decisions on e.g. TACs and fishing practices that are not conflicting with the key marine legislation of MSFD and HD regarding specific species and habitats, largely because the advice does not take into account fish and fisheries as part of the ecosystem at large, see point 1. 6. The implementation of the landing obligation has not led to changed gears and stricter demands on fishermen to avoid certain catches in the first place. The results are either more or less business as usual with created derogations or simply non-compliance with illegal dumping ongoing. All points mentioned are either driven by conflict with other legislation, poor understanding of the rules in place or by simply placing one objective above another one. There is little use in changing the CFP basic regulation if its promises are not implemented. Nor will a reform of the CFP matter if the control and enforcement do not work. The rules and intentions already exist within the current legislation, and what is needed now is to speed up implementation and plug the existing gaps and problematic overlaps using new instruments such as the Nature Restoration Law and Fisheries Action Plan. We must see the Baltic Sea as the greatest failure and warning to all sea areas: halt poor performance in time or face total loss of iconic stocks like cod and herring.
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Swedish conservationists demand mandatory EU pesticide reduction targets

19 Sept 2022
Topic — The Commission is reviewing rules to reduce pesticide risks and promote non-chemical farming.
Message — The organization calls for ambitious mandatory targets and clear definitions for non-chemical methods. They demand that farmers justify using chemical pesticides rather than explaining why they used sustainable alternatives. Mandatory education on non-chemical practices for all advisors and farmers is also requested.123
Why — Stronger regulations would help the organization achieve its core mission of halting European biodiversity loss.4
Impact — The chemical industry would face lower sales as states are urged to discourage synthetic pesticides.56
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Swedish Nature Conservation Society demands end to chemical secrecy

11 Aug 2022
Topic — The initiative aims to improve chemical data access for safety assessment purposes.
Message — SSNC requests the removal of legal obstacles to confidentiality and intellectual property rights. They advocate expanding the SCIP database and establishing global transparency standards for chemicals.123
Why — Accessing broader datasets would help the organization conduct thorough health risk assessments.4
Impact — Manufacturers would lose protection for proprietary information through stricter confidentiality claim limits.56
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

28 Jun 2022 · Implementation of the EU Forest Strategy for 2030; SSNC overview on situation in Swedish forests

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

28 Jun 2022 · Implementation of the EU Forest Strategy for 2030; SSNC overview on situation in Swedish forests

Meeting with Pär Holmgren (Member of the European Parliament)

16 Jun 2022 · EU Climate Policy (staff level)

Meeting with Jakop G. Dalunde (Member of the European Parliament) and Världsnaturfonden WWF (WWF Sweden)

1 Jun 2022 · Roundtable: Fit for 55

Meeting with Frans Timmermans (Executive Vice-President) and Swedish Forest Industries Federation and

31 Mar 2022 · Forest policy and the EU Green Deal roundtable discussion

Meeting with Pär Holmgren (Member of the European Parliament)

8 Nov 2021 · COP26 & Climate Policy

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

14 Oct 2021 · Climate Policy

Response to Carbon Border Adjustment Mechanism

20 Sept 2021

Naturskyddsföreningen har beretts möjlighet att lämna synpunkter på EU-kommissionens förslag om införandet av en gränsjusteringsmekanism för koldioxid (CBAM). Rätt utformad kan en sådan mekanism vara en viktig åtgärd för att minska Sveriges och unionens höga konsumtionsbaserade utsläpp i samband med import från tredje land, i enighet med principen om att förorenaren ska betala. Enligt kommissionens förslag syftar gränsjusteringsmekanismen till att motverka koldioxidläckage vid sidan av den fria tilldelningen under ETS, en risk som Naturskyddsföreningen ifrågasätter, bland annat baserat på en stor studie av Carbon Market Watch (https://carbonmarketwatch.org/wp-content/uploads/2021/06/Phantom_leakage_WEB.pdf). En gränsjusteringsmekanism skulle dock utgöra ett bättre instrument än fri tilldelning, i enighet med principen att förorenaren ska betala. Vidare har vi en positiv syn på mekanismens potential att bidra till att unionen tar fullt ansvar för hela sin klimatpåverkan, något som är avgörande för uppfyllandet av EU:s nya klimatmål och i synnerhet klimatmålen i Parisavtalet. Sammanfattning - Gränsjusteringsmekanismen för koldioxid bör täcka de mest utsläppsintensiva sektorerna och snarast efter utredning utvidgas till fler sektorer. - Vid införandet av en gränsjusteringsmekanism måste den fria tilldelningen under ETS omedelbart upphöra. Den långa övergångsperiod i kommissionens förslag riskerar att urholka styrmedlens effektivitet i såväl CBAM som ETS. - Möjligheter till särskilda övergångsregler och ekonomisk kompensation behövs för särskilt utsatta länder som de minst utvecklade länderna (LDCs) och små utvecklingsönationer (SIDS). - Intäkterna från gränsjusteringsmekanismen vid import bör enbart användas till att finansiera klimatåtgärder, huvudsakligen internationellt, inte som i förslaget om att bli en egen resurs i EU-budgeten. Se vidare mer detaljerade synpunkter i bifogat dokument.
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Response to Updating the EU Emissions Trading System

20 Sept 2021

En reform av EUs system för utsläppshandel är absolut nödvändig för att utsläppshandeln ska kunna bidra till uppfyllandet av unionens nya klimatmål och i synnerhet klimatmålen i Parisavtalet. Sammanfattning • Reformen behöver börja gälla senast 2023. • Ambitionsnivån behöver höjas ytterligare. Den linjära reduktionsfaktorn behöver ligga på minst 6 procent per år fram till 2030 och en engångsreduktion av antalet utsläppsrätter på minst 450 miljoner ton behöver göras inledningsvis. • Intagsgränsen för överblivna utsläppsrätter till marknadsstabiliseringsreserven bör ligga på minst 36% per år till 2030 och utsläppsrätter i reserven bör skrotas automatiskt efter tre år. • Ett europeiskt prisgolv behöver införas för utsläppsrätter inom ETS-systemet, initialt minst på en nivå kring 500 kronor per ton. • All gratis tilldelning av utsläppsrätter måste upphöra, senast 2023. Också den fria tilldelningen av utsläppsrätter till flyget bör avskaffas samtidigt. Principen om att förorenaren ska betala måste gälla fullt ut. • Det är positivt att sjöfarten föreslås ingå i utsläppshandeln. Dock bör reformen även omfatta all sjötrafik till och från EU. Ingen fri tilldelning bör tillåtas. • Koldioxidutsläpp från byggnader och från transportsektorn bör inte ingå i utsläppshandeln. Andra styrmedel, främst höjda energiskatter, är här enklare och effektivare styrmedel. Se vidare bifogat dokument för mer detaljerade synpunkter.
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Response to Revision of the Energy Tax Directive

20 Sept 2021

Naturskyddsföreningen är tacksam över att EU-kommissionen nu lämnar förslag om ett kraftigt reformerat och aktualiserat energiskattedirektiv. Det nu gällande direktivet är från 2003 och sedan länge inaktuellt och utdaterat, vilket kommissionen själv funnit i sin Impact Assessment Report. En reform är absolut nödvändig för att direktivet ska kunna bidra till uppfyllandet av unionens nya klimatmål och klimatmålen i Parisavtalet. Allmänna synpunkter: • Det är positivt att skattenivåerna i direktivförslaget nu grundar sig på energiinnehåll i stället för på volym, detta gynnar förnybara, oftast mindre energitäta, bränslen. • Den föreslagna miljörankingen av bränslen är heltäckande och baserad på strikta definitioner och avgränsningar, vilket är bra. Det är dock bekymmersamt att en del kategorier är mer övergripande och andra väldigt specifika, vilket leder till att ett bränsle kan passa in i flera olika kategorier. Detta kan leda till tolkningsproblem i medlemsländerna. Exempelvis återfinns biogas uttryckligen i fyra kategorier och passar in i ytterligare två kategorier. Minimiskattenivåer: • För medlemsländer som saknar separat koldioxidbeskattning för sektorer utanför utsläppshandeln skulle energiskatter kunna täcka upp för denna brist. Om de föreslagna minimiskattenivåerna för bensin och diesel ökas med ytterligare 80 procent för dessa länder skulle det ungefär motsvara den samlade svenska drivmedelsbeskattningen. • Förslaget innebär att förnybara bränslen som i dag oftast är skattebefriade beläggs med energiskatt, om än på en låg nivå. Det kan accepteras genom att avståndet till beskattningen av de fossila drivmedlen samtidigt ökar när skattesatserna för dessa höjs. Medlemsländerna slipper nu begära kortfristiga undantag för förnybara drivmedel som tidigare, i alla fall på den svenska bränslemarknaden, ställt till med oreda, vilket är positivt. • För drivmedel är minimiskattenivån för diesel väsentligt högre än dagens svenska energiskatt för bränslet, det kan förväntas medföra en höjning av den svenska energiskatten på diesel, vilket skulle innebära likabeskattning mellan bensin och diesel och borttagande av en klimatskadlig subvention. • LPG och fossilgas föreslås få en lägre minimiskattenivå än övriga fossila bränslen. Med hänsyn till fossilgasens stora klimatpåverkan, sett ur ett livscykelperspektiv där även läckage från utvinningen mm inkluderas, bör fossilgasens minimiskattenivå vara lika hög som för andra fossila drivmedel. • Icke-hållbara biodrivmedel, som t.ex. HVO från palmolja eller PFAD, föreslås att drabbas av lika hög skatt som de fossila drivmedlen, vilket är positivt. • Flygfotogen förslås beskattas lika som bensin och diesel för marktransport, vilket är positivt. Dock föreslås ett fortsatt undantag från bränslebeskattning för fraktflyg. All användning av flygbränsle bör beskattas lika, utan undantag. • För sektorer och drivmedelsanvändningar som enligt förslaget beviljas undantag är miniminivåerna för de fossila bränslena satta väldigt lågt. Skillnaderna mellan fossilt och förnybart blir då också alldeles för små, med bristande incitament för övergång till förnybart som följd för dessa sektorer. Naturskyddsföreningen anser att all fossil drivmedelsanvändning bör beskattas lika, utan undantag och att dessa nedsättningar av energiskatterna måste upphöra. • För uppvärmningsbränslen är minimiskattenivåerna också alltför lågt satta för de fossila bränslena. Skillnaden mot det förnybara blir för liten, vilket förtar styreffekten av beskattningen. Naturskyddsföreningen anser att beskattningen av fossila uppvärmningsbränslen borde vara densamma som för fossila drivmedel. Så är fallet i Sverige sedan tidigare. Se vidare i bifogad fil för ytterligare synpunkter.
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Response to Revision of EU rules on food contact materials

28 Jan 2021

The Swedish Society for Nature Conservation (SSNC) opine the Inception Impact Assessments for revision of the regulation No 1935/2004 on Food Contact Materials (FCM) to be well thought-out. The description of the drawbacks of the current regulation (A 1-8) agrees with our opinion of the situation. A coherent regulation, harmonised with other chemical regulations within EU, is needed to get both a level play of business, as well as high protection of the health of the most vulnerable groups. Nevertheless, to achieve the outset goals, these points must be fulfilled: • The food contact material legislation must protect human health and the environment, according to the precautionary principle. • Substances lacking data for any of health classifications in CLP should not be allowed to be used in food contact until proven safe. • The FCM-legislation should not allow any: o Substances of Very High Concern (SVHCs) o CMR substances o EDC substances o PFAS substances, including polymers • Recycled materials should have the same requirements as virgin materials. • Non-intentionally added substances must be included in the legislation and measured in the final product. • Legislation should include used products, like scratched and broken articles, to ensure human health. • The FCM-legislation should require national authorities to establish and implement a control program to ensure that the legislative requirements are fulfilled, and if not oblige economic penalties.
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Response to Towards a strong and sustainable EU Algae sector

18 Jan 2021

Input regarding option 2, particularly Objective 1 (Improving regulatory and governance framework): An increased algal farming has good potential to be both environmentally beneficial and profitable, and the Swedish Society for Nature Conservation is in general positive to a sustainable growth of the sector and specifically to the points raised under Objective 1. There are, however, some essential elements to keep in mind to ensure a sustainable development of macroalgal farming in the EU: 1. Only native species should be farmed – introduced macroalgal species have become invasive in numerous locations around the world, and it is important that non-native species – even those which have already become established in European waters – are not given the opportunity to spread further and become invasive pests. 2. In open-water farming in the ocean, or if the farm has water exchange with the ocean, seaweeds in farms should to as large extent as possible be based on native genetic material from the area in question. This is important to ensure continued genetic diversity of the species in the farm area, which will minimise the risk of detrimental effects on local algal habitats. Domestication of algae (as well as of plants and animals) decreases the genetic diversity within the farmed varieties, and if selected cultivars from other locations have competitive advantages over wild varieties such as high growth rates, local varieties may be outcompeted if there is spread of reproductive material from the farms. A continued high genetic diversity in wild seaweed populations is vital to maintain adaptive potential in a changing climate. 3. All farms should be placed in areas where they will have minimally negative effect on the surrounding environment – for example, any farming in areas where farms may negatively affect already existing marine habitats such as seagrass or natural macroalgal beds by shading should be avoided. 4. Any increase in open-water farming needs to be in line with an ecosystem-based management, and always consider the cumulative impacts from the farming in concert with all other pressures impacting the coastal and ocean ecosystems. 5. In open-water farming in the ocean any and all addition of nutrients or fertilizer should be avoided. For algal farms to have a positive effect on the marine environment they need to secure a net decrease of nutrients. In addition to this we would like to affirm the point made in Option 3 regarding the quota setting and environmental impact assessment on the harvest of wild macroalgae. Harvesting of wild seaweeds have been going on across the globe for a long time and is in many cases a culturally and economically important activity that, if executed in a responsible fashion, can be both sustainable and environmentally friendly. We would, however, like to raise concerns regarding overharvest and unsustainable harvesting methods. Macroalgae commonly support diverse marine communities and host a wide range of organisms, while contributing important ecosystems services - it is vital that the development of a European algae industry does not compromise the importance of natural macroalgal beds. Harvest of wild seaweeds have in many locations around the world resulted in over-exploitation of the resource with ensuing environmental problems. Natural macroalgal beds, such as kelp forests, are important players in marine carbon sequestration given their large export of organic material to deeper areas where the carbon is stored in the sediment. This clearly illustrates that, in addition to the importance of macroalgae for biodiversity purposes, natural algal beds may constitute an important piece of the puzzle in marine carbon sequestration. We therefore stress the necessity of suitable scientific monitoring and evaluation of the harvest and its potential side effects to ensure a sustainable use of the wild seaweed resources.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

The Swedish Society for Nature Conservation's demands for EU-ETS reform in brief: - The EU needs to reduce its total emissions by at least 75 percent by 2030 compared to 1990 levels and reach near zero emissions by 2035. - The EU-ETS needs to be reformed in line with these higher ambitions, but also needs to be supplemented with other instruments for the EU as a whole to be able to phase out all coal power plants by 2030 and all fossil fuels by 2035. To meet this the linear reduction factor within the EU-ETS would need to be around 15 per cent per annum, instead of the current 2.2 per cent. To reach the European Commission's ambition level of -55 percent by 2030, it needs to be at least -6 percent annually. - The EU-ETS must guarantee that a sufficient amount of allowances is cancelled annually in order to reach and maintain a price level that is in line with the 1.5-degree C target and can help to achieve substantial emission reductions. - The polluter pays principle must apply in full, therefore free allocation of allowances should not be allowed. The free allocation must be phased out as soon as possible. Full auctioning should be applied by 2023. - SSNC is positive towards the European Commission exploring if and how a Carbon border adjustment mechanism (CBA) can be implemented. The sole objective of the CBA must be fighting climate change, and the CBA must not be used as a protectionist measure for EU industry. In this regard, the CBA should apply to imports only, and not also benefit exports. - A CBA will need to be complemented by a total phaseout of all free allowances that are currently being distributed to high emitting industries under the EU ETS. - Measures must also be taken to ensure that carbon prices don´t fall back to low levels. This can be done through an EU-wide price floor for the EU-ETS, for example as a component of a CBA mechanism, which guarantees a minimum price level for emission allowances. If free allocation is phased out during the trading period, it also helps keeping up the price level. - EU should not abandon its own emissions trading scheme for aviation in favour of CORSIA. On the contrary, the emissions trading scheme for aviation should also include flights to and from the EU, as was originally intended. - The free allocation to aviation should be abolished and the possibility of exchange between aviation allowances and industrial allowances should be removed. High altitude effects should also be included in the calculation basis for allowances for aviation within the EU-ETS. For emissions trading to be a suitable instrument, it is necessary to choose sectors: • Where the emissions are large, • Where it is possible to measure emissions accurately and without great difficulty, • Where the number of emission sources is not unmanageable, • Where existing effective instruments are not compromised, • Where cheating can be prosecuted in a meaningful way. - Based on these criteria, the EU should urgently explore the possibilities to integrate shipping in the EU-ETS. No free allocation should then be made for shipping either. Shipping must also be accommodated within the existing total EU-ETS bubble. Based on the same criteria, emissions from road transport and buildings should not be included in emissions trading. Instead, these sectors should remain under the Effort Sharing Regulation (ESR) and thus be covered by the nationally binding targets that each member states have under that regulation.
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Response to Commission Delegated Regulation amending Annex IV to the LULUCF Regulation

14 Sept 2020

The Swedish Society for Nature Conservation is a large member-based environmental non-governmental organization with over 200 000 members and local branches throughout Sweden. In the Paris agreement (Article 5.1.) parties are called to take action to protect and enhance sinks and reservoirs, including forests. While the LULUCF regulation is a step forward from Kyoto accounting rules, the EU member states’ LULUCF forests reference levels combined show how the LULUCF regulation does not currently safeguard the forest sink in the EU. Compared to the 2000-2009 baseline, the forest reference levels calculated based on the rules of the LULUCF regulation allows a 18.7% decrease in the carbon sink of EU and the UK, or over 70 million tonnes CO2 annually, during 2021-2025, without causing accounted debits. This is likely to allow substantial increased biogenic carbon emissions from forest harvesting or bioenergy without due accounting. The gap implies insufficient incentives for, firstly, safeguarding forest carbon stocks, secondly, improving the climate benefits of the bioeconomy and strengthening circular economy, and thirdly, improving the longevity of products in the bioeconomy. This weakness is related both to the LULUCF regulation design and implementation, which cannot fully ensure transparency or environmental integrity. Due to the possibility to use some LULUCF-credits in the ESR sector (in place of emissions reductions in transport and agriculture) the weak baseline carries a risk of “hot air” – implying LULUCF credits without sufficient environmental integrity that may reduce overall ambition of EU climate policy. The EU Green Deal and review of the LULUCF regulation must address the issues identified above and ensure EU managed forests contribute both in the short, medium and long term to climate mitigation. There is a continued possibility and need to strengthen the carbon sink in EU member state forests through eg. restoration measures with co-benefits for climate mitigation, climate adaptation and biodiversity. The LULUCF regulation may give support to such efforts in individual member states but not in a coherent way that would allow increased climate ambition. A clear need for a carbon removals target to increase the ambition in the land sector remains. In order for the land sector to deliver there is a need to treat fossil emissions reductions separately (and without fungibility) from forest carbon sinks and stocks in all EU climate policy.
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Response to Chemicals strategy for sustainability

18 Jun 2020

Swedish Society for Nature Conservation (SSNC) comments on the roadmap for The Chemicals Strategy for Sustainability A circular and climate-neutral economy in a non-toxic environment where the biodiversity thrives, can only be achieved with sustainable and solidary usage of non-toxic chemicals from renewable sources worldwide. It is important to strategically develop and refine EU’s chemicals policies in the light of today’s better understanding of climate changes, biodiversity loss, planetary boundaries and globalized economy with multi-national supply chains for materials and articles and their relation to the usage, spread and impacts of chemicals. It is also important to design this strategy as a central piece of the Green Deal puzzle, both in the Zero Pollution Action Plan, and as an important corner stone to fulfil the Biodiversity and the Farm to Fork Strategies. To reach Zero Pollution, the pharmaceuticals, pesticides, waste and wastewater legislations have to be updated with an environmental precaution. It is important that the Chemicals Strategy gives concrete suggestions on how to fulfil the aim of the initiative as stated in the roadmap (to live up to Art. 191 TFEU, Art. 3(3) TEU, Art 26 and 27 TFEU), prioritising the precautionary principle, the polluter pays principle and sufficient protection of human health and the environment at the same time as European companies increase their global competitiveness with a shift to a circular and carbon neutral economy without hazardous chemicals. The Chemicals Strategy needs a concrete action plan for the transition towards a sustainable use of non-toxic chemicals with timelines of legislation refinement, implementations and updates: • Urgently improve the implementation and enforcement of current EU chemical legislations according to REACH REFIT Evaluation and the Fitness Check of other chemical legislations. • Provide imported, as well as exported, articles and materials with the same chemical requirements as for EU produced for the EU market. • Have the same chemical requirements for recycled materials as for virgin materials. If this principle is not in place, trust in the circular economy will quickly be eroded. • Enforce the concept of “No data – no market”. Comprehensive evaluation is needed before chemicals enter the market, to protect human health and the environment. There have been too many chemicals approved that later have been found harmful. • Speed up the evaluation of chemicals by evaluation of groups of similar chemicals, like in the PFAS-case recently presented. • Adopt “One substance – one hazardous assessment” to reduce the confusion of what effects a specific chemical has and to strengthen and harmonise the chemical legislations. • Make full disclosure of all chemicals (not only SVHC) in articles, materials and waste in the SCIP-database mandatory. Chemicals currently of no concern may in the future be recognised as hazardous. • Included polymers in REACH. Make it mandatory for polymers to follow the same procedure as chemicals and mixtures, i.e., to be registered, fully evaluated for their health and environmental properties and regulated accordingly. • Urgently decide on an action plan to phase out all non-essential use of per- and polyfluorinated substances (PFAS). • Consider the specific physio-chemical properties of nanomaterials in the legislation. • Urgently include and implement rules for endocrine disrupting chemicals (EDC) in all chemical legislations. Introduce EDC as a new hazard class in the CLP, and work for the same in GHS. • Revise the Food Contact Materials (FCM) legislation. The framework legislation needs to be updated according to the latest scientific knowledge including all materials used and national regulations needs to be harmonised within EU. The Farm to fork strategy requires a revision of the FCM-legislation. How to make chemical use sustainable? Please see attached file.
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Response to Climate Law

30 Apr 2020

The Swedish Society for Nature Conservation, SSNC (Svenska Naturskyddsföreningen) welcomes the initiative to put in place a Climate Law for Europe. However, SSNC is concerned that the level of ambition is not in line with what science requires to limit global temperature rise to 1.5°C above pre-industrial levels. In more detail, SSNC would like to give the following feedback to the proposal “European Climate Law: • Level of ambition: The Law must set out a binding objective of increasing its 2030 climate target to at least 65%-70% compared to 1990, reaching climate neutrality in the Union by 2040 and negative emissions thereafter. The Paris Agreement Article 2.2 requires the Agreement to be “implemented to reflect equity and the principle of common but differentiated responsibilities and respective capabilities, in the light of different national circumstances”. Reducing emissions with 50-55% by 2030 compared to 1990 and reaching climate neutrality by 2050 is for the EU not in line with that requirement, and hence the objective of the climate law must be amended. Moving into negative emissions is equally crucial to limit warming to 1.5°C. Further, to ensure the Union objective can be met, it is critical that the law requires each Member State to reach zero net emissions within its territory by 2040 at the latest. • Trajectory: the trajectory, set out in Article 3.2 of the proposal, must start from the Union’s 2020 target for climate. The Commission proposal creates two different governance regimes (2020-2030 and 2030-after), which is not acceptable. When setting a trajectory, the Commission must consider the best available science, including the latest reports of the IPCC, and equity principles. • Nature-based solutions and a target for sinks: Nature-based solutions should be at the centre of reaching the climate neutrality target and reaching negative emissions. Relying too heavily on so far uncertain and undeveloped – and from a sustainable development perspective questionable – technologies like CCS or BECCS to reach climate neutrality is not acceptable to the SSNC. These technologies might play a limited future role, but nature-based solutions are available today with strong co-benefits for biodiversity. The climate law should include an objective for protection and restoration of biodiverse ecosystems to enhance the EU’s carbon sink, and task the European Commission to come up with a strategy on nature-based negative emissions. For 2030, the climate law should set – in addition to the emissions reductions target - a separate quantified target to remove CO2 from the atmosphere. Focus should be on protection and restoration of lands and ecosystems to conserve and enhance carbon sinks and stocks in line with Article 5 of the Paris Agreement. • Contribution of all sectors: We agree that “achieving climate neutrality should require a contribution from all economic sectors”. However, the proposal does not reflect this in a satisfactory way. The climate law should include sectoral intermediate targets as well as binding dates for phasing out all exploration, extraction and use of fossil fuels, and fossil fuel subsidies. • Mainstreaming of policy: Mainstreaming of all Union policies in line with the objective of the climate law, as well as removing legal barriers for Member States to phase out fossil fuels, is critical for reaching the objectives of the climate law. Consistency checks of existing and non-existing policies should start as of now (2020) and not post 2030, and the checks should be science based. • Independent scientific body: An independent expert climate panel should be established – enshrined in the climate law - to provide advice in support of the achievement of the objectives of the climate law. • Review clause: A clause which requires the climate law be kept under review in the light of the best available science and the developments to achieve the objectives of the Paris Agreement must be included.
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Response to 2030 Climate Target Plan

15 Apr 2020

Swedish Society for Nature Conservation, SSNC (Svenska Naturskyddsföreningen) welcomes that the EU 2030 climate target will be revised. It is of utmost importance that the proposal for revision is based on the best available science of what is required to keep global temperature rise to 1.5°C. SSNC would like to provide the following feedback on the “INCEPTION IMPACT ASSESSMENT” for the 2030 climate target plan: - The Commission intends to propose increasing the EU’s GHG emission reductions target for 2030 “in line with the ‘do no harm’ principle”. Reducing emissions with 50-55% by 2030 is, however, not in line with such a principle. The IPCC concludes that global emissions need to be at least halved by 2030 compared to 2010 levels if there is to be chance to keep global temperature rise to 1.5°C. The recent UNEP Emissions Gap report underlined that current efforts could only limit global temperature increase to 3°C by the end of the century. The report stressed that to keep temperature rise to 1.5°C all countries need to reduce their GHG emissions annually by 7.6% between now and 2030. This implies a 2030 climate target of at least 65% for the EU. Pairing that with EUs obligations under the Paris Agreement Article 2.2, the Commission must explore options for a new 2030 target of at least 65 to 70% emission reductions compared to 1990. - It will be critical that the planned revision of implementing legislation, including the Emissions Trading System, the Effort Sharing Regulation, the Land Use, Land Use Change and Forestry Regulation, the CO2 Standards for Cars and Vans, the Energy Efficiency Directive, the Renewable Energy Directive, the Energy Taxation Directive and all forthcoming new policy measures to underpin the delivery of the significantly increased 2030 climate ambition. - The Commission wants to raise the target “in a responsible way”. In this regard, it must ensure that the total economic, social and environmental risks, impacts and costs associated with lack of adequate action is fully taken account for in the impact assessment. Eurostat shows that climate related economic losses amounted up to 11.6 billion euro in 2015 alone [1]. To make an informed choice of what is “a responsible way” to revise the target, costs and benefits of action must be paired with the total cost of inaction for various target levels. - Similarly, to allow for a comparison of the costs associated with near term investments with the longer-term benefits of a certain target level, the discount rates used in the impact assessment must not inflate cost estimates. - To keep international momentum, the Commission should present the impact assessment as early as possible, preferably before September as is suggested. - SSNC is positive towards the Commission exploring if and how a Carbon Border Adjustment can be implemented. However, the process of adopting a new 2030 climate target must not be delayed while a proposal for a CBA is being developed and negotiated. - We welcome the proposal to extend the ETS with the emissions from aviation and shipping. The emissions from these sectors are currently largely unregulated and need to be tackled urgently. However, we do not support the proposal to integrate emissions from road transport and buildings in the ETS. The emissions in these sectors come from a multitude of small sources, and there is no guarantee that an instrument like the ETS will be able to deliver emission reductions in these sectors. The Commission should instead investigate increasing the ambition in the policy instruments already available to these sectors. - We welcome that the initiative will assess how the EU can increase the absorptions of CO2 emissions over time, including in its natural sinks. While doing so, we would like to underline the importance of keeping targets for emission reductions and the increase of CO2 uptake through carbon sinks separate. [1] Eurostat. Sustainable Development in the European Union 2017.
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Response to Access to Justice in Environmental matters

3 Apr 2020

The Swedish Society for Nature Conservation (SSNC) welcomes the roadmap on Access to Justice and emphasize the importance and urgency of the matter. SSNC supports the intention to amend the Aarhus regulation to improve access to justice concerning acts of the EU institutions. This is undeniably necessary for the European Union’s compliance with the Aarhus convention and reaching the environmental ambitions in the treaty. Even if there are good reasons for placing the main burden of settling disputes over EU law on national courts, the system has proven to be malign in quite a few environmental matters. Furthermore, the failure of EU to comply with the Aarhus convention undermines the convention and gives legitimacy to states that consistently fail to grant access to justice to their citizens. The SSNC agrees with the Roadmap’s ambitions to revise the identified shortcomings in the regulation by widening the scope for access to justice when it comes to non-legislative regulative acts and administrative acts and omissions that contravene provisions of environmental law. There are also good reasons to improve the functioning of the review. • The Aarhus Regulation must be changed so that internal review is no longer only available for acts of “individual scope” but also for “acts of general application other than legislative acts”. • The category of administrative acts must be extended to all non-legislative regulatory acts and not only to those that do “not entail implementing measures”. • We strongly support the intention to specify that the administrative acts and omissions covered by the internal review mechanism are those that contravene provisions of environmental law in line with the Aarhus Convention. • The practical application of the Aarhus Regulation has demonstrated that the phrasing “external and legally binding effects” in Article 2(g) is unnecessarily restricting. • Ensure that costs are not prohibitive. We also support the ambitions on improvement of access to justice before national courts, not least for environmental organizations. The situation in most Member States is dire, consuming much of the environmental organizations’ resources and delaying impact of the union’s environmental legislation. We support a new Commission Communication on access to justice in environmental matters, albeit we had wanted a more detailed roadmap on what improvements the Commission wants to pursue. The challenges for environmental organizations, however, will not be overcome by a non-binding guidance document published by the Commission. There is no indication that the Commission’s Access to Justice Notice had a measurable impact. The obstacles for Environmental organizations to access to justice in the Member States are substantial and diverse. In some countries we see governmental initiatives that worsen the situation. The problems range from overly expensive fees to advanced schemes that move decision-making from regular permits to allegedly non-binding plans. In Sweden, a central problem with access to justice is connected to forestry operations. Sweden has immense and increasing problems with forest ecosystems. Every year around 60.000 clear-cutting operations is carried through without permits. The operator only needs to notify the authority, not apply for a permit, except in very few cases. There is in the vast majority of those cases no decisions to appeal against. Recent Swedish caselaw has rejected complaints from environmental organizations when they tried to appeal. If access to justice isn’t strengthened in the Member States, the administrative burden for the Commission and the CJEU can be expected to increase. It must therefore be an integral part of the strategy at least to increase resources for infringement initiatives targeted on inadequate access to justice in the Member States.
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

The Swedish Society for Nature Conservation (SSNC) supports the concept of fully integrating the external environmental cost of products and consumption, including for goods that are imported to the EU. This is not being done in a satisfactory way today and in many EU countries, including Sweden, emissions per capita are higher than perceived if consumption-based emissions are accounted for. Further, SSNC fully supports that economic policy instruments in the EU should favour ambitious climate action and increase costs for environmentally damaging activities regardless of where they occur. A Carbon Border Adjustment (CBA) has the ability to address both of these issues. If designed correctly, it could address the consumption-based emissions embedded in consumption goods being imported to the EU, while at the same time allowing for an appropriate and higher carbon pricing within the EU. Therefore, SSNC is positive towards the European Commission exploring if and how a CBA can be implemented. SSNC holds that a policy tool like CBA likely will be necessary to deliver on the EUs long-term climate goals. SSNC would like to give the following recommendations to the European Commission regarding the development of a CBA: - Supporting a CBA does not imply that SSNC agrees with the notion that the EU industry suffers from carbon leakage, as this is still largely unproven. In this regard, a CBA will need to be complemented by a total phaseout of all free allowances that are currently being distributed to high emitting industries under the EU ETS, taking effect immediately. This must not be compromised. Giving out free allowances goes against the Polluter Pays Principle, and a CBA is therefore a better policy instrument to prevent possible carbon leakage, while allowing for a higher carbon price. - Ideally, the sectoral or product scope of the CBA should be as wide as possible to strengthen the environmental justification of the measure and for the tool to be able to address consumption-based emissions. SSNC recognizes, however, that applying a wide scope initially might increase administrative burden. For the sake of not delaying implementation, SSNC therefore supports that the Commission assess pros and cons of different sectoral or product scopes and, if necessary, make a proposal for a gradual inclusion of sectors starting with 1) carbon-intensive basic goods (e.g., cement, steel) and deforestation risk commodities; 2) industrially processed goods; and 3) others. - To assist the implementation of a CBA, all industries and medium-large companies should start accounting for emissions from the whole value chain, including Scope 3, and the Commission should offer support in this regard. - The sole objective of the CBA must be fighting climate change, and the CBA must not be used as a protectionist measure for EU industry. In this regard, the CBA should apply to imports only, and not also benefit exports. - To avoid that the CBA result in negative equity impacts, it should be possible to grant exemptions for products (excluding hydrocarbons) from Least Developed Countries and countries responsible for a de minimis level of global greenhouse gas emissions. - Revenues from the CBA should be earmarked to further climate action in the EU or to assist affected lower-income countries to cut back on the carbon intensity of their economies. No measure known as a CBA has ever been implemented fully anywhere in the world. Putting in place a CBA is therefore likely going to be a big challenge, from a methodological and possibly legal point of view but also in terms of convincing trade partners of the usefulness and justification of the measure. In this regard, SSNC would like to stress that any reform or adoption of other policy measures, including adopting a new and revised 2030 climate target, must by no means be delayed while a CBA is being developed and negotiated.
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Response to Climate Law

5 Feb 2020

The Swedish Society for Nature Conservation, SSNC (Svenska Naturskyddsföreningen) welcome that the European Commission President Ursula Von der Leyen has announced that tackling climate change is a top priority for the European Commission. SSNC very much welcome the initiative to put in place a Climate Law for Europe. It is of utmost importance that the climate law is legally binding, that it is based on best available science, and that it ensures a review of EU climate and energy policies every five years, in line with the five year global stocktake under the Paris Agreement. In more detail, SSNC would like to provide the following feedback on the Roadmap for the initiative "Climate Law": - The Climate Law should include a binding target of reaching climate neutrality by 2040. Reaching climate neutrality by 2050 is not in line with what is required from a developed region like the EU to pursue efforts to limit global warming to 1.5 degrees Celsius. - The Climate Law should include an enhanced 2030 target from at least 40% to at least 70 % GHG emissions reduction compared to 1990 levels and not including off-setting. Reducing emissions with 50-55% by 2030 is not in line with what is required from a developed region like the EU to pursue efforts to limit global warming to 1.5 degrees Celsius above pre-industrial levels. - Nature-based solutions should be at the centre of reaching the climate neutrality target and reaching negative emissions. Relying too heavily on so far undeveloped - and from a sustainable development questionable - technologies like CCS or BECCS to reach climate neutrality is not acceptable to the SSNC. These technologies might play a limited future role, but nature-based solutions are available today with strong co-benefits for biodiversity. The Climate Law should include targets for protection and restoration of ecosystems to enhance the EUs carbon sink, and task the European Commission to come up with a strategy on natural negative emissions. - The Climate Law should include a five year review mechanism for EU climate and energy policies, in line with the five year global stocktake under the Paris Agreement. The review mechanism should guarantee no backsliding. - The Climate Law should include sectoral and intermediate targets on the way to reducing emissions with 65% by 2030 and reaching climate neutrality by 2040. Binding phase out dates for ending all exploration and use of fossil fuels is in this regard a necessity. - The Climate Law should ensure policy coherence, which means mainstreaming of climate policy and the removal of legal barriers e.g. for Member States to phasing out fossil fuels. Related to this, the climate law should ensure the removal of all subsidies, tax breaks, and other financial benefits for fossil fuels - An independent scientific advisory and monitoring body should be established to monitor the implementation of the climate law. - The Climate Law should include an obligation for meaningful engagement of civil society and citizens
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

Please see attached file
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Response to A new Circular Economy Action Plan

20 Jan 2020

SSNC respond to the public consultation on the new Circular Economy Action Plan Swedish Society for Nature Conservation (SSNC) welcomes the new Circular Economy Action Plan and its ambition to speed up the transition and to empower the citizens and SMEs with the right to reliable, verifiable and comparable information on the products sustainability and environmental footprint for informative decisions. The new Action Plan is also in good agreement with the Green Deal, which highlights a fast transfer to a circular economy, clean energy, resource efficiency and zero pollution, as basis for a toxic-free environment. Following actions are necessary to reach the circular goal: - Reduction of virgin resources used. - Transparency of chemical content for safe usage, reuse and waste treatment. - Ban of SVHC substances in articles to include imported ones. - Taxes on characteristics that reduce the circularity of the product. - Citizens’ inclusion and facilitation of sharing economies. Further recommendations are found in SSNCs report “Towards a safe circular economy without hazardous chemicals”.
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Meeting with Miguel Arias Cañete (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

21 Jan 2019 · Implementation of the RED Directive

Response to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters

5 Jun 2018

The Swedish Society for Nature Conservation (SSNC) wants to underscore the necessity of bringing the Aarhus regulation into full compliance with the Aarhus convention. This is of utmost importance to safeguard the integrity of European environmental law and access to justice in environmental matters throughout the Union. Upholding highly questionable exemptions for EU institutions is damaging for environmental rights in the Member States. Double standards weaken the legitimacy of the rules and the EU institutions’ function as guardians of fundamental rights in the environmental field. SSNC especially wants to point out the findings of the Aarhus Convention Compliance Committee in March 2017, when the Committee found the EU to be in violation of the Aarhus Convention by failing to provide members of the public with access to the EU courts (CJEU). The findings of the Committee are unequivocal: The EU fails to comply with the Convention and is recommended to amend the Aarhus Regulation (or adopt new legislation) in the absence of a change in jurisprudence of the CJEU. SSNC does not agree with the legislation being “already complete” as stated in the Roadmap. The EU system of remedies suffers from considerable shortcomings. As recognized already in the Aarhus Compliance Committee findings in 2011, the preliminary reference system under Article 267 TFEU does not meet the requirements of Article 9(3) of the Convention. Over the last years, the CJEU has further consolidated its case law in claims brought by NGOs, thereby clarifying that members of the public have no standing under Article 263 TFEU to challenge acts and omissions of EU institutions that are not addressed directly to them. The Aarhus Regulation is the only remaining avenue for the public – but it remains unduly restrictive in its current form. The situation is therefore clear: (1) The EU is a party to the Aarhus Convention in its own right; it therefore constitutes an integral part of the EU legal order. (2) The EU is in non-compliance with the Convention and therefore violates international law and primary EU law. (3) Based on one of the fundamental principles of the international legal order (article 27 of the Vienna Convention of the Law of Treaties), the EU cannot avoid performing its obligations by invoking its internal law. (4) The only option open to the Commission to remedy this violation of international law is to propose an amendment of the Aarhus Regulation. There is no need to conduct a further assessment of “how access to justice works”. The time for studies is over – it is time to amend the Regulation. A swift and thorough correction of the Aarhus Regulation could set an important example for the Member States, and thereby revitalize the work with implementation of environmental law in the Union.
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Response to Criteria to identify endocrine disruptors for plant protection products

21 Jul 2016

Naturskyddsföreningen, The Swedish Society for Nature Conservation, calls on the EU Commission to make significant changes to the proposed criteria for identifying endocrine disrupting chemicals (EDCs). The current proposal fails to address this pressing public health threat and fulfil the legal mandate to protect the health of humans, animals and the environment from exposure to these chemicals in our daily lives. The proposed criteria requires such a high amount of evidence that it will be nearly impossible to identify more than a small number of substances posing a threat to human health & environment from hormone disruption. In contrast, current lists of potential EDCs include over 800 substances. Over 1300 scientific studies link exposure to EDCs to spiralling rates of hormone-related cancers such as breast or testicular cancer, fertility problems, diabetes, obesity & behavioural problems. The World Health Organization has called EDCs a ‘global threat’. The health costs of diseases associated with EDC exposure are estimated at 158 billion € yearly in the EU. The Commission has ignored the majority of respondents to its 2015 public consultation who supported the most effective use of science to protect humans and wildlife, especially vulnerable groups such as pregnant women, babies and children. In the 7th Environmental Action program, the EU committed to minimizing EDCs exposure. To achieve this goal, 2 major aspects need to be changed: 1) The Commission proposes to identify EDCs only if they are known to have adverse effects in humans or wildlife not intended to be affected. The word ‘known’ means to have proof. Demanding such proof weakens the current law which says to regulate those substances that ‘may’ cause harm (like for carcinogens that ‘may cause cancer’). Such a high burden of proof blocks expert opinion about the likelihood of an effect and is unacceptable, as it is likely to result in damage to humans and the environment before action is taken. This contradicts the precautionary approach enshrined in the EU Treaty and built into the biocide & pesticides laws. It also clashes with the current successful approach of identifying & ranking carcinogens and chemicals toxic to reproduction. Substances should be identified as EDCs when they are known or presumed to have adverse effects. The Commission should act on the existing scientific knowledge and the best option for health is an approach with 3 categories according to the level of evidence. 2) The Commission proposes widening the current exemption for those pesticides identified as EDCs into a major loophole. Changing `negligible exposure’ to ‘negligible risk´ would allow continued uncontrolled exposure to these EDCs. This is unacceptable. The Commission has gone beyond their identification task, weakening the law by reintroducing specific risk assessments for pesticides identified as EDCs in the future The proposal must be rectified to ensure a high level of protection for health and the environment, preventing endocrine-related diseases for Europeans and averting damage from our ecosystems. France, Sweden and Denmark have already expressed their disagreement http://goo.gl/oU3QDS. The world’s leading experts on EDCs - the Endocrine Society https://goo.gl/MNE4c7 and other scientists http://goo.gl/u0LtIl have strongly criticized the proposal, as have certain industry sectors who believe the criteria should be stronger to identify and phase out potentially harmful materials http://goo.gl/pmYHkh. EDCs are a threat to our society’s current & future public health and prosperity. Europe needs to take a leading role in regulating EDCs, as this will stimulate innovation so that all industries in the various sectors develop and use better and safer alternatives. Our everyday exposure to these chemicals – in our food, cosmetics, homes, work places, schools, & hospitals, must stop to protect the health of current and future generations.
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