sei-brief-2022-swedish-policy-positions-cbam-3-d385799736793900.pdf

This policy brief by the Stockholm Environment Institute examines the European Commission's proposal for a Carbon Border Adjustment Mechanism (CBAM) and analyzes its implications for Swedish climate goals and industrial competitiveness. It focuses on four critical areas: the phase-out of free allowances, the exclusion of exports, the scope of emissions covered, and the crediting of third-country climate policies, while detailing the divergent perspectives of Swedish industry and environmental stakeholders.

• The European Commission proposes a 10-year transitional period from 2026 to 2035 to gradually phase out free allowance allocations while phasing in the CBAM. During the pilot phase from 2023 to 2025, importers have no financial obligations but must report embedded emissions and any carbon price paid in the country of origin. Starting in 2026, free allowance coverage will drop from 100% to 90%, decreasing by 10 percentage points annually until a full phase-out in 2035.
• Swedish stakeholders hold conflicting views on the timeline for phasing out free allowances. The Swedish Society for Nature Conservation advocates for an immediate end to free allocations after the 2023–2025 pilot phase. Conversely, the Swedish Steel Producers’ Association (Jernkontoret) argues that replacing free allocations with CBAM without export rebates will increase costs and harm the competitiveness of export-oriented industries, suggesting the CBAM's functionality be evaluated first.
• The CBAM proposal excludes export rebates, meaning it only applies to imports into the EU. This creates a risk for Swedish industry, as most covered products and downstream goods are exported to third countries. Stakeholders such as the Confederation of Swedish Enterprise, SSAB, and Vattenfall argue that this exclusion could place European products at a competitive disadvantage and lead to the displacement of low-carbon products by carbon-intensive foreign alternatives.
• The current CBAM proposal only includes direct emissions (Scope 1), initially excluding indirect emissions (Scope 2). Because Sweden has not introduced compensation schemes for indirect electricity costs—unlike other EU Member States—Swedish industry stakeholders, including the Confederation of Swedish Enterprise and the Swedish Steel Producers’ Association, are calling for the inclusion of Scope 2 emissions to prevent a competitive disadvantage.
• The EU proposal allows for the crediting of third countries' climate policies, but restricts this specifically to carbon pricing policies, such as national or subnational carbon taxes or emissions trading systems. The Swedish National Board of Trade (Kommerskollegium) has expressed concerns regarding the justifiability of the CBAM under the General Agreement on Tariffs and Trade (GATT) due to the different treatment of various types of climate policies.

APA

Stockholm Environment Institute (n.d.). sei-brief-2022-swedish-policy-positions-cbam-3-d385799736793900.pdf. https://www.sei.org/wp-content/uploads/2022/02/sei-brief-2022-swedish-policy-positions-cbam-3.pdf

Chicago

Stockholm Environment Institute. sei-brief-2022-swedish-policy-positions-cbam-3-d385799736793900.pdf. n.d. https://www.sei.org/wp-content/uploads/2022/02/sei-brief-2022-swedish-policy-positions-cbam-3.pdf.

Wikipedia

{{cite report |author=Stockholm Environment Institute |title=sei-brief-2022-swedish-policy-positions-cbam-3-d385799736793900.pdf |url=https://www.sei.org/wp-content/uploads/2022/02/sei-brief-2022-swedish-policy-positions-cbam-3.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{stockholmenvironmentinstitutendseibrief2022swedishpolicypositionscbam3d385799736793900pdf, author = {{Stockholm Environment Institute}}, title = {{sei-brief-2022-swedish-policy-positions-cbam-3-d385799736793900.pdf}}, institution = {Stockholm Environment Institute}, url = {https://www.sei.org/wp-content/uploads/2022/02/sei-brief-2022-swedish-policy-positions-cbam-3.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }