Swedish policy positions and perspectives on CBAM

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The document analyzes the EU's proposed Carbon Border Adjustment Mechanism (CBAM), which aims to prevent carbon leakage by imposing a carbon price on imports in sectors like iron, steel, cement, aluminum, fertilizers, and electricity. It specifically examines the phase-out of free EU ETS allowances, the exclusion of export rebates, the scope of emissions (direct vs. indirect), and the crediting of third-country climate policies. Swedish stakeholders are divided: industry groups generally fear competitiveness losses due to the lack of export rebates and the exclusion of Scope 2 emissions, while environmental groups advocate for a faster phase-out of free allowances.

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  • The European Commission proposes a 10-year transitional period from 2026 to 2035 to gradually phase out free allowance allocations under the EU ETS while phasing in the CBAM, with a pilot phase from 2023 to 2025 focused on reporting.
  • Swedish stakeholders hold divergent views on the timeline for phasing out free allowances: the Swedish Society for Nature Conservation wants an immediate end after the pilot phase, while others like LKAB suggest a faster phase-out by 2030, and Kubal requests a delayed timeline.
  • The CBAM proposal excludes export rebates to avoid being viewed as a protectionist subsidy and to remain compatible with WTO rules, but Swedish industry stakeholders argue this puts EU exports at a competitive disadvantage in international markets.
  • The current proposal only covers direct emissions (Scope 1), excluding indirect emissions (Scope 2). Swedish industry stakeholders, including the Confederation of Swedish Enterprise and the Swedish Steel Producers’ Association, argue that this exclusion harms the competitiveness of Swedish industry as it decarbonizes and relies more on electricity.
  • The EU proposal allows for the crediting of carbon pricing policies from third countries to avoid double charging, but it does not include non-pricing regulatory policies due to administrative complexity and the risk of tilting the competitive field.

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APA
Gallegos, M. B., van Asselt, H., & Suljada, T. (2022). Swedish policy positions and perspectives on CBAM. Stockholm Environment Institute. https://www.sei.org/wp-content/uploads/2022/02/sei-brief-2022-swedish-policy-positions-cbam-3.pdf
Chicago
Gallegos, Maricruz Bravo, Harro van Asselt, and Timothy Suljada. Swedish policy positions and perspectives on CBAM. Stockholm Environment Institute, 2022. https://www.sei.org/wp-content/uploads/2022/02/sei-brief-2022-swedish-policy-positions-cbam-3.pdf.
Wikipedia
{{cite report |last1=Gallegos |first1=Maricruz Bravo |last2=van Asselt |first2=Harro |last3=Suljada |first3=Timothy |title=Swedish policy positions and perspectives on CBAM |publisher=Stockholm Environment Institute |date=February 2022 |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{gallegos2022swedish, author = {Gallegos, Maricruz Bravo and van Asselt, Harro and Suljada, Timothy}, title = {{Swedish policy positions and perspectives on CBAM}}, institution = {Stockholm Environment Institute}, year = {2022}, month = feb, 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} }

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