Swedish Government Implements Supplementary Rules To Facilitate Permit Processes For Strategically Important Industries.

Stockholm; January 2026: Proposals for supplementary provisions to the EU Regulation on Critical Raw Materials and the EU Regulation on Net Zero Industries are now being submitted. The proposals aim to ensure that the rules on contact points, permit processes and deadlines are implemented in the Swedish system. The proposals are in line with the government’s efforts to facilitate permit processes for strategically important industries.

“The pace of the permit processes must increase, otherwise we have no chance in global competition. Approximately SEK 240 billion of the industry’s investments in transition are currently in some form of permit process. The government is now taking measures to ensure that Swedish companies can grow and invest for the future”, says Minister of Energy and Enterprise Ebba Busch. “High speed in permit processes is important for our competitiveness. The business community is demanding faster and more predictable permit processes, and that is precisely what the contact points for strategically important industries should contribute to”.

The government has previously assigned six county administrative boards to be contact points under the EU Regulation on Critical Raw Materials and the EU Regulation on Net Zero Industries. The memorandum that has now been sent out for consultation makes supplementary proposals aimed at ensuring that the EU regulations function as intended in Sweden. This concerns the contact points and deadlines for permit processes in the first instance, as well as the special provisions on environmental assessments.

The supplementary provisions are proposed to enter into force on 1 October 2026. To further strengthen the conditions for the net-zero industry, the government has previously decided on a regulation that clarifies the process for recognizing strategic net-zero projects. The regulation designates the Swedish Agency for Economic and Regional Growth as the responsible authority for recognizing strategic projects with regard to manufacturing projects for net-zero technology. It also includes projects in certain sectors that reduce carbon dioxide equivalent emissions from energy-intensive industry.

The Geological Survey of Sweden is designated as the responsible authority for the recognition of strategic projects within the carbon dioxide value chain. This includes projects for carbon dioxide ‘storage’, carbon dioxide ‘capture’ and carbon dioxide ‘transport infrastructure’.

The classification of a project as a strategic net-zero project primarily means that shorter deadlines apply for permit processes. It also means that companies only need to contact one authority that guides them through the entire permit process. The project owner also receives advice on financing the investment, if necessary.

Earlier in December 2024, the Swedish Government had assigned 06 Counties – Västerbotten, Dalarna, Stockholm, Orebro, Vastra Götaland and Skåne counties to be contact points under the EU Regulation on Critical Raw Materials and the EU Regulation on Net Zero Industries. These six county administrative boards had also been the contact points for projects located in other counties. The county administrative boards had a role in several permit processes, such as review under the Environmental Code, and thus acquired the knowledge of permit processing that is now proven to be useful in carrying out the assignment.

Before the government takes a position on a proposal, it is sent for consultation to the relevant authorities, organisations, municipalities and other stakeholders. The government wants to know what those affected think and what support the proposal has. The public also has the right to submit comments. Responses from those who have been asked to respond are published on the website. All responses and statements regarding the consultation are included in the basis for the decisions that follow the consultation.

Supplementary provisions are also proposed that clarify which Swedish permit procedures are covered by the deadlines and how the contact point’s confirmation of a complete application is to be obtained. The memorandum proposes that the supplementary provisions are mainly collected in a new law and associated ordinance. With regard to the provisions of the EU regulations on environmental assessments, it is proposed that information provisions and supplementary provisions be introduced in the Environmental Code.

It is further proposed that information provisions be introduced in the Planning and Building Act (2010:900) and sectoral legislation regulating permit procedures stating that the EU regulations contain provisions on planning and deadlines. This memorandum only deals with those parts of the EU regulations that relate to contact points, deadlines and environmental assessments. The need for constitutional amendments in relation to other parts of the EU regulations is being prepared within the Government Offices.

In April 2025, the Ministry of Climate and Enterprise submitted a memorandum with proposals implementing the Renewable Energy Directive (KN2025/00895). The Government subsequently decided on 11 December 2025 on the legislative council referral Permit review under the Renewable Energy Directive (KN2025/02315). This memorandum provides proposals for provisions on time limits for a land and environmental court’s first instance processing of applications for permits for environmentally hazardous activities or water activities relating to renewable energy. The provisions are needed for, and complement, the implementation of the Renewable Energy Directive.

The constitutional amendments in the memorandum are proposed to enter into force on October 1, 2026.

Suvro Sanyal

Team Maverick.