Sweden

Status of the current legislative process

No draft implementation has been published yet. There are currently no further information available with regards to the timeline.  

The Swedish Government has appointed an inquiry chair to consider how the EmpCo rules should be implemented in Sweden. This assignment includes assessing the need for amendments to current legislation as well as other measures, and, if necessary, proposing new legislation. The inquiry chair shall provide its report by 15 December 2025. 

Link to the draft (if available) 

N/A

Does the implementation go beyond EmpCo requirements? 

No

Are there any comments from relevant authorities on the interpretation or enforcement of the national implementation?  

No

Will the national implementation be applied in a Business-To-Business (B2B) context? 

Likely yes.  

Please note that the Swedish Marketing Practices Act (SFS 2008:486), which currently governs green claims, applies to both B2C and B2B contexts. 

Is there a green claims guide/guidance in your country? 

The Swedish Consumer Agency (Sw. Konsumentverket) has published guidance on the current legislation on green claims on its website (available in Swedish here). This guidance has not been modified to address the EmpCo rules.  

What are the sanctions and penalties?  

There is no Swedish draft legislation available yet. However, under the current Swedish legislation, companies can be sanctioned with a prohibition to cease unlawful marketing practices (which can be combined with a fine), marketing disruption fees ranging between SEK 10,000 and 4% of the company’s turnover, and damages from consumers and other traders. 

Does the national implementation answer the following questions:  

(1) whether sustainability labels can take the form of text; 
(2) whether generic environmental claims can be used or are they banned unless you have recognised excellent environmental performance; 
(3) whether GHG impact claims based on GHG offsets are banned only if offsets are the sole basis, or even if offsets and GHG reductions are combined.

There is no Swedish draft legislation available yet.