{"id":1542690,"date":"2022-09-14T10:05:21","date_gmt":"2022-09-14T09:05:21","guid":{"rendered":"https:\/\/www.applia-sverige.se\/?p=1542690"},"modified":"2026-05-27T10:05:51","modified_gmt":"2026-05-27T09:05:51","slug":"oppet-brev-till-var-blivande-miljominister","status":"publish","type":"post","link":"https:\/\/www.applia-sverige.se\/en\/oppet-brev-till-var-blivande-miljominister\/","title":{"rendered":"Open letter to our future Minister of the Environment"},"content":{"rendered":"

14.9.2022

Since the electronics tax was introduced in 2017, we in both the white goods industry and other electronics industries have struggled with its consequences. Our costs have increased, the administration is unsustainable and the regulations are complicated. But our biggest concern is not primarily the parts that affect us \u2013 our concern is instead about the environment. The tax does not drive towards an improved environment, it risks worsening it instead. We are not alone in our criticism of the electronics tax. Expert authorities have aired their concerns and criticism on several occasions. Despite this, the previous government's response has been to raise the tax on several occasions. We now appeal to you as Minister of the Environment to take the environmental issue seriously and work to abolish the tax \u2013 because there are many measures that would have a greater effect than an ineffective tax that does not contribute to the environmental benefits it is intended to achieve.<\/strong><\/p>\n\n\n\n

Good intentions with poor outcomes<\/strong><\/h3>\n\n\n\n

When the government introduced the electronics tax, it was done with the aim of reducing the presence of environmentally and health-hazardous substances in people's home environments. By taxing goods that contain certain substances, the electronics tax would function as an economic instrument to minimize people's exposure to the hazardous substances and promote the use of less hazardous substances. We understand that the intention of the tax was good, but the outcome has shown major shortcomings that important consultation bodies warned about in the very first consultation round. The tax has been designed so that the tax amount is determined based on the type and weight of the goods. Even though certain products, such as heavier white goods, sometimes contain less hazardous substances, these are therefore taxed more heavily.<\/p>\n\n\n\n

The flame retardants that are taxed are included in the products to make them fireproof. The assumption that all additive flame retardants pose a higher risk than reactively added flame retardants is also incorrect and risks leading to false substitution as the tax only targets certain types of flame retardants. The flawed deduction rules, which only allow deductions of up to 90 percent, also mean that even products that do not contain the hazardous substances may be taxed. At the same time, other, lesser-known but potentially more dangerous, substances may escape tax because they are not included in the list of taxable substances. The above are typical examples of how the tax misses the mark and risks steering manufacturers towards using more hazardous substances.<\/p>\n\n\n\n

We are not alone in our criticism.<\/strong><\/h3>\n\n\n\n

Criticism has been directed from several quarters. Even before the electronics tax was introduced, the Swedish Tax Agency warned in its consultation response that \u201dthe tax is not considered to be cost-effectively designed\u201d. Other important consultation bodies also dismissed the proposal. Despite this, the tax was introduced, with the promise that it would be evaluated. However, the evaluation had to wait until 2020 and was only carried out after considerable pressure from the Riksdag.<\/p>\n\n\n\n

The Swedish Tax Agency and the Swedish Chemicals Agency, which carried out the evaluation, concluded, among other things, that the tax was not cost-effectively designed, that the tax did not reduce the substances that were intended to be reduced, and that the administrative burden was unusually high. A logical consequence of the criticism should have been to abolish the tax, but the response given has instead been to increase it on several occasions. Even before the evaluation, the tax on white goods had been increased by a full 40 percent. There are currently proposals for two further increases that will be considered in the Riksdag during the autumn. This would be a severe blow to an already established industry.<\/p>\n\n\n\n

The measures must be targeted where they will have a real impact<\/strong><\/h3>\n\n\n\n

We take the work of reducing harmful substances very seriously. We are constantly working to improve the sustainability of products and reduce harmful substances in our products. And we have succeeded. Sweden is at the top of the world in terms of both the collection and recycling of white goods and other electronic products, and we will continue to pursue this work. Therefore, political measures are needed that give us the conditions for this and that are directed where they will have an effect \u2013 not symbolic politics that make the transition more difficult.<\/p>\n\n\n\n

The electronics tax is not, and has never been, a working tool for reducing exposure to hazardous substances in electronics. The products that are taxed are manufactured for a global market and the Swedish market is not large enough for national excise taxes to force manufacturers to adapt their products. On the other hand, the electronics tax has put pressure on the Swedish market and the increased costs have led to lost sales and lost jobs.<\/p>\n\n\n\n

Hazardous substances should be banned or restricted, and from APPLiA's perspective, we see that this must primarily take place at the EU level, where it has a real impact. Examples of such successful work are what is happening within the framework of REACH and RoHS and, most recently, in the work to ban PFAS substances, where Sweden, among others, has been a driving force. Thanks to international legislation, many hazardous substances such as heavy metals have been greatly reduced in waste management. This is where Sweden should focus its efforts.<\/p>\n\n\n\n

Until the tax is completely abolished, APPLiA sees several changes that must be implemented to more effectively meet the purpose of the tax.<\/p>\n\n\n\n