Comments on the European Commission's draft delegated act on climate - related objectives in taxonomy

The Swedish Peat Association is a collaborative organization for Sweden’s peat producers and peat consumers. Peat is a highly sought-after and necessary raw material both in Sweden and the rest of Europe for many uses; growing media and soil improvement in professional horticulture, hobby growing and cultivation of forest plants, litter in animal husbandry and for energy purposes. Peat is also important for Sweden’s preparedness in times of crisis.

In Sweden, there are 6 million hectares of peatland, which constitutes 25% of Sweden’s area. Of this area, 2.6 million ha are affected by ditching. That so much of Sweden’s peatlands are affected is due to a 100-year government project for increased food and forest production. The side effect is that this ditched land today emits more greenhouse gases than all of Sweden’s domestic traffic. On 2 ‰ (12,000 hectares) of these ditched peatlands, peat is harvested today. Swedish climate-adapted peat extraction activities only take place on previously ditched land and these areas are always restored afterwards.

This makes the members of The Swedish Peat Association to the primary restorers of damaged wetlands in Sweden. This restoration is guaranteed by allocating money before each extraction site start-up and by adapting production so that the best possible nature and climate benefits are achieved for landowners and society. In addition to the efforts of our members, the restoration of damaged wetlands into carbon sinks is slow in Sweden. In addition to cost reasons, this is because many of the huge areas that need to be restored are inaccessible.

If peat extraction is minimized according to the taxonomy, the work of re-wetting and restoring wetlands, which means that these emissions are stopped, will take longer time and be very costly for taxpayers. Today, Sweden and the EU receive a free climate and sustainability service from our member companies.

We believe that there is every reason to classify the carbon sinks, that the peatland restoration results in, as negative emissions. In Swedish Government Official Report, SOU 2020:4, negative emissions are classified as follows:
“Negative emissions occur if human activity leads to the uptake of carbon dioxide in addition to the uptake that would otherwise have occurred naturally in the carbon cycle. Negative net emissions of carbon dioxide occur when a larger amount of carbon dioxide is removed from the atmosphere through human activity than the remaining human-caused emissions.”
The Swedish Peat Association considers that the taxonomy ordinance in its current form should not be adopted for the following reasons:

  • Peat should be considered a resource. We get the greatest positive climate effect by restoring the emitting ditched peatlands to become efficient carbon sinks and valuable environments for plants and animals with high biodiversity by first harvesting the peat and then restoring the area.
  • The restorations that are made on already ditched peatland must be classified as negative emissions.
  • Via the substitution, where renewable products and materials replace more climate-damaging alternatives, peat has an obvious place as it refines other circular materials to become resources in growing media and soil improvers giving better soil health and higher carbon storage. Peat as part of litter for animals is also reducing ammonia emissions.
  • The emissions and savings included in LULUCF shall include Peat Extraction Management so that the climate effects of all land use and not just agriculture and forestry are registered and monitored.
  • Peat extraction in Sweden is conducted in a unique, sustainable and climate-adapted way for Europe in only already ditched peatland, which is a high national concern and should therefore be followed up and reported.
  • The encroachments on property rights are too great.
  • Sustainable and fossil-free activities risk being classified as unsustainable, such as bioenergy.