Shipping 2026

SWEDEN Law and Practice Contributed by: Michele Fara, Ninos Aho, Paula Bäckdén and Anders Leissner, Advokatfirman Vinge KB

As a general rule, the company can leave the ton - nage tax system after ten tax years at the earliest. A proposal has been made by the government to extend the tonnage tax system to special vessels of a smaller tonnage, such as cable-laying, salvage, ice-breaking and marine work vessels. In addition, cabotage traffic is proposed to be eligible for tonnage tax if subject to “international competition”. If approved by Parlia - ment, the law will be amended on 20 June 2026. 9. Implications of Non-Performance, IMO 2020, Trade Sanctions and International Conflict 9.1 Force Majeure and Frustration Force majeure is not per se an established concept under Swedish law. Instead, whether unforeseeable, uncontrollable and/or extraordinary events will relieve a party from its contractual obligations will depend on the particular circumstances and the relevant contrac - tual terms. However, there are possibilities under the Swedish Contracts Act (1915:218) to modify or set aside contract terms that become excessively oner - ous as a result of circumstances that are typically regarded as force majeure events. 9.2 Enforcement of the IMO 2020 Rule Limiting the Sulphur Content of Fuel Oil Sweden has implemented “IMO 2020”. Notably, the Baltic Sea and the North Sea are so-called sulphur emission control areas (SECAs), which means that vessels are prohibited from using fuel within this area having a sulphur content exceeding 0.10% by weight. The requirements for the sulphur content of fuel used on board are regulated by EU Directive 2016/902, and the applicable Swedish legislation is the Sulphur Ordinance (2014:509). The authority responsible for enforcing the Sulphur Ordinance is the Swedish Trans - port Agency. However, bunker suppliers must be reg - istered under the Sulphur Ordinance with a different agency – the Swedish Chemical Agency. Breach of the Sulphur Ordinance entails an environ - mental penalty fee. The fee varies from EUR2,500 to EUR50,000, depending on the level of sulphur and

the power of the engine of the vessel that used the bunkers. It should be noted that, as of 1 July 2025, it is prohib - ited to discharge water from scrubbers (the purpose of which is to reduce the sulphur content in bunkers) in “open-loop mode” within the territorial waters of Sweden, Denmark or Finland. 9.3 Trade Sanctions Sweden does not have any sanctions of its own. Instead, Sweden applies UN and EU sanctions. Breach of sanctions entails criminal liability in Sweden. Only natural persons can commit a crime in Sweden. Legal persons (eg, companies) can, however, be subject to corporate fines if a sanctions breach has been com - mitted within the ambit of the company’s operations. There is very little public case law in Sweden regard - ing sanctions breaches. The lack of public judgments from sanctions-related commercial disputes may be explained by the fact that most commercial disputes in Sweden are referred to private arbitration. The administration of sanctions is performed by sev - eral agencies, of which the two most prominent are the Inspectorate of Strategic Products and the Nation - al Board of Trade Sweden. There is no mechanism to grant authorisations or permits beyond what the sanctions legislation provides for. The Swedish government has recently taken several steps to enhance the focus on sanctions and sanc - tions compliance amongst agencies, and in business life. Amongst other things, a new sanctions law was enacted in 2025, which, among other things, increased the penalties for sanctions breaches. Trade sanctions against Russia and the non-govern - mental controlled areas of Ukraine have had a large impact on Sweden’s business life, including shipping. The main legal instruments regarding the EU’s sanc - tions against Russia are EU Regulation 833/2014, EU Regulation 269/2014 and EU Regulation 1351/2014. These Regulations contain several provisions specifi - cally targeting shipping and shipping-related services.

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