The transition to a climate-neutral economy has intensified demand for critical raw materials (CRM), prompting the European Union to adopt the Critical Raw Materials Act (CRMA) to secure supply and promote circularity. Among its objectives, the CRMA seeks to accelerate the recovery of CRM from extractive waste. However, the implementation of these ambitions depends on existing legal frameworks that were not designed for large-scale resource recovery. This article examines the institutional and legal challenges arising from the interaction between the CRMA and key areas of EU environmental law, with a particular focus on the Water Framework Directive and EU waste legislation. Through a doctrinal analysis supported by case law and examples from northern Sweden, the paper demonstrates how overlapping regulatory regimes create structural tensions between the CRMA's acceleration logic and established environmental safeguards. Water law imposes strict non-deterioration requirements that may delay or prevent project authorization, while waste law introduces significant uncertainty regarding material classification and marketability. The article identifies structural regulatory tensions: While the CRMA promotes the recovery of CRM and advances circularity and net-zero ambitions, it operates within legal frameworks that impose stringent constraints. In doing so, it effectively collides with environmental protection rules that pursue the same overarching goals, risking the obstruction of circular solutions. This tension reflects deeper inconsistencies in EU law and calls for greater legal coherence, clearer rules, and better alignment between environmental and industrial objectives.

Water is a vital resource that requires long-term legal protection to ensure both ecological values and societal benefits. The European Union’s Water Framework Directive (2000/60/EC) is central to this aim, establishing binding requirements for good ecological and chemical status in all water bodies and legally binding environmental quality standards. Sweden has implemented the Directive into national law; however, its application has been characterized by legal ambiguities, particularly regarding the possibility of considering disproportionate costs in environmental measures. This study examines the scope and application of the disproportionate cost criterion within the context of environmental law and hydropower regulation in Sweden. A comparative overview of the criterion’s application in other EU/EEA countries is also provided. Based on a legal approach, the analysis focuses on how these rules affect hydropower, where the goal of renewable energy production often needs to be weighed against the requirement for ecological recovery. The study concludes that applying the disproportionate costs criterion requires transparency and legal certainty to ensure a fair balance between the social benefits of hydropower and the need for long-term protection of the aquatic environments. To avoid differences in how the criterion is applied in different EU Member States, harmonized guidelines are needed.

The growth of hydrogen infrastructure in Sweden requires navigating a complex permitting landscape. This overview examines the Swedish permitting process for hydrogen-related projects. Key national laws include the Environmental Code (Miljöbalken) for environmental permits, the Seveso Act on major accident prevention, the Flammable and Explosive Goods Act, and the Work Environment Act for occupational safety. The classification of projects under the Swedish Environmental Code determines which authority is responsible for the permit assessment. In this overview, each stage of the consultation and permitting process, from early project planning and stakeholder consultations through application submission, environmental impact assessment (EIA), public notification, and decision are outlined. 

There have been investigations in environmental permit processes in Sweden. Earlier proposals from these investigations, such as SOU 2022:33, focused on improving coordination between authorities and strengthening capacity through a climate permit taskforce. These measures aimed to streamline the handling of climate-related projects such as hydrogen without weakening environmental protection. More recently, SOU 2024:98 proposes a broader restructuring of Sweden’s permitting framework. The inquiry suggests a more unified system, including clearer environmental assessment procedures, strengthened time-management requirements, and a more coordinated organisation for permitting. These changes will respond to persistent challenges such as long processing times and uneven practices across authorities. 

The report discusses these challenges and compares Sweden’s approach with fast-track hydrogen permitting initiatives in Germany and the Netherlands. Together, the findings indicate that while current Swedish regulation maintains strong environmental integrity, further simplification and clearer guidance will be important to accelerate hydrogen investments in line with Sweden’s 2045 climate goals.

Implementing new technologies, such as large-scale hydrogen applications, often represents a challenge for society. For example, when assessing permits for new types of operations, considerable challenges exist, not least in terms of difficulties regarding the degree of hazardousness and what constitutes ‘best available technique’. The less knowledge there is about the activity, the higher the requirements for safety/protective measures typically become. Some guidance can be obtained from the examination of similar activities, but as the assessment must be made on a case-by-case basis, the possibility of analogously applying the process from another type of activity is limited. The environmental permit assessment in Sweden has often been accused for both dragging on and for containing significant elements of unpredictability. For hydrogen applications, the lack of a coherent regulatory framework risks amplifying these challenges, thus creating a situation characterized by a high level of uncertainty and thereby considerable costs, which may threaten the (necessary) investments. This study examines the Swedish environmental permit process with a focus on large-scale hydrogen applications. Using both quantitative methods (a survey distributed to key actors in the hydrogen industry and relevant authorities) and qualitative legal analysis, the study aims to identify potential legal barriers that may hinder the development of hydrogen technologies and, by extension, the green transition in northern Sweden.

A global transition from the current “brown economy” to a “green economy” has been perceived as an ineluctable carbon neutrality strategy to deal with climate change and its global devastating impacts. This global ambition of green economy necessitates large-scale electrification which imposes growing demand for lithium-ion batteries as state-of-the-art energy storage technologies. Thereupon, the developing market of batteries reinforces the concern over the resilient and consistent supply of battery raw materials. By the reason of the interdependencies of all the stages involved in a value chain of a battery, it is critical to identify the battery material supply-disruptive risks and uncertainties, and subsequently to analyze the impacts of the perpetuation of the supply issues on the future market of batteries. In this research study, to contribute to these processes necessary for overcoming the ongoing supply sustainability challenges, the focus is on lithium, nickel, graphite, and cobalt, which are among the battery raw materials with high supply risks. After analyzing and categorizing the driving forces behind the historical and current bottlenecks to their mining production, the regional and global mining production of those battery materials have been predicted for twenty years ahead using three time series forecasting techniques including Seasonal Autoregressive Integrated Moving Average, Holt's linear trend, and Holt-Winters’ methods. Forecasting possible future production trends of those battery raw materials is indisputably imperative to resolve planning strategies while dealing with uncertainties and supply risks. Reliable supply forecasting results provide more uncertainty and risk management achievements since the stakeholders and policymakers can use the outcomes as a source of information in the decision-making process at any stage of a lithium-ion battery value chain.