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Is your activity covered?
- Environmental report: permit holders. Anyone who runs an environmentally hazardous activity that requires a permit (A or B under the Swedish Ordinance on Environmental Permits and Notifications, SFS 2013:251) must submit an annual environmental report to the supervisory authority every year (chapter 26, section 20 of the Swedish Environmental Code).
- Also without a permit if the activity is listed in Annex I to the EU's E-PRTR Regulation (166/2006), for example combustion with a thermal input of at least 50 MW. An environmental report is then submitted every year under section 2 of NFS 2016:8.
- Self-monitoring: everyone. The requirement in chapter 26, section 19 of the Environmental Code to plan and check the activity applies to everyone who can affect the environment. The ordinance SFS 1998:901, with its documentation requirements, applies to professional activities that require a permit or a notification (section 1).
- A registered boiler without a permit: a medium combustion plant that is only notified and registered submits no environmental report. The self-monitoring and the measurement requirements in the Swedish Ordinance on Medium Combustion Plants (SFS 2018:471) still apply.
What must the environmental report contain?
The environmental report covers a calendar year and is submitted in the Swedish environmental reporting portal (SMP), where the parts are called the basic part, the emission declaration and the text part. What each part must contain is set out in sections 4–5 l of NFS 2016:8. Measurement data belong in the text part and, for some activities, in the emission declaration and the sector annexes.
| Part | What must be included | Measurement data that belong here |
|---|---|---|
| Basic part (section 4) | Operator and company registration number, plant, supervisory authority, activity codes and contact persons | No measurement results |
| Text part (section 5) | Fifteen points, among them the conditions in force and how each has been complied with (point 7), a commented summary of the year's measurements, calculations and investigations (point 8) and the measures taken after disturbances (point 10) | The results of periodic measurements and continuous measurement, compared with the conditions, with the measurement method and uncertainty |
| Emission declaration (section 5 a) | Activities in Annex I to the E-PRTR Regulation: the annual emission of every parameter that passes the threshold, marked M (measured), C (calculated) or E (estimated), with the method | Annual emission in kg: concentration × flue gas flow × operating time, see the thresholds |
| Industrial emissions activities (section 5 b) | Which BAT conclusions apply and how the activity complies with them, from the year after the conclusions were published | Measurements against the BAT conclusions' BAT-associated emission levels (BAT-AELs) |
| Large combustion plants (section 5 c and annex 2) | Per plant: type, commissioning, rated thermal input, fuel in GWh and operating hours | SO2, NOx and dust in kg per year, as averages before validation (section 94 of the Swedish ordinance SFS 2013:252) |
| Waste incineration (annex 3) | Per plant: capacity in tonnes per hour, hazardous and non-hazardous waste incinerated | The emission figures in the report refer to averages before validation (section 106 of the Swedish ordinance SFS 2013:253) |
The text part is uploaded as a PDF in SMP. An approver with authorisation in SMP approves and submits the report.
Key dates
The dates for the environmental report are in section 6 of NFS 2016:8; the dates of the measurements themselves are set by the permit and the monitoring programme.
| When | What applies |
|---|---|
| 31 March | The environmental report for the previous calendar year must have been submitted in SMP. |
| Extension | On special grounds the supervisory authority can grant at most one month for the basic part and the emission declaration (sections 4 and 5 a) and at most three months for the other information. |
| Late report | Environmental sanction charge: SEK 2,000 for A activities and SEK 1,000 for B activities (chapter 12, section 5 of the Swedish ordinance SFS 2012:259). |
| When the permit is taken into use | The monitoring programme must be ready, with measurement methods, measurement frequency and evaluation methods, and be revised as needed (Land and Environment Court of Appeal, MÖD 2003:131). |
| Immediately | Inform the supervisory authority of a disturbance or similar event that may cause harm to health or the environment (section 6 of the Swedish ordinance SFS 1998:901). |
| Five years | How long the documentation of measurements (section 5 of NFS 2021:6) and the basis for the emission declaration (section 5 a of NFS 2016:8) are kept. The Swedish Ordinance on Medium Combustion Plants (SFS 2018:471) requires six years (section 56). |
| 1 January 2028 | EU Regulation 2024/1244 on an Industrial Emissions Portal replaces the E-PRTR Regulation. The thresholds remain. The reporting for 2026 is still done under 166/2006. |
How often must you measure?
How often the emissions must be measured is set out first of all in the permit conditions and in the monitoring programme. A permit must contain provisions on emission checks, with measurement method, measurement frequency and evaluation method (chapter 22, section 25 of the Swedish Environmental Code). If the permit says nothing, the minimum requirements of the sector ordinances apply, and they always apply on top of the permit.
| Regulations | Parameters | At least this often |
|---|---|---|
| Medium combustion plants, 1–50 MW (SFS 2018:471) | NOx, SO2 and dust where a limit value applies, and always CO | Every three years up to 20 MW, every year above 20 MW (section 43) |
| Large combustion plants, 50 MW and more (SFS 2013:252) | SO2, NOx and dust, and CO with gaseous fuel | Continuously from 100 MW (section 21), otherwise every six months (section 24). Permanently installed measuring systems are checked by parallel measurement every year (section 27) |
| Waste incineration (SFS 2013:253) | Dust, TOC, HCl, HF, SO2, NOx and CO continuously; metals, mercury and dioxins periodically | Metals and dioxins twice a year, every three months during the first twelve months of operation |
| The Swedish NOx charge (NFS 2016:13) | NOx and flue gas flow, in parallel with your own measuring equipment | Once per calendar year, every third year below 2,000 operating hours per year |
| Permanently installed measuring systems (EN 14181) | The parameters measured continuously | QAL2 at least every five years, AST every year |
The County Administrative Boards also describe a periodic inspection by an impartial and competent inspector under the monitoring programme, at an interval that is usually one to three years.
How to get measurement data that hold up in the environmental report
Read the permit and the monitoring programme
They set out the conditions, which parameters are to be measured, how often, with which method and how the result is evaluated: as an average over a day, a month or a year. If there is no monitoring programme, the supervisory authority can ask you for a proposal (chapter 26, section 19 of the Swedish Environmental Code).
Plan the year's measurements
Schedule the periodic measurements when the plant is in representative operation and so that the results are in before 31 March. The comparison measurement for the Swedish NOx charge and the AST can be done on the same visit.
Measure with standard methods
Use the methods that regulations, a court ruling or the permit specify, otherwise methods according to a Swedish or international standard (section 4 of NFS 2021:6). Document the requirements, method, equipment, operating conditions, time, place and results (section 5). METLAB measures according to the EN standards, accredited by Swedac, and delivers the report digitally signed.
Convert to the form of the condition
The measured value is converted to mg/Nm3 dry gas at the permit's reference oxygen content and to the averaging period of the condition. The annual emission in kg is concentration × flue gas flow × operating time, so the flue gas flow must be measured or calculated on the same occasion.
Compare with the conditions and act
If a value lies above the condition: find the cause, correct it, and inform the supervisory authority in the way the permit and section 6 of SFS 1998:901 require. Measure again once the fault has been corrected.
Write and submit the environmental report
Report how each condition has been complied with (point 7) and summarise the measurements with comments (point 8). Fill in the emission declaration if the activity is covered. The approver submits the report in SMP by 31 March.
Keep the records
Measurement reports, operating data and calculations are kept for at least five years, so that every figure in the environmental report can be traced back to the measurement.
Thresholds in the emission declaration
The emission declaration is submitted by activities in Annex I to the E-PRTR Regulation (166/2006): among others combustion with a thermal input of at least 50 MW and incineration of non-hazardous waste above 3 tonnes per hour. It states the annual emission to air of every parameter that passes its threshold (section 5 a of NFS 2016:8). The thresholds are in Annex II to the E-PRTR Regulation; for some of them Sweden has lower values in annex 1 to NFS 2016:8. If the emission is below the threshold, no value is entered in the declaration, but it must still be reported in the text part if a condition applies.
| Parameter | Threshold to air, kg per year | Source |
|---|---|---|
| NOx (as NO2) | 10,000 | Annex 1 to NFS 2016:8 (E-PRTR: 100,000) |
| SO2 (SOx) | 150,000 | E-PRTR Annex II |
| Dust (PM10) | 50,000 | E-PRTR Annex II |
| CO | 500,000 | E-PRTR Annex II |
| CO2 | 100 million | E-PRTR Annex II |
| N2O | 10,000 | E-PRTR Annex II |
| CH4 | 100,000 | E-PRTR Annex II |
| NH3 | 1,000 | Annex 1 to NFS 2016:8 (E-PRTR: 10,000) |
| NMVOC | 5,000 | Annex 1 to NFS 2016:8 (E-PRTR: 100,000) |
| HCl (inorganic chlorine compounds) | 10,000 | E-PRTR Annex II |
| HF (inorganic fluorine compounds) | 5,000 | E-PRTR Annex II |
| Mercury (Hg) | 0.1 | Annex 1 to NFS 2016:8 (E-PRTR: 10) |
| Cadmium (Cd) · Lead (Pb) | 0.1 · 5 | Annex 1 to NFS 2016:8 (E-PRTR: 10 · 200) |
| Dioxins and furans (PCDD + PCDF, as TEQ) | 0.000001 | Annex 1 to NFS 2016:8 (E-PRTR: 0.0001) |
Every value is marked M (measured), C (calculated) or E (estimated), and the method is stated. The basis is kept for five years (section 5 a). From 1 January 2028 EU Regulation 2024/1244 applies instead of the E-PRTR Regulation, with the thresholds retained.
Permit conditions, limit values and measurement uncertainty
A condition in the permit is binding. Breaching it is the offence of unlawful environmental activity, punishable by a fine or imprisonment for at most two years (chapter 29, section 4 of the Swedish Environmental Code). The Land and Environment Court of Appeal has ruled that emission conditions are to be written as limit values (begränsningsvärden), that the older Swedish terms gränsvärde and riktvärde (limit value and guideline value) are no longer to be used, and that it must be possible to establish objectively when a breach has occurred (MÖD 2009:9). The framework for the checks, such as the averaging period and the measurement frequency, is therefore stated in the condition and the details in the monitoring programme.
The Environmental Code has no general rule for how the measurement uncertainty is handled when a measured value is compared with a condition. That is decided by the wording of the condition and the monitoring programme. The sector ordinances have their own rules: at periodic measurement under the Swedish Ordinance on Medium Combustion Plants (SFS 2018:471) the value is complied with if the measurement results show that it has not been exceeded, without any deduction for measurement uncertainty (section 51), while validated averages from continuous measurement are compared with the value after a deduction (sections 52 and 53). Our report states the measured value with its expanded measurement uncertainty, so that you and the supervisory authority can make the comparison in the way the condition specifies.
If a condition is exceeded
If a measurement shows that a condition is not complied with, you must find the cause and put it right; self-monitoring is meant to prevent and counter harm (chapter 26, section 19 of the Swedish Environmental Code). A disturbance or similar event that may cause harm to health or the environment must be reported to the supervisory authority immediately (section 6 of SFS 1998:901). The permit can also have a condition on how exceedances are to be reported, and SFS 2018:471 requires the supervisory authority to be informed as soon as possible, together with an account of the measures taken (section 55).
In the environmental report the exceedance is reported under the condition (section 5, point 7 of NFS 2016:8) and the measures after a disturbance under point 10. Giving incorrect information in the environmental report is a criminal offence, obstruction of environmental control (chapter 29, section 5). Once the fault has been corrected, a new measurement shows whether the condition is complied with.
How the annual emission is calculated
The emission declaration and the annexes for large combustion plants and waste incineration state the emission as mass per year. The concentration from the measurement (mg/Nm3 dry gas) is multiplied by the dry flue gas flow (Nm3/h) and by the operating time (h per year) and divided by a million, which gives kg per year. If the plant runs on several fuels or loads, each operating condition is calculated separately and the results added up. At continuous measurement, the validated hourly averages are multiplied by the flow for each hour and summed.
The flue gas flow is therefore as important as the concentration. At our periodic measurements we determine it with a pitot tube according to EN ISO 16911-1 and report the mass flow in kg/h in the report. With the operating time from your operating log we calculate the annual emission when you ask for it, and in the emission declaration the figure is marked as measured (M) with the measurement method stated.
What does a measurement for the environmental report cost?
The price depends on how many sampling locations and operating conditions the permit requires, which parameters are to be measured, how many sub-samples the condition specifies and what the measurement site is like. Measurements that the permit, the sector ordinances and the Swedish NOx charge require can be made on the same visit, and the price per measurement is then lower. The calculation of the annual emission is included when you ask for it. Request a quote – we reply within two working days. Approximate prices for the most common measurements are in the price guide.
Frequently asked questions about environmental reporting and self-monitoring
When must the environmental report be submitted?
By 31 March of the year after the calendar year the report covers, electronically in the Swedish environmental reporting portal (section 6 of NFS 2016:8). On special grounds the supervisory authority can grant an extension: at most one month for the basic part and the emission declaration and at most three months for the text part.
Who has to submit an environmental report?
Anyone who runs an environmentally hazardous activity that requires a permit, that is A and B activities (chapter 26, section 20 of the Swedish Environmental Code), and activities in Annex I to the E-PRTR Regulation even if they have no permit (section 2 of NFS 2016:8). A C activity, which requires a notification, normally submits no environmental report but must have self-monitoring under SFS 1998:901.
What is a monitoring programme, and do we have to have one?
The monitoring programme describes how you check that the conditions are complied with: parameters, measurement methods, measurement frequency and evaluation. The supervisory authority can ask you for a proposal (chapter 26, section 19 of the Environmental Code), and the permit can have a condition that a monitoring programme must exist when the permit is taken into use. You are responsible for keeping it up to date even if the authority has not formally adopted it.
Which measurement data belong in the text part?
How each condition has been complied with (section 5, point 7 of NFS 2016:8) and a commented summary of the year's measurements, calculations and investigations (point 8). State the measured value in the unit and averaging period of the condition, the measurement method, the date and the measurement uncertainty, and preferably attach the accredited measurement report.
Do we have to submit an emission declaration?
Only if the activity is listed in Annex I to the E-PRTR Regulation, for example combustion with a thermal input of at least 50 MW or incineration of non-hazardous waste above 3 tonnes per hour. The annual emission of the parameters that pass the threshold is then reported, for NOx 10,000 kg per year in Sweden. Below the threshold no value is entered.
Who may do the measurements?
You are responsible for the checks, and NFS 2021:6 requires methods according to regulations, a court ruling or the permit, otherwise a Swedish or international standard. The permit or the monitoring programme can require an accredited laboratory, and for the comparison measurement under NFS 2016:13 one is always required. METLAB is accredited by Swedac for the emission measurements.
What happens if the environmental report is late or wrong?
A late environmental report brings an environmental sanction charge, SEK 2,000 for an A activity and SEK 1,000 for a B activity (chapter 12, section 5 of the Swedish ordinance SFS 2012:259). Incorrect information of significance for supervision can be obstruction of environmental control (chapter 29, section 5 of the Environmental Code).