ness drastically. Most importantly the new regulations are not in line with the EU internal market and therefore not in line with the Rome treaty and the Lisbon agenda. Regional rules are basically not possible for regional shipping.

In a report by the Swedish Maritime Administration, published in May 2008, it concludes that for the pulp and paper industry the regulations will lead to increasing marine fuel costs by 50-80% or by 75% as an average, and to a sea transport cost increase of 30-45%. The report also shows a cost increase for the pulp and paper industry in the range of Euro 2-9/ tonne product. This will lead to an enormous cost increase and amount to 7% ( Table 2) of value added for the forest industry. The Confederation of Swedish Enterprise has showed that for Swedish companies from all sectors, the annual cost is as large as Euro 2. 3 billion ( Table 1) when using marine fuel of 0.1 % instead of 0.5 %.

At the same time the cost benefit for society has been calculated by the Swedish Maritime Administration as Euro 0.7 billion. The measure is therefore 230% more expensive than the value of it. Sustainable development is built on three aspects: environmental, social and economic. In this case, the economic aspect is clearly not fulfilled making the SECA regulation unsustainable.

BACKGROUND

The EU has for a long time put pressure on the UN maritime organization, IMO, to take action to lower sulphur and nitrogen oxide emission levels. The Ceilings Directive sets the emission levels of sulphur and nitrogen oxide for the member states and it is argued that sea transport has to be included in order not to exceed the limits (“ceiling”). Since shipping is an activity where national borders have little importance and where around 80% of the world fleet is flagged with non-industrialized countries, it was argued that IMO was a better body to deal with this very international issue. In a way, the EU has threatened the IMO that if it does not act, the EU will implement EU regulations.

Also, SECA was previously established where special emission restrictions apply. Present regulations in the SECA stipulate a maximum sulphur content of