The government proposes to update the national species protection. Protect the Forest (Skydda Skogen) is strongly critical in its response to the consultation, as the proposal suggests extensive exemptions for agriculture and forestry. These activities are by far the greatest threats to biodiversity in Sweden. The government proposal erodes and weakens species protection and goes against the environmental goals to which Sweden has committed itself.
Extensive exemptions erode species protection under national species protection
The memorandum weakens the protection function of species protection mainly through the extensive possibilities for exemptions that are proposed. It emphasizes that species protection “does not unnecessarily make activities and measures more difficult” – that is, does not limit agriculture and forestry – and that more possibilities for exemptions from species protection are needed with “consideration of other pressing interests than the conservation of biodiversity”. The memorandum therefore proposes exemptions for activities that do not intentionally negatively affect protected species, and in the same breath determines that all agriculture and forestry are assumed to not have this intention. This gives agriculture and forestry a comprehensive free pass to deplete biodiversity in Sweden.
The fact that species are damaged as a side effect of agriculture and forestry then suddenly becomes irrelevant, which ignores research that shows that clear-cutting directly threatens many forest-dwelling species. According to the Swedish Environmental Protection Agency (Naturvårdsverket), agriculture and forestry are the greatest impact factors that threaten habitats and biodiversity. Giving these particular activities a blanket exemption from prohibitions based on national protection is directly counterproductive and counteracts Sweden’s environmental goals as expressed in Living Forests and A Rich Flora and Fauna.
The exemptions are suggested to apply when prohibitions under the protection regulations mean “that ongoing land use is significantly made more difficult”. A ban on clear cutting could be interpreted as such a significant aggravation, which in that case means that forestry does not have to take protected species into account.
The proposed changes to species protection endanger biodiversity in Sweden and risk widespread extinction of species!
The exemptions deviate from EU regulations
According to the current national conservation regulations, the county administrative board can grant an exemption from the bans “if there is no other suitable solution and the exemption does not make it more difficult to maintain a favourable conservation status of the species’ population in its natural range”. This reflects the EU’s Species and Habitats Directive (92/43/EEC, Article 16). However, the new proposal deviates from this and weakens the role of the species’ conservation status. Here it is proposed that the exemption may also make the species’ conservation status more difficult, if there is no other solution and “is needed for reasons of public health and safety or for other compelling reasons that have an overriding public interest.” It remains unclear what counts as overriding public interest – which again opens a loophole that weakens species protection.
Protection is limited to the most fragile species
The government proposes that the Swedish Environmental Protection Agency (Naturvårdsverket) regularly review which species should be protected. The current list is in the Species Protection Ordinance (2007:845). It was last updated almost two decades ago and does not refer to a regular review of which species are included. The selection of species has certain biases. For example, only five fungi are currently protected, while as many as 786 fungi species are red-listed in Sweden today. There are therefore arguments for updating the list based on the current threat status and the needs for protection of all native species in Sweden. It is also positive that the protection of protected species is proposed to apply not only to the species itself but in some cases also to its habitats. However, this addition is undermined by the extensive exceptions in the government proposal.
The government proposal largely intends to limit and weaken the protection that national protection entails. Birds shall remain generally protected, while protection for plants and fungi will be much more limited. First and foremost, the selection of species is proposed to be based on the SLU Red List, and then only apply to species that are classified as Endangered (EN) or Critically Endangered (CR). In addition, these species are proposed to be separated into two groups, with weaker protection for species that are classified as Endangered (EN). This means that national protection only protects the most endangered and fragmented species in the country.
Critically Endangered (CR) is the highest level on the Red List before national extinction. These species are so fragile and fragmented that in many cases they have little chance of regaining a more favorable conservation status in Swedish nature today without extensive protection measures. Only protecting species that are so close to being eliminated from Swedish nature is irresponsible and exposes many other threatened species to the danger of continuing to decline until they too become critically endangered.
The proposal thus weakens the protection of red-listed species that are currently classified as Near Threatened (NT) or Vulnerable (VU). These species then risk further decline and possibly end up in the EN or CR categories, where it will be significantly more difficult for a species to recover. This counteracts the goal of the memorandum, “that viable populations can be maintained at a national level in the long term” and makes conservation protection a purely reactive protection.
Conservation protection based solely on the EN and CR categories is insufficient!
The memorandum also intends that species threatened by picking and plundering should receive a form of conservation protection – but then the ban is proposed to only apply to intentional picking. It would therefore not apply when the species is destroyed as a side effect of other activities, such as logging and land preparation. This again erodes and limits the protection of species.
Currently protected species are at risk of losing protection
National protection in its current form is a protection that aims to protect both endangered species and species that are particularly vulnerable to picking or plundering. Today, national protection covers approximately 585 species. It is unclear how many or which species will be included in the future according to the government’s proposal and what rules will apply to specific species. The Swedish Environmental Protection Agency is expected to present a list by 21 November 2025.
However, it is clear that several species that are currently protected could lose their current protection if the criteria for protection are limited to species that are classified as Endangered or Critically Endangered (EN or CR) according to the Red List. Examples of these are Goodyera repens, an orchid classified as Vulnerable (VU) and also signals forest environments with long continuity. Sarcosoma globosumis also red listed as Vulnerable (VU) today. Since it mainly occurs in Sweden, we have a special national responsibility to protect this species. Both species are threatened by clear-cutting and have declined sharply in recent decades.
Skydda Skogen takes its stance
Skydda Skogen has submitted its response to the consultation and also supports the Swedish Society for Nature Conservation’s views on the government proposal. Both of these can be read in full on the government’s website.
References
Naturvårdsverket, ”Fridlysta arter”, published 25-06-2025, https://www.naturvardsverket.se/amnesomraden/arter-och-artskydd/fridlysta-arter/
Naturvårdsverket, ”Läget för biologisk mångfald i Sverige”, published 13-12-2023, https://www.naturvardsverket.se/amnesomraden/biologisk-mangfald/laget-for-biologisk-mangfald-i-sverige/
Regeringen, “Skyddet genom nationell fridlysning anpassas till arternas skyddsbehov och andra angelägna intressen”, KN2025/01529, published 24-07-2025, https://www.regeringen.se/rattsliga-dokument/departementsserien-och-promemorior/2025/07/skyddet-genom-nationell-fridlysning-anpassas-till-arternas-skyddsbehov-och-andra-angelagna-intressen/
Regeringen, “Remiss av promemorian Skyddet genom nationell fridlysning anpassas till arternas skyddsbehov och andra angelägna intressen”, https://www.regeringen.se/remisser/2025/07/remiss-av-promemoria-skyddet-genom-nationell-fridlysning-anpassas-till-arternas-skyddsbehov-och-andra-angelagna-intressen/
SLU Artdatabanken, ”Många skogslevande arter hotas av trakthyggesbruk”, published 13-05-2025 https://www.slu.se/artdatabanken/arter-och-natur/artiklar/manga-skogslevande-arter-hotas-av-trakthyggesbruk/
SLU Artdatabanken, ”Svampar – nödvändiga och spännande”,published 02-04-2025, https://www.slu.se/artdatabanken/arter-och-natur/organismgrupper/svampar/#:~:text=Svampar%20i%20naturv%C3%A5rden%20I%20Sverige%20finns%20runt,uppfylla%20IUCN:s%20kriterier%20f%C3%B6r%20att%20bli%20r%C3%B6dlistade.
Sveriges Miljömål (Sweden’s environmental objectives), see https://www.sverigesmiljomal.se/
WWF, ”Fridlysning av växter och djur kan försvagas”, published 29-08-2024, https://www.wwf.se/nyheter/wwf-fridlysning-av-vaxter-och-djur-kan-forsvagas/