Reactions received from Swedish companies indicate that existing barriers are not specific for environmental goods or services, but rather general problems, typical for most exporting companies to countries outside the EU.

As far as tariffs are concerned this means that most products of in-terest to the Swedish environmental industry are covered by the APEC initiative. However, as a result of this new survey a limited number of new products have been added. Also, the Doha mandate should preferably be broadened to include energy related goods in the list annexed to the Energy Charter Treaty.

An agreement on liberalisation of environmental goods and services should be as transparent and user-friendly as possible. For customs duties this could be achieved by including all goods classified under a given tariff number (6-digit HS code), even if only a subset of the goods satisfy the criteria for “environmental goods”. An overall in-terest should be to avoid complicating the customs system or the trade procedures.

From interviews with companies and after contacts with their indus-try associations and the Swedish Trade Council we want to point out the following:

Special attention is needed to the trade facilitation negotiations, since many administrative procedures are both time- and money-consuming, especially for small companies operating in the environ-mental sector.

Technical barriers to trade such as requests for special certification and national labels hamper the trade in environmental goods.

For environmental services an urgent task is to remove market ac-cess and national treatment barriers. Lack of transparency in public procurement and domestic regulations are other fields that cause obstacles for foreign suppliers of environmental services.