The Swedish Maritime Code (1994:1009) establishes seven maritime courts in Sweden whose internal jurisdiction is purely geographical. The maritime courts are exclusively competent in respect of matters governed by the Maritime Code, such as cargo claims, charterparty disputes, liability funds and limitation of liability.

Disputes under marine insurance contracts are subject to the exclusive jurisdiction of the Swedish Dispascheur.

Sweden is bound by the EU Port State Control Directive (2009/16/EC) and is party to the Paris Memorandum of Understanding on Port State Control. Port state control is carried out by the Maritime Administration under the Transport Authority, which is also the authority to which to report marine casualties. If a crime is suspected to have been committed the casualty is investigated by the marine prosecutor in co-operation with the Coast Guard and/or the marine Police.

The registration and nationality of vessels is governed by chapter 1 of the Swedish Maritime Code (1994:1009). The practical aspects of registration are governed by the Ordinance on Vessel Registration (1975:927).

A vessel more than 50% of which is owned by Swedish citizen(s) or company/companies is considered Swedish and must be registered in the Maritime Registry. The vessel can be considered non-Swedish, and thus not subject to registration, if it is registered in an official registry of another EU or EEA state and is part of a business established in that state and the vessel is directed and controlled therefrom. Separate rules apply to vessels not used in a business. A vessel under construction can be registered.

A vessel can be temporarily registered for up to one month if registration in Sweden is a condition for deletion in the vessel’s current registry. Dual registration is not expressly prohibited, meaning that the law does not prohibit a bare boat registration in another registry. On the other hand there is no law expressly allowing it either, which is sometimes required by the bare boat registry.

Vessels are registered with the Maritime Registry held by the Swedish Transport Authority. Mortgages can be granted over a registered vessel by the ship-owner by handing over the deed of mortgage issued by the same authority to the lender in exchange for a loan. Such mortgage may be registered with the Maritime Registry but such registration is not a precondition for the mortgage to be effected.

Transcripts of the registration of a vessel, including any registered mortgages, are available to the public from the Maritime Registry by request to the authority.

Pollution

The 1969 International Convention on Civil Liability for Oil Pollution Damage, as amended in 1992, and the 2001 International Convention on Civil Liability for Bunker Oil Pollution Damage, are incorporated in chapters 10 and 10a of the Swedish Maritime Code (1994:1009), respectively.

Registered owners are, with some exceptions, strictly liable for damage or loss caused by oil pollution and bunker oil pollution. The ship-owner is exempt from liability if it can prove that the damage was caused by an act of war or a similar action, if the damage was entirely caused by an act or omission by a third party with intent to cause damage, or if the damage was caused by negligence of a public authority in connection with maintenance of lights or other navigational aids. The law also includes provisions on limitation of liability, establishment of a limitation fund, compulsory insurance and direct action against the registered owner. In addition, the Swedish Transport Agency has issued Ordinance TSFS 2010:96, which contains detailed rules and recommendations on the discharge of oil and other pollutants from vessels.

Wreck Removal

Sweden has ratified the 2007 Nairobi International Convention on the Removal of Wrecks. Chapter 11a of the Swedish Maritime Code incorporates the convention’s provisions. As a main rule, the ship-owner is required to remove a wreck that poses a danger to navigation or to the environment. Further, lost cargo must always be reported, regardless of whether it poses a danger to navigation or not. As for larger ships, the ship-owner is also obliged to have liability insurance in place, or to provide other adequate security to cover their liability. The provisions apply to all Swedish territorial waters, including lakes and canals.

There is no mechanism for the establishment of a separate wreck fund.

Collision

Chapter 8 of the Swedish Maritime Code contains provisions on collision liabilities. The provisions are based on the 1910 Brussels Collisions Convention and are complemented by the general rules on ship-owners’ liability in chapter 7 of the Swedish Maritime Code (1994:1009) as well as general tort law.

The main rule regarding collision liability is contribution in proportion to the level of causation. A party involved in a collision is liable for losses only to the extent the party has caused the collision. Each party answers for half of the loss, unless there are circumstances that give support for any other distribution of liability. There are, however, some exceptions to this rule. If the collision is due to an accident or if it cannot be determined whether the parties have caused the collision, each party shall be liable for its own loss.

Salvage

The 1989 International Convention on Salvage has been ratified by Sweden. The provisions are incorporated in chapter 16 of the Swedish Maritime Code (1994:1009) and are, for the most part, optional. This allows for salvage contracts on different terms, except for certain provision relating to, inter alia, the salvor’s obligation to act with due care to prevent or mitigate environmental damage.

Sweden is party to the 1976 Convention on Limitation of Liability for Maritime Claims, as amended by the 1996 Protocol and, consequently, maritime claims in Sweden are subject to global limitation. The convention’s provisions are codified in chapter 9 of the Swedish Maritime Code (1994:1009). Special limitation rules relating to freight and transport of passengers can be found in chapter 13 (on carriage of general cargo), chapter 14 (on chartering of vessels) and chapter 15 (on carriage of passengers and luggage). These special rules are to be applied before limitation and distribution is set according to chapter 9.

Provisions pertaining to limitation funds can be found in chapters 9 and 12 of the Swedish Maritime Code (1994:1009). A limitation fund may be constituted if, on account of a claim subject to limitation in Sweden, suit has been brought or arrest or other legal proceedings have been instituted. The fund shall be constituted with the court where the suit has been brought, or otherwise one of the seven Maritime Courts competent for the place where arrest or other legal action has been applied for. A limitation fund is deemed to have been constituted with effect for all persons who can claim the same limit of liability. It is intended only for payment of claims of the kind to which that limit of liability applies.

A global fund shall be equal to the aggregate amounts that constitute the limit of liability for claims for which limitation is invoked and which have arisen out of one distinct occasion, plus interest. The person applying for constitution of a limitation fund shall pay the fund amount into court or produce satisfactory security for it. The application must be in writing, and the applicant shall account for the circumstances and state the names and addresses of likely claimants against the fund.

Accrued interest can increase the limitation amount significantly. This is especially worth noting in cases of prolonged limitation proceedings. Interest shall be calculated in accordance with the Act on Interest (1975:635).

Sweden has ratified the 2006 Maritime Labour Convention. Corresponding provisions are found in laws and regulations such as the Seaman’s Act (1973:282), the Act on Periods of Rest for Seafarers (1998:958), the Act on Enlistment of Seamen (1983:929), the Ship Safety Act (2003:364), the Work Environment Act (1977:1160) and the Social Insurance Code (2010:110).

Sweden is a party to the International Convention for the Unification of Certain Rules of Law Relating to Bills of Lading, 1924, First Protocol, 1968, Second Protocol, 1979 (the “Hague-Visby Rules”) as well as the United Nations Convention on the Carriage of Goods by Sea, 1978 (the “Hamburg Rules”). Provisions regarding contract of carriage of goods are found in chapter 13 of the Swedish Maritime Code (1994:1009). The Chapter can be described as a hybrid of the Hague-Visby Rules and the Hamburg Rules, though only those parts of the Hamburg Rules which are not in conflict with the Hague-Visby Rules have been implemented.

As for the Rotterdam Rules, Sweden has signed but not yet ratified the convention.

Sweden is also a party to the Convention on the Contract for the International Carriage of Goods by Road, 1956 (CMR), which may be applicable to transport by sea.

Under Swedish maritime law, the lawful holder of the bill of lading has title to sue under the bill of lading. Apart from the original shipper or consignee, a third party, to whom the bill of lading has been endorsed, is also considered the lawful holder.

The ship-owner is liable for loss or damage that the master, members of the crew or a pilot cause through fault or neglect in the performance of their duties. Further, the ship-owner is liable if the loss or damage is caused by any other person while performing work in the vessel’s service on the direction of the ship-owner or master (chapter 7 of the Swedish Maritime Code (1994:1009)).

Provisions on the carrier’s liability for damaged goods are found in chapter 13 of the Swedish Maritime Code. The code defines the carrier as the person who enters into a contract with a sender for the carriage of general cargo by sea – ie, the contractual carrier. The ship-owner may, however, also incur liability as the actual carrier of the goods, without having entered into any contract with the cargo interests (eg, in its capacity as a subcarrier). The mandatory liability will in general not differ depending on whether ship-owners cause damage in their capacity as contractual or actual carriers. The main rule regarding liability for cargo damage is that the carrier is liable for damage resulting from the goods being lost or damaged while in its custody. The carrier may, however, be exempt from liability if it proves that the loss or damage is caused by navigational errors or fire not caused by personal fault or neglect.

The carrier’s liability can be limited to 667 SDR per unit or, if the liability thereby is higher, 2 SDR per kilo of the gross weight of the goods (the SDR is an international reserve asset created by the IMF, based on the value of a basket of currencies). The right of limitation is lost if the carrier is proven to have caused the damage or loss with intent, or recklessly with knowledge that such damage or loss would probably occur.

The ship-owner can further limit its liability regarding claims on account of damage to property if the damage occurred on board the vessel or in immediate connection with her operation or with salvage operations (global limitation).

The shipper has a strict liability towards the carrier regarding the correctness of the statements relating to the goods inserted in the bill of lading. Regarding carriage of dangerous goods, the shipper is not only liable towards the carrier, but also towards any subcarrier. The shipper is obliged to inform the carrier about the dangerous nature of the goods and any necessary safety measures. Failure to do so may give the carrier the right to discharge or destroy the goods without liability for paying any compensation.

To the best of the authors’ knowledge, shippers’ misdeclaration of cargo has not been tried in any recent case law of material significance.

In the event of loss or damage to cargo that the cargo owner has observed or ought to have observed, the cargo owner must provide the carrier with a notice of claim immediately upon delivery. If the damage or loss is not apparent, a notice of claim must be given within three days from delivery.

Claims for compensation regarding loss or damage of cargo become time barred within one year from the date of delivery.

There are possibilities to extend the time limit (for a maximum of ten years), for example through a mutual agreement between the parties, provided that such agreement has been concluded after the claim arose.

Sweden is a party to the 1952 International Convention Relating to the Arrest of Sea-Going Ships (the 1952 Arrest Convention). The provisions of the convention are incorporated into chapter 4 of the Swedish Maritime Code (1994:1009). These rules are applicable to the arrest of a vessel with some international aspect (international arrest) and to vessels entered into the Swedish ship registry or an equivalent foreign ship registry.

Domestic arrests (ie, arrest of Swedish-flagged vessels where the applicant has its habitual residence or principal place of business in Sweden) are regulated by the provisions in chapter 15 of the Swedish Code of Judicial Procedure (1942:740).

Maritime liens are recognised in Sweden (chapter 3 of the Swedish Maritime Code (1994:1009))

A maritime lien upon a vessel secures any claim against the operator concerning:

• wages and other sums due to the master or other person employed on board on account of their employment on the vessel;
• port, canal and other waterway dues and pilotage dues;
• compensation for personal injury that has occurred in direct connection with the operation of the vessel;
• compensation for property damage that has occurred in direct connection with the operation of the vessel, provided the claim is not based on contract; and
• salvage, remuneration, compensation for removal of wreck and contribution in general average (where all cargo owners are responsible for the losses of others).

Difference Between Maritime Liens and Maritime Claims

Swedish law differentiates between maritime liens and maritime claims. As stated above, maritime liens are regulated in chapter 3 of the Swedish Maritime Code (1994:1009). Maritime claims for which a vessel can be arrested are, on the other hand, regulated in chapter 4 of the Swedish Maritime Code. The code specifies a list of all such maritime claims for which a ship can be arrested. This list corresponds with the list found in Article 1 of the 1952 Arrest Convention. The maritime claims that may lead to arrest are:

• claims arising out of damage caused by a vessel’s collision;
• loss of life or personal injury caused by a vessel or occurring in connection with the operation a vessel;
• salvage;
• general average; and
• disputes over the ownership of a vessel.

It should be noted that the list is exhaustive and therefore it is not possible to arrest a vessel on a claim relating to any other circumstance than those listed.

For a vessel to be arrested, the ship-owner must be liable for the maritime claim, unless the claim is secured by a maritime lien.

Under the Swedish Maritime Code, a claim based on demise charter agreement or an agreement concerning the carriage of goods on board a vessel on account of a charterparty is considered a maritime claim.

Regarding international arrests, a vessel can only be arrested for the maritime claims listed in chapter 4 of the Swedish Maritime Code (1994:1009), provided that the owner of the vessel is liable for the claim. There is, however, no requirement for the ship-owner or demise charterers to be liable in persona regarding claims that are subject to maritime lien.

Bunker suppliers have the option to arrest a vessel for claims relating to bunker deliveries provided that the owner of the vessel is liable for the claim. In cases where bunkers have been supplied to a bareboat or time charterer, the bunker supplier can only rely on the general rules on arrest under chapter 15 of the Swedish Code of Judicial Procedure (1942:740) to arrest bunkers on board or to seize other assets of the charterer.

For a vessel to be arrested, certain formalities are required. The arrest applicant must submit an application to the Maritime Court with jurisdiction over the matter (see 2.4 Procedure and Requirements for Establishing a Limitation Fund).

A power of attorney in original form must be submitted with the request for arrest. The arrest application must be drafted in Swedish. Supporting documentation in English is usually accepted.

To obtain an arrest order, the applicant must demonstrate probable cause for a legitimate claim that is or could be assumed to be brought before the court. In addition, the applicant must show that there is a presumed risk that the defendant may evade, conceal assets or otherwise avoid payment, unless the claim is secured by a maritime lien. Lastly, the applicant is obligated to provide security covering all potential costs and damages that may be incurred by the other party in the event of an unjustified vessel arrest. Without security, the court will generally not grant the application for arrest. The court can decide to waive the security requirement for a claimant who cannot afford it and has very strong reasons (synnerliga skäl) for its claim. The court also determines what kind of security is adequate and how much it should cover.

Bunkers supplied to a bareboat or time charterer may be subject to arrest. The bunker supplier can, however, only invoke general rules on arrest outlined in chapter 15 of the Swedish Code of Judicial Procedure (1942:470) in order to arrest bunkers onboard or seize other assets of the charterer.

So called sister-ship arrests are possible in Sweden. Pursuant to chapter 4 of the Swedish Maritime Code (1994:1009), a vessel, other than that to which the maritime claim relates, can be arrested in some particular cases. This is possible if the other vessel is owned by the same legal entity at the time when the maritime claim arose. There are however exceptions to this rule, for example if the claim relates to disputes as to the ownership, possession, employment or earnings of the vessel, or mortgage of a vessel.

There are different types of attachment orders in Swedish law that can be used to obtain security, depending on the nature and stage of the claim, the type of property involved, and the risk of dissipation or loss of the assets. Apart from ship arrests and provisional attachment under chapter 15 of the Swedish Code of Judicial Procedure (1942:470), if the claimant has a binding decision against the debtor, security can be obtained by attachment (utmätning) under the Swedish Enforcement Code (1981:774).

A vessel subject to arrest shall be prevented from departing. However, pursuant to chapter 4 of the Swedish Maritime Code (1994:1009), the owner or any interested party in possession of the vessel may apply to the court for permission to use the vessel against bail or as security. This can be granted in two cases: if the vessel is arrested because of a maritime claim related to disputes as to the ownership of the vessel or, disputes between co-owners of a vessel as to the ownership or possession of the vessel or the operation of or earnings from the vessel.

To release the arrest, the owner or a stakeholder can provide security that satisfies the claimant’s demand. The Enforcement Code (1981:774) does not specify what forms of security are valid, but it states that a pledge, a guarantee (borgen) or a business mortgage (företagshypotek) will do. The court decides if the security is adequate, unless the other party agrees to it. Bank guarantees and P&I letters of undertaking are usually seen as a form of guarantee and are thus valid.

According to the Enforcement Code (1981:774), once an enforcement title has been granted, usually a judgement regarding the merits of the claim, and following a granted application of attachment (utmätning), an arrested vessel, provided it is registered, can be sold at public auction. The sale should normally take place within four months of the attachment.

The auction shall be announced well in advance and in an appropriate manner. The announcement shall contain information about the meeting regarding distribution of the purchase price. Holders of claims shall be urged to report their rights to the enforcement authority no later than at the time of the auction.

Notification of the sale shall be sent to the applicant and the owner, as well as to known creditors who have a maritime mortgage, mortgage rights or right of retention, no later than 30 days before the auction. If such a creditor becomes known later, it shall be notified immediately.

Claims are listed in accordance with the priority prescribed by statute. Interest and other ancillary obligations are listed before the principal sum of the claim unless the creditor requests otherwise. The administration expenses are included immediately prior to the enforcement claim.

A decision to grant an arrest will be enforced by the enforcement authority. The enforcement authority informs the vessel’s master about the arrest order and the vessel’s certificates and nationality documents will normally be taken into custody. A seal will also be fixed to the rudder. Breaching the arrest of the vessel is sanctioned by fines or imprisonment of up to one year. The party who requested the arrest might be required to cover the costs of maintaining the arrest in advance, such as harbour fees or similar costs.

Sweden is not a signatory to the Convention on the International Effects of Judicial Sales of Ships.

The Company Reorganisation Act (2022:964) is part of Swedish insolvency law and regulates how companies can be reconstructed in order to overcome financial difficulties. A company can apply for reconstruction if it has a viable business model that can survive the financial problems that the reconstruction is meant to solve. The goal of the reconstruction is to help the company overcome its economic troubles and become profitable and stable.

Chapter 2 of the Company Reorganisation Act sets out that while the corporate restructuring is in progress, as a main rule, enforcement or other execution according to the Enforcement Code (1981:774) may not take place against the debtor. During this time, a creditor may not in any other way realise the debtor’s assets. This implies that the debtor’s property is protected from individual creditor claims during a reconstruction procedure.

If the arrest applicant has failed to initiate proceedings on the merits of the claim within one month or, if the applicant is unsuccessful in such proceedings, the applicant becomes strictly liable for all expenses and damages that the defendant suffers. The owner of the vessel has the right to seek compensation for damages resulting from a wrongful arrest by initiating separate legal proceedings against the applicant in court.

The liability of a carrier of passengers is regulated by chapter 15 of the Swedish Maritime Code (1994:1009), which recaps the Athens Convention Relating to the Carriage of Passengers and their Luggage by Sea, 1974, as amended by the 2002 Protocol. Sweden has ratified the Athens Convention, as amended by the 2002 Protocol, and is further bound by EC Regulation 392/2009 on the liability of carriers of passengers by sea in the event of accidents, which incorporates the Athens Convention into EU law. Sweden is also bound by EC Regulation 1177/2010 concerning the rights of passengers when travelling by sea and inland waterways.

The time limit of two years, which is initiated when the passenger disembarked from the vessel, and/or the luggage was brought from the vessel, can be interrupted only by initiation of legal proceedings at court. The date of the filing of the suit is the date that the time bar is interrupted. Agreements on time-bar extensions are generally accepted in Sweden.

In general, Swedish courts will recognise and enforce law and jurisdiction clauses stated in bills of ladings. However, there are certain limitations for jurisdiction and arbitration clauses in chapter 13 of the Swedish Maritime Code (1994:1009).

In disputes concerning the carriage of cargo, a jurisdiction clause may be void if it limits the claimant’s right to bring an action at the place where:

• the respondent has its principal place of business or, in the absence thereof, where the respondent has its habitual residence;
• the agreed contract of carriage was entered into, provided that the respondent has a place of business, a branch or an agency there through whom the contract was concluded; or
• the agreed port of loading or the agreed actual port of discharge is situated.

For arbitration clauses, the Swedish Maritime Code states that – as a part of the arbitration agreement – the claimant always has a right to request that the arbitration shall be pursued in one of the states where a place named in the above list is situated.

It should be noted that the above-mentioned limitations do not apply to jurisdiction or arbitration clauses in cross trade (ie, in traffic between non-Nordic states) nor to jurisdiction clauses if anything else follows from certain EU legal acts or international instruments.

If a bill of lading is issued under a charterparty containing a provision on the competent court or an arbitration clause, without the bill of lading expressly mentioning that the provision/clause is binding on the holder of the bill of lading, the carrier may not invoke the provision/clause against the holder of the bill of lading, provided that the holder has acquired it in good faith (chapter 13 of the Swedish Maritime Code (1994:1009)).

Thus, a provision on the competent court or an arbitration clause in a charterparty may only be invoked against the holder of the bill of lading if the bill of lading expressly mentions that the provision/clause is binding on such holder. A general reference to the charterparty in the bill of lading will not suffice.

Sweden is a party to the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards. Recognition and enforcement of foreign arbitral awards is conducted in accordance with the Swedish Arbitration Act (1999:116).

Under Swedish law, an arrest can be obtained provided that the requirements outlined in 4. Maritime Liens and Ship Arrestsare fulfilled. Hence, it does not matter if the substantive claim is subject to foreign jurisdiction through arbitration or court proceedings. However, the foreign judgment/arbitral award must be enforceable in Sweden (chapter 4 of the Swedish Maritime Code (1994:1009)).

The Swedish Chamber of Commerce is the main domestic arbitration institute in Sweden. It does not specialise in maritime claims but deals with maritime disputes in addition to most other types of dispute.

In addition, the Nordic Offshore and Maritime Arbitration Association (NOMA) was established in 2017 as a Nordic initiative. NOMA has developed its own arbitration rules and their importance is likely to increase in Sweden.

Further, ad hoc proceedings under the Swedish Arbitration Act (1999:116) may also be an option for maritime claims.

A court may not, provided that the respondent objects, rule on an issue which shall be decided by arbitrators pursuant to an arbitration agreement. The respondent must, however, invoke the arbitration agreement on the first occasion it pleads its case on the merits in court (Section 4 of the Swedish Arbitration Act (1999:116) and chapter 10 of the Swedish Code of Judicial Procedure (1942:740)).

As a main rule, a Swedish court will consider itself competent to entertain proceedings for a dispute instituted in that court unless the respondent has made a timely objection to the competence of the court invoking the relevant jurisdiction clause, or has failed to appear in court at the first hearing, or, if the preparation is in writing, omitted to submit an answer (chapter 10 of the Swedish Code of Judicial Procedure (1942:740)). The respondent must present its objection when making its first appearance in the case. Should the respondent be prevented from asserting an objection by legal excuse, the objection must be presented as soon as possible after the excuse has ceased to exist. Failure to raise such an objection within the timeframe results in the forfeiture of the right to raise the objection (chapter 34 of the Swedish Code of Judicial Procedure). Please note that the rules are somewhat different where the Brussels I Regulation is applicable.

There is an optional tonnage tax system. Shipping operations that are qualified include the transport of goods and passengers at sea with ships that have a gross tonnage of at least 100, have their strategic and financial management in Sweden and are mainly used in international traffic or in domestic traffic in another country. In order for the shipping business to be considered qualified, it is further required, among other things, that a certain proportion of the ships in the company’s fleet are registered in a register in a state within the EU/EEA. As a general rule, the company can leave the tonnage tax system after ten tax years at the earliest.

There have been a number of decisions by Swedish courts as to non-performance of contractual obligations in the aftermath of the COVID-19 pandemic. Generally, these types of issues will depend on the particular circumstances and the applicable contractual terms. Although, the concept of force majeure is not expressly provided for as a generally applicable rule under Swedish law, there are possibilities under the Swedish Contracts Act (1915:218) to modify or set aside contract terms that become excessively onerous as a result of circumstances which are typically regarded as force majeure events.

While the authorities imposed various restrictions on maritime activities at the relevant time, COVID-19 is no longer classified as a pandemic and no restrictions have applied since early spring 2022.

Sweden has implemented “IMO 2020” and the responsible authority is the Swedish Transport Agency. Notably, the Baltic Sea and the North Sea are so-called sulphur control areas (SECA) which means that the sulphur content must not exceed 0.10% by weight.

The requirements for the sulphur content of fuel used on board are regulated by EU Directive 2016/902 and the applicable Swedish legislation is the Sulphur Ordinance (2014:509). The authors are not aware of any proceedings or sanctions having taken place because of a violation.

See 8.4 The War in Ukraine.

Trade sanctions against Russia and the non-governmental controlled areas in Ukraine have had a large impact on Sweden’s business life, including shipping. Sweden does not have any sanctions of its own. Instead, Sweden applies UN and EU sanctions. Breach of sanctions entails criminal liability in Sweden. Generally, only natural persons can commit a crime in Sweden. Legal persons (eg, companies) can be subject to corporate fines if a sanctions breach has been committed within the ambit of the company’s operations.

Sanctions breaches are investigated by the Swedish Security Service or the Special Branch of the Prosecutor’s Office. What implications sanctions have on shipping (as well as other) contracts will depend on the contractual terms, and the interpretation of the same. There is very little public case law in Sweden regarding sanctions breaches and no case law at all (as of January 2024) regarding breaches of sanctions against Russia. The lack of public judgements from sanctions-related commercial disputes may be explained by the fact that most commercial disputes in Sweden are referred to private arbitration.

The administration of sanctions is performed by several agencies of which the two most prominent are the Inspectorate of Strategic Products and the National Board of Trade Sweden. There is no mechanism to grant authorisations or permits beyond what the respective sanctions legislation provides for.

The main legal instruments regarding the EU’s sanctions against Russia are EU Regulation 833/2014, EU Regulation 269/2014 and EU Regulation 1351/2014. One of the most relevant provisions for the shipping industry is probably the prohibition on providing technical assistance, brokering services or financing or financial assistance, related to the trading, brokering or transport of certain Russian oil products below a price cap (Article 3n of Council Regulation 833/2014).

Given the nature of shipping, shipping companies have high exposure to sanctions compared to more domestic industry sectors in Sweden. 

In Sweden, maritime and transport law are generally considered to be rather particular and somewhat inaccessible legal regimes, and are typically not well known to, or practised by, the average lawyer.