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  1. International Commercial & Trade
  2. Sweden: Government publishes report on export controls and related statistics

Sweden: Government publishes report on export controls and related statistics

The Swedish government has published its annual report on strategic export controls covering 2024. The report covers both military equipment and dual-use items.
06 May 2025    5 minute read
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Sweden Export Control

In brief

On 3 April 2025, the Swedish government published a report on the Swedish export control framework (military equipment and dual-use items) as well as export-related statistics (Sw. Regeringens skrivelse 2024/25:114 Strategisk exportkontroll 2024 krigsmateriel och produkter med dubbla användningsområden) ("Report"). The statistics include inter alia the value and type of exported items, destinations to which exports were authorized as well as destinations to which exports were denied. The competent and supervisory authority, the Inspectorate of Strategic Products (ISP), is chiefly responsible for producing the statistics.


Contents

Generally, the Report states that exports, domestic supply and manufacturing of military equipment is growing and that the growth accelerated during 2024. Since 2018, the number of entities licensed to supply (both domestically and by way of export) and manufacture military equipment has more than doubled to 450 (by the end of 2024). However, a majority of the increase may be attributed to the requirement for subcontractors to Swedish manufacturers of military equipment to also hold a license (i.e., entities that do not export military equipment).

Separately, there is an ongoing legislative process to revise and amend the current Military Equipment Act, which will likely remove certain license requirements and potentially lead to Sweden adopting a de minimis-rule with respect to international supply chains to certain countries.

Key takeaways

The Report on exports of military equipment and dual-use items provide that Swedish exports are growing and are relatively varied in scope, in terms of both products and destinations. 
With respect to military equipment, the ISP only denied sought export licenses in two cases (with the destinations Thailand and Türkiye). However, note that this number does not reflect applications filed with the ISP that would have been denied, but where the applicant chose to recall the application, prior to the ISP making a formal decision in the matter.

With respect to dual-use items, the Report states that a large degree of export applications concern items within the Wassenaar Arrangement control regime, and the most frequent destination, in this regard, is China. Furthermore, exports of dual-use items to Haiti and Kazakhstan appear to have been completely stopped. It is reasonable to assume that exports to Kazakhstan are at least in part reduced due to circumvention and diversion risks, with respect to Russia, and the denied exports to Haiti are likely connected to the significant human rights violations and internal repression in the country in 2024.

In more detail

It is important to note that the statistics provided in the Report may not be entirely reliable for the purpose of drawing conclusions on probability or trends with respect to approval or denial. This is in part due to the fact that the ISP does not always have an opportunity to make a formal decision in a matter (i.e., denying an application), as the applicant, at any time, may recall its application. As such, an applicant may prefer to recall its application to avoid public access to information, procedural or other such consequences.

Military Equipment

Authorization on manufacturing and provision of military equipment

In 2024, the Report states, 450 Swedish companies, authorities and individuals held military equipment manufacturing or supply licenses. Of these, 86 exported military equipment or technical assistance related to such equipment. 219 of the licensees provided military equipment within Sweden only and 145 licensees did not sell any military equipment.

The ISP formally denied export license applications (Sw. utförseltillstånd) and/or prohibited tenders, following a tender notification (Sw. anbudsunderrättelse), in two cases, involving the destinations Thailand and Türkiye.

Authorizations on license manufacturing and foreign cooperation

The ISP granted 20 authorizations for applicants to enter into agreements which entailed a transfer or sublicensing of the right to manufacture military equipment to a foreign counterparty. The ISP also granted 58 authorizations for Swedish companies to enter into foreign cooperation agreements.

Military training

The ISP did not provide any authorizations for the provision of military training. However, the Report does not state whether any authorizations were sought.

Dual-Use Items

In comparison with other EU countries,1 it is noteworthy that Sweden exports, to a relatively large degree, telecommunications and information security items.

Applications regarding listed items

During 2024, a total of 33 dual-use export authorization applications were denied, of a total of 849 applications. 26 of the denied applications concerned the Wassenaar Arrangement control regime, according to the Report. In line with the other Member States' dual-use exports, China was the most frequent destination for exports from Sweden. The countries to which exports of dual-use items were most frequently denied include:2 

  1. China (ten denied applications, 144 approved applications)
  2. Haiti (eight denied applications, number of approved applications not provided)
  3. India (five denied applications, 84 approved applications)
  4. Kazakhstan (five denied applications, number of approved applications not provided)
  5. Egypt (four denied applications, number of approved applications not provided)
  6. Armenia (three denied applications, number of approved applications not provided)
  7. Central African Republic (three denied applications)
  8. Kyrgyzstan (three denied applications, number of approved applications not provided)
  9. Russia (three denied applications, number of approved applications not provided)
  10. El Salvador (three denied applications, number of approved applications not provided)

Applications with military end users

Ten applications were made under the catch-all provision (Article 4 of the Dual-Use Regulation), of which one was denied.

With respect to exports of dual-use items to military end users, the ISP denied four applications (to India, Serbia and Thailand) but approved a total of 48 applications (15 of which were general licenses and the remaining 33 were individual licenses).

Exports under specific regimes

Under Council Regulation 833/2014 (Russia), a total of eight applications for exports of dual-use items were made, of which half were denied. Under Council Regulation 267/2012 (Iran), a total of 144 applications were approved and none were denied.

 


1 Please see Report from the Commission to the European Parliament and the Council on the implementation of Regulation (EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items. However, please note that the Commission's report's data concern 2022, as opposed to the Swedish government's report, which concerns 2024.

2 Please note that multiple countries may be included in one application, and that the total number of denied export applications therefore differs from the sum of the listed figures.

Contact Information
Mattias Hedwall
Partner
Stockholm
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mattias.hedwall@bakermckenzie.com
Olof König
Partner
Stockholm
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olof.konig@bakermckenzie.com
Nicole Mansson (Chen)
Associate
Stockholm
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nicole.mansson@bakermckenzie.com
Anton Lindblad
Associate
Stockholm
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anton.lindblad@bakermckenzie.com

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