The 212CD submarine acquisition and its alignment with the Norwegian defence sector’s climate and sustainability goals

In recent years, the Norwegian defence sector has made it clear that it aims to take greater responsibility for its impact on climate and environment and to contribute to achieve national climate and environmental goals, as well as UN’s Sustainable Development Goals. In 2022, the sector launched its own climate and environmental strategy to reduce its climate footprint and negative environmental impacts and to adapt the sector to future climate changes. The strategy was specified in the Action Plan 2023–2030.
In 2021, Norway signed a procurement contract for 212CD submarines from the German shipyard TKMS to replace its Ula class submarines. The procurement process is a collaboration with Germany. In 2025, Norwegian Defence Material Agency (NDMA) Maritime Capabilities asked the Norwegian Defence Research Establishment (FFI) to evaluate how this procurement and the planned quay and maintenance facilities in Skværvika aligns with the sector’s climate and environmental strategy. FFI has analysed the procurement across all phases of the submarine’s life cycle and compared both the submarine acquisition and the new infrastructure with existing solutions for the Ula class.
Emissions from the production of the 212CD submarines have been estimated by FFI at approximately 9000–10 000 tonnes of CO₂-equivalents (CO2e) per submarine. This is roughly three times higher than for the Ula class. In operation, annual emissions from the Norwegian 212CD fleet are estimated at approximately 4700 tonnes of CO2e, of which 86 % stems from the combustion of marine diesel oil in the diesel generators. The most effective climate measures will be to avoid higher sailing speeds than necessary, and in the future, replace current fuels with alternatives that have lower emissions. Local production of hydrogen for air independent propulsion can further reduce emissions by around 600 tonnes of CO₂e per year. In addition, new technological opportunities, such as planning the most energy-efficient sailing routes, may contribute to lower emissions and strengthen operational capability. The 212CD procurement contract does not contain specific requirements to avoid substances regulated under the REACH regulation or to provide an Inventory of Hazardous Materials (IHM). We do, however, expect such requirements to be introduced. For the Ula class, there are few plans for reuse and disposal. We consider access to an IHM important to ensure responsible end-of-life management.
In Skværvika, the quay and maintenance facility is being built by the Norwegian Defence Estate Agency (NDEA) in accordance with the Norwegian building regulation TEK17. Greenhouse gas emissions related to the four quays are estimated to be approximately 9000-10 500 tonnes of CO2e. Similar calculations will be carried out for the maintenance facility once it is completed. The facility will be operated using self-produced energy from seawater-based district heating and will be prepared for installation of a solar power system. NDEA largely complies with the sector’s climate and environmental requirements. However, the blasting work carried out during quay construction exceeded the requirements for explosives quantities and noise levels.