EUROPEAN COMMISSION Brussels, 8.9.2022 SWD(2022) 253 final COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022













Country Report - DENMARK



























Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance













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This report has been written by the staff of the Directorate-General for Environment, European Commission. Any comments are welcome to the following e-mail address: ENV-EIR@ec.europa.eu More information on the European Union is available on the internet ( http://europa.eu ). Photographs: For reproduction or use of these photos, permission must be sought directly from the copyright holder. ©European Union, 2022 Reproduction is authorised provided the source is acknowledged.

Table of Contents Executive summary

Part I: Thematic areas 1. Circular economy and waste management Measures towards a circular economy Waste management 2. Biodiversity and natural capital Nature protection and restoration Marine ecosystems Ecosystem assessment and accounting 3. Zero pollution Clean air Industrial emissions Major industrial accidents prevention – SEVESO Noise Water quality and management Chemicals 4. Climate action Key national climate policies and strategies Effort sharing Key sectoral developments Use of revenues from the auctioning of EU ETS allowances

Part II: Enabling framework: implementation tools 5. Financing Environmental investment needs in the European Union EU environmental funding 2014-2020 EU environmental funding 2021-2027 National environmental protection expenditure Green budget tools Overall financing compared to the needs 6. Environmental governance Information, public participation and access to justice Compliance assurance Effectiveness of environmental administrations Reforms through the Commission’s technical support instrument TAIEX EIR peer to peer projects



Executive summary In previous Environmental Implementation Reviews (EIRs), the main challenges identified for Denmark for the implementation of EU environmental policy and law were: ·the need to reduce pressures on nature from intensive agriculture, including the use of pesticides and nutrients; ·the need to improve air quality, especially in densely populated areas.

For air quality, Denmark plans to reach emission reduction commitments for sulphur and nitrogen oxides and non-methane volatile organic compounds for the period 2020-2029 and from 2030 onwards. However, the projections do not demonstrate compliance with emission reduction commitments for ammonia and particulate matter (PM2.5) for 2020-2029 and from 2030 onwards. Denmark did not exceed of EU air quality limit values in 2020, and has substantially improved air quality since the 2019 EIR with dedicated extra efforts. According to the last report on implementation of the Nitrates Directive, groundwater quality has slightly improved. The situation concerning the concentration of nitrates in surface water is stable and some improvements were recorded in reducing eutrophication. Nutrient inflows into the Baltic Sea around Denmark have significantly decreased for nitrogen in the Danish Straits and Kattegat, and for phosphorus in Kattegat. Improving nitrogen and phosphorus cycles helps improve circularity of the economy. Nevertheless, the Commission is closely monitoring the situation. The Recovery and Resilience Programme (RRP) makes the environmental transition in agriculture a specific target. On environmental financing, Denmark has a small RRP (2021-2026) with just over EUR 1.5 billion and a cohesion policy (2021-2027) allocation of EUR 500 million. Denmark’s overall environmental financing for investments is estimated to be annual 0.57% of GDP over the period 2014-2020, almost exclusively from national sources. The overall environmental investment needs in the coming years are estimated to be at least an annual 0.72% of Denmark’s GDP, suggesting an environmental investment gap of at least 0.15%, by focusing on the country’s environmental implementation priorities.



Part I: Thematic areas 1.Circular economy and waste management Measures towards a circular economy The new Circular Economy Action Plan adopted in March 2020 is one of the main building blocks of the European Green Deal. The EU’s transition to a circular economy will reduce pressure on natural resources and will create sustainable growth and jobs. It is also a prerequisite to achieve the EU’s 2050 climate neutrality target and to halt biodiversity loss. The Action Plan announces initiatives along the entire life cycle of products, aiming to reduce the EU's consumption footprint and to double the EU's circular material use rate by 2030. It targets how products are designed, promotes circular economy processes, encourages sustainable consumption, and aims to ensure that waste is prevented and the resources used are kept in the EU economy for as long as possible. The circular material use rate is a good indicator of an economy’s circularity, as it includes all the materials that are fed back into the economy. Large differences in the circularity rate exist across countries. To help achieve the EU circular economy action plan’s goal of doubling the EU circular material use rate by 2030, ambitious measures targeting the whole product life cycle are needed at Member State level. Such measures range from sustainable product design to increase durability, reparability, upgradability and recyclability of products, to other measures such as remanufacturing, increasing the circularity in production processes, recycling, as well as boosting eco-innovation and the uptake of green public procurement. Denmark’s circular (secondary) material use rate was 8.2% in 2016 and 7.7% in 2020, well below the EU average of 12.8%. The trend in Figure 1 shows a light fall in the use of secondary material in the past few years . Figure 1: Circular material use rate (%), 2010-2020 Resource productivity expresses how efficiently the economy uses material resources to produce wealth. Improving resource productivity can help minimise negative impacts on the environment and reduce dependency on volatile raw material markets. As shown in Figure 2, with EUR 2.05 generated per kg of material consumed in 2020, resource productivity in Denmark is close to the EU average of EUR 2.09 per kg. More specifically, Denmark needs to reduce its Domestic Material Consumption and Raw Material Consumption. Figure 2: Resource productivity 2010-2020

Circular economy strategies The Commission encourages Member States to adopt and implement national/regional circular economy strategies covering the whole life cycle of products, as they are one of the most effective ways to progress towards a more circular economy. Since the launch of the European Circular Economy Stakeholder Platform in 2017, national, regional or local authorities have used the platform to share their strategies and roadmaps. The Danish government has in 2021 launched an action plan for circular economy .. This plan describes the current conditions and the direction to follow for the prevention and management of waste in Denmark until 2032. The plan puts extra focus on how to make the value chains for biomass, construction and plastics become more circular. The Action Plan for Circular Economy contains a total of 129 initiatives, many of which are also included in Climate plan for a green waste sector and circular economy (2020), Strategy for Green Public Procurement (2020), National Strategy for a Sustainable Built Environment (2021), Strategy for circular economy (2018) and Action Plan on Plastics (2018). Also worthy of note is the 2020 strategy for investments in green research, technology, and innovation, which contains a green mission (one of four) on circular economy focusing on reuse and reduction of plastic and textile waste Although Denmark’s recovery and resilience plan (RRP) does not contain reforms relating to circular economy, there is an investment dedicated to research on circular economy focusing on reuse and reduction of plastic and textile waste (EUR 23.5 million). The European Regional Development Fund (ERDF) for 2021-27 also includes actions to boost the circular economy. Eco-innovation A successful transition to a circular economy requires social and technological innovation as the full potential of circular economy can only be reached when implemented across all value chains. Therefore, eco-Innovation is an important enabling factor for the circular economy. Product design approaches and new business models can help produce systemic circularity innovations, creating new business opportunities. In 2021, Denmark ranked 4th on the 2021 Eco-Innovation Scoreboard, with a total score of 177, resulting in an eco-innovation leader performance. On two out of five components (eco innovation activities and resource efficiency outcomes) of the 2021 Eco-Innovation Index, Denmark performed below the EU average. On eco-innovation inputs, eco innovation outputs and socioeconomic outcomes it performed above the EU average, ranking 1st in eco-innovation outputs. See Figure 3. Figure 3 – Eco-innovation performance 2010-2019 EU Ecolabel and the eco management and audit scheme (EMAS) The number of EU Ecolabel products and EMAS-licensed organisations in a given country provides some indication of the extent to which the private sector and national bodies are actively engaged in the transition to a circular economy. It also shows how committed public authorities are to supporting schemes designed to promote the circular economy. As of September 2021, Denmark had 2 465 products out of 83 590, and 81 licences out of 2 057, registered in the EU Ecolabel scheme, showing a high take-up of these schemes. As of October 2021, 14 organisations from 48 sites in Denmark are registered in the EMAS scheme. Since the last report in 2019, there has been 1 299 new product and 25 licences registrations of the EU Ecolabel, but there has been a decrease in the number of organisations registered with EMAS, by 14 organisations since 2019. Green public procurement Public procurement accounts for a large proportion of European consumption, with public authorities’ purchasing power representing around 14% of EU GDP. This can help drive the demand for sustainable products that meet repairability and recyclability standards. Denmark adopted a green public procurement strategy in October 2020 (Green Procurement for a Green Future), which put the public sector at the forefront of the green transition. Around EUR 25 billion is spent per year in Denmark on public procurement of goods and services, which is around 10% of GDP. The strategy includes a target that all public procurement on areas where official ecolabelling schemes exist must be eco-labeled or comply with corresponding requirements by 2030. Denmark has been one of the first countries to comprehensively assess the climate footprint from public procurement. In 2019, procurement on behalf of the government, municipal, and regional authorities resulted in a climate footprint totalling approximately 12 million tons, of which around 4 million tons were emitted in Denmark. Based on the assessment made, Denmark plans to set an emission reduction target in 2022. Denmark received a study visit using the EIR peer to peer tool on transferring knowledge and practice on setting up effective repair and reuse systems 24-25 September 2018 to learn from Belgium’s experience.

Since Denmark’s circular material use rate is far below the EU average a priority action on this is proposed.



2022 priority actions ·adopt measures to increase the circular material use rate, and lower Domestic Material and Raw Material Consumption, learning from best EU practices. Waste management Turning waste into a resource is supported by: (i) fully implementing EU waste legislation, which includes the waste hierarchy, the need to ensure separate collection of waste, the landfill diversion targets, etc.; (ii) reducing waste generation and waste generation per capita in absolute terms; (iii) limiting energy recovery to non-recyclable materials and phasing out landfilling of recyclable or recoverable waste. This section focuses on the management of municipal waste for which EU law sets mandatory recycling targets. Preventing products and materials from becoming waste for as long as possible is the most efficient way to improve resource efficiency and to reduce the environmental impact of waste. Waste prevention including re-use are the most preferred options; they top the waste hierarchy. The volume of municipal waste generated is a good indicator of the effectiveness of waste prevention measures. After a stable trend, municipal waste generation in Denmark has started to increase again in recent years. It amounted to 845 kg/year/inhabitant in 2020, the highest in the EU (EU average 505 kg/year/inhabitant), as Figure 4 shows. It indicates that Denmark’s economic growth is not yet decoupled from waste generation. This is an issue of waste prevention. In the 2019 EIR Denmark had two priority actions on waste: to introduce new policy instruments to promote waste prevention and recycling and to shift away from incineration. Figure 4: Municipal waste by treatment in Denmark, 2011-202019 Figure 4 also shows municipal waste by type of treatment, in kilos produced per person. Much of the waste in Denmark is incinerated with energy recovery (382 kg per person in 2020). By 2019, there were 23 dedicated and multi-fired incineration plants in Denmark, of which 17 plants are municipally owned. It is expected that moving to private ownership will lead to an adjustment of the current over-capacity over time. This may lead to some investment losses, although most incineration plants are more than 20 years old. No new plants are envisaged. In June 2020, Denmark decided that it must reduce capacity for waste incineration to correspond to the amount of residual waste from Denmark in 2030, which entails an expected reduction in capacity by approximately 30% from 2020 to 2030, and that the treatment of residual waste must be sent out for tender in order to optimise waste treatment both environmentally and economically. Thus, it is assessed that there is a need to close several municipal incineration plants – corresponding to the expected need for incineration capacity for domestically generated residual waste in 2030. As part of this political agreement DKK 200 million are reserved for stranded assets in incineration plants. Figure 5 and national projections shows that Denmark is moving towards the EU’s 2025 municipal waste recycling target of 55%, as 53.9% in 2020 was recycled (EU average (47.8%)). The EU action plan for circular economy includes a number of targeted policy initiatives to ensure compliance with the 2025 targets.

Figure 5: Recycling rate of municipal waste, 2011-2020 Denmark was not listed in the Commission's Early Warning report' at risk of missing the EU 2020 target of 50 % collected for recycling of municipal waste. The Commission is currently finalising its analysis of the progress on the recommendations from the 2018 Early Warning Reports and analysis of progress towards achieving the 2025 waste recycling targets. This report will be presented at the end of 2022 and will assess the progress made to date. Implementation of the 2018 waste legislative package Denmark has notified the Commission that it has transposed the 2018 waste package. A conformity assessment is now ongoing. Waste management plans and waste prevention programmes (referred to in the section on circular economy) are instrumental for a sound implementation of the EU waste legislation. They set out key provisions and investments to ensure compliance with existing and new legal requirements (e.g. on waste prevention, separate collection for a number of specific waste streams, recycling and landfill targets). Revised plans and programmes were due on 5 July 2020. Denmark’s revised waste management plan & waste prevention programme from July 2021 is acceptable. The plan aims to reduce waste generation and shift away from incineration with energy recovery as there is overcapacity and towards more recycling. Denmark has implemented door to door collection within walking distance from houses (depending on the logistics of the area) for nine fractions of household waste. However, Denmark must take more action to ensure compliance with the recycling targets for the post-2020 period. Therefore, only limited progress was made on both priority actions since 2019, and in the light of the Early Warning Report 2022 they are repeated. National plans, programmes and strategies also need to be implemented. 2022 priority actions ·Bring in new policy instruments, including economic instruments. These instruments should: (i) promote waste prevention; (ii) make preparing for waste reuse and recycling more economically attractive. ·Shift reusable and recyclable waste away from incineration with energy recovery. 2.Biodiversity and natural capital The 2030 EU biodiversity strategy adopted in May 2020 aims to put the EU’s biodiversity on a path to recovery and sets out new targets and governance mechanisms to achieve healthy and resilient ecosystems. In particular, the strategy sets out ambitious targets to: (i) protect a minimum of 30% of the EU’s land area and 30% of its sea area and integrate ecological corridors, as part of a true trans-European nature network; (ii) strictly protect at least a third of the EU’s protected areas, including all remaining EU primary and old-growth forests;

(iii) effectively manage all protected areas, defining clear conservation objectives and measures, and monitoring them appropriately. The strategy also sets out an EU nature restoration plan – a series of concrete commitments and actions to restore degraded ecosystems across the EU by 2030, and manage them sustainably, addressing the key drivers of biodiversity loss. The Habitats and the Birds Directives are key legislative tools to achieve the EU biodiversity strategy targets. They are the cornerstone of EU legislation governing wildlife conservation. Denmark’s national biodiversity strategy is entitled ‘The Danish Nature Policy — Our Shared Nature’. Adopted in 2014, it contains a long-term vision for 2050 and serves as Denmark’s revised national biodiversity strategy and action plan. In 2020 there was a political agreement on nature and biodiversity and in 2021 on green cities. Nature protection and restoration Natura 2000, the largest coordinated network of protected areas in the world, is the key instrument to achieve the Birds and Habitats Directives' objectives to ensure the long term protection, conservation and survival of Europe's most valuable and threatened species and habitats and the ecosystems they underpin. The setting up of a coherent Natura 2000 network, the designation of Sites of Community Importance (SCI) as Special Areas of Conservation (SAC) and the setting of conservation objectives and measures for the Natura 2000 sites are key milestones towards meeting the objectives of the Directives. Setting up a coherent network of Natura 2000 sites Denmark hosts 60 habitat types and 79 species covered by the Habitats Directive. The country also hosts populations of 54 bird taxa listed in Annex I the Birds Directive. By 2021, 8.3% of Denmark’s territory was covered by Natura 2000 (against the EU average of 18.5%), see Figure 7. Special Protection Areas (SPAs) classified under the Birds Directive covered 6% (against the EU average of 12.8%) and SCIs under the Habitats Directive covered 7.4 % (EU average 14.2%) of Danish territory. The latest assessment of the SPA part of the Natura 2000 network shows that Demark’s designation of the network of marine SPAs was insufficient to cover several important bird areas (IBAs). The Danish government on 12 November 2021, with an Order No 2091, proceeded with the designation of 6 new SPAs, and promised 6 December 2021 to look further at appointing additional marine areas as SPAs. The Danish government initiated in 2018 a procedure to adjust the boundaries of the sites within its Natura 2000 network. This procedure is still ongoing. The Commission will be able to finalise its assessment after receiving full justifications for each proposed change. Considering both Natura 2000 and other nationally designated protected areas, Denmark legally protects 15.1% of its territory (against the EU 27 average of 26.4%) and 18,7% of marine areas (against the EU 27 average of 10.7%). Figure 6 shows the situation at EU level for land and marine sites to meet the EU’s biodiversity strategy 2030 target of 30%. Figure 6: Marine & terrestrial protected area coverage, 2021 Figure 7: Natura 2000 terrestrial protected area coverage, 2021 Designating Special Areas of Conservation (SACs) and setting conservation objectives and measures All SCIs have been designated as SACs and conservation objectives and measures have been drawn up for each of these sites. However, the quality of the current conservation objectives and measures is insufficient and will be updated in 2022/23. Moreover, the management plans are not sufficiently linked with other applicable legislation to tackle agriculture emissions which exert high pressure on species and habitats.; these aspects will also be a part of the coming plans, which were in public consultation in spring 2022. Progress in maintaining or restoring favourable conservation status of species and habitats

The results of Habitats Directive Article 17 and Birds Directive Article 12 reports on progress towards maintaining or restoring the favourable conservation status of species and habitats are key to measure the performance of Member States. According to the report submitted by Denmark on the conservation status of habitats and species covered by Article 17 of the Habitats Directive for the period 2013-2018, the share of assessments for habitats in good conservation status in 2018 is only 5% which is the second lowest in the EU and the same as the number reported under the previous reporting period (2007-2012), see Figure 8. As to protected species, the share of assessments in good conservation status in 2018 is 20% which is less than the 32% reported under the previous reporting period (2007-2012), see Figure 9. The bird conservation results with 54% show that the population of breeding species was either increasing in the short term or stable (for wintering species this figure was 27%). The share of habitats in bad conservation status has remained at 77% and the share of assessments for species in bad conservation status has increased to 34%, as shown in Figure 8.. The main pressures come from agriculture, mixed sources of pollution, development, construction and use of residential, commercial, industrial and recreational infrustructure and alien and problematic species. Figure 8: Assessments on conservation status for habitats for 2007-2012 and 2013-2018 reporting periods Figure 9: Assessments on conservation status for species for 2007-2012 and 2013-2018 reporting periods Denmark has used LIFE for nature projects for example the Better BirdLife and Open Woods projects. Denmark had two priority actions in 2019. The first was to achieve favourable conservation for habitats and species where there has been no progress; thus it is repeated. The second was to put in place clearly defined conservation measures for sites, and to provide adequate resources; on the first aspect there is limited progress since the management plans for the new planning period to put in place clearly defined conservation objectives and measures were in public consultation in spring 2022; on the second aspect, considering that Denmark has not submitted a complete priotised action framework (see section 5), a new priority action is included. 2022 priority actions ·increase efforts to ensure that the Natura 2000 network is managed in a way that achieves the favourable conservation status of protected habitats and species, especially by reducing main pressures such as from agriculture. ·finalize the update of the Natura 2000 management plans to be adopted for the next planning cycle to ensure that their conservation objectives and measures are clearly defined, sufficiently detailed and linked with other applicable legislation and plans to achieve favourable conservation status. ·complete and submit a finalised PAF. Bringing nature back to agricultural land and restoring soil ecosystems Agricultural land The biodiversity strategy works alongside the new farm to fork strategy and the new common agricultural policy (CAP) to support and achieve the transition to fully sustainable agriculture. The biodiversity and farm to fork strategies have set four important targets for 2030:

- a 50% reduction in the overall use of – and risk from – chemical pesticides; - a 50% reduction in the use of more hazardous pesticides; - a 50% reduction in losses of nutrients from fertilisers while ensuring there is no deterioration of soil fertility (which will result in a 20% reduction in the use of fertilisers); - bring back at least 10% of agricultural area under high-diversity landscape features and increase areas under organic farming to at least 25%. Denmark has an estimated 11.45% of area under organic farming, slightly above the EU average of 9,07% (2020), see Figure 10. Figure 10: Share of total utilised agricultural area occupied by organic farming per Member State The agricultural sector in Denmark has a level of high productivity. However, intensive farming generates negative impacts on the environment and climate, such as nutrient leaching, GHG emissions, loss of habitats and biodiversity. The farmland bird index fell from 79.3 in 2011 to 72 in 2019 (2000 = 100). Soil ecosystems Soil is a finite and extremely fragile resource. It is increasingly degrading in the EU. The new EU soil strategy, adopted on 17 November 2021, stresses the importance of soil protection, of sustainable soil management and of restoring degraded soils to achieve the Green Deal objectives as well as land-degradation neutrality by 2030. This entails: (i) preventing further soil degradation; (ii) making sustainable soil management the new normal; (iii) taking action for ecosystem restoration. One example of soil degradation is the area of soil that is sealed or artificialised (Figure 11). The net land taken per year in the period 2012-2018 can be seen as a measure of one important pressure on nature and biodiversity - land use change - which constitutes at the same time an environmental pressure on people living in urbanised areas. Despite falling during the last decade (land take was over 1000km2/year between 2000-2006), land take in EU28 still amounted to 539km2/year between 2012-2018 . The net land take concept combines land take with the share of land returned to non-artificial land use (re-cultivation). While some land was re-cultivated in the EU28 in the period 2000-2018, 11 times more land was taken. Denmark ranks above the EU average on land take with net land take of 152.8m2/km2 2012-2018 (EU27 average: 83.8 m2/km2). . In 2018, Denmark updated its reporting on land degradation in line with the next Performance Review and Implementation System (PRAIS3) reporting platform. It includes actions intended to combat land degradation .

However, Denmark has not yet committed to set land degradation neutrality targets under the United Nations Convention to Combat Desertification (UNCCD). The RRP for Denmark provides EUR 89 million for a reform to take 4 700ha of carbon rich soil out of production and EUR 38 million for an investment to rehabilitate four sites. Figure 11: Land take and re-cultivation in EU27 (m2/km2), 2012-2018 Forests and timber The EU Forest Strategy for 2030 adopted in July 2021 is a part of the Fit for 55 Package. The Strategy promotes the many services that forests provide. Its’ key objective is to ensure healthy, diverse and resilient EU forests, that contribute significantly to strengthened biodiversity and climate ambition. Forests are important carbon sinks and their conservation efforts are vital for the EU’s vision of achieving climate neutrality by 2050. Of the 27% of EU forest area protected under the Habitats Directive, less than 15% of areas assessed were found to be in a favourable conservation status. The share of forest area in the EU in a bad conservation status increased from 27% in 2015 to 31%. In Denmark, forests cover 12.19% of land with 21 000ha in Denmark covered by primary forests. The situation of forest habitats protected under the Habitats Directive is particularly worrying in Denmark as more than half of the assessed protected forests are in a bad status (Figure 12). Figure 12: Conservation status of forests protected under the Habitats Directive in EU Member States, 2013-2018 (% assessments) In accordance with the EU Timber Regulation (EUTR), which prohibits placing illegally harvested timber on the EU market, EU Member States competent authorities must conduct regular checks on operators and traders, and apply penalties for any breaches. By amending Article 20 of the EUTR, biennial reporting became annual and covers the calendar year as of 2019. In the period March 2017 - February 2019, Denmark carried out 49 checks on operators importing timber. It is estimated that Denmark had 24 000 operators placing domestic timber and 3 889 operators placing imported timber onto the internal market over the reporting period. The new Deforestation Regulation38 will repeal and replace the EU Timber Regulation, as it will essentially integrate and improve the existing system to control timber legality. Denmark hosted an EIR peer to peer study visit on implementation of the EUTR, 29 October2018. It also participated in a Workshop of the EUTR Nordic Baltic Competent Authorities 17-19 June2019. Invasive alien species (IAS) IAS are a key cause of biodiversity loss in the EU (alongside changes in land and sea use, overexploitation, climate change and pollution).

Besides inflicting major damage on nature and the economy, many IAS also facilitate the outbreak and spread of infectious diseases, posing a threat to humans and wildlife. The implementation of the EU Invasive Alien Species Regulation and other relevant legislation must be stepped up. The biodiversity strategy for 2030 aims to manage recognised invasive alien species and decrease the number of ‘red list’ species they threaten by 50%. The core of Regulation (EU) 1143/2014 on invasive alien species. (the IAS Regulation ) is the list of Invasive Alien Species of Union concern. There are currently 66 invasive alien species (IAS) of EU concern , of which: 30 are animal species and 36 are plant species; 41 are primarily land species, 23 are primarily freshwater species, 1 is a brackish-water species and 1 is a marine species. A 2021 report on the review of the application of the IAS Regulation based on reports that Member States submitted for the period 2015-2018, showed the implementation of the IAS Regulation is already starting to deliver on its objectives such as a coherent framework for addressing IAS at EU level and has increased awareness of the problem of IAS, including among the general public. At the same time, the above report identified some challenges and areas for improvement. Given that the deadlines for implementing the various obligations of the IAS Regulation applied gradually between July 2016 and July 2019, it is premature to draw conclusions on several aspects of the implementation of the IAS Regulation. Another 2021 report on the baseline distribution shows that of the 66 species on the Union list, 18 have been observed in the environment in Denmark. The spread can be checked in Figure 13. Denmark had a priority action in 2019 to remedy the lack of data, and seek ways to improve its surveillance system. In the 2019 Article 24 report, it is indicated that in Denmark, there is a registration website for IAS for citizens to register observations, which are then verified by the Danish Environmental Protection Agency. These data are especially important for rapid eradication actions. Additionally, Denmark has a national programme (NOVANA) for surveillance of IAS, and when new species are added to the EU list, they are included in the programme. Moreover, IAS are included in several surveillance projects, e.g., altas projects, and projects using new technologies, such as eDNA and satellite data. Figure 13: Number of IAS of EU concern, based on available georeferenced information for Denmark, 2021 Marine ecosystems The EU Biodiversity Strategy for 2030 aims to substantially reduce the negative impacts on sensitive species and habitats in marine ecosystems and to achieve good environmental status as well as eliminate or reduce the incidental catches of protected, endangered, threatened and sensitive species to a level that allows species recovery and conservation. The Marine Strategy Framework Directive (MSFD) requires Member States to achieve good environmental status (GES) of their marine waters. To that end, Member States must develop marine strategies for their marine waters, and cooperate with Member States sharing the same marine regarion or subregion. These marine strategies comprise different steps to be developed and implemented over six-year cycles. Among other obligations, the MSFD requires Member States by 15 October 2018 to define a set of GES characteristics for each descriptor (Article 9), and to provide an initial assessment of their marine waters (article 8). The Commission then assesses whether this constitutes an appropriate framework to meet the requirements of the Directive. The Commission assessed Denmark’s 2018 determinations of GES for each of the 11 descriptors in the MSFD and determined their adequacy in relation to the Commission GES Decision . A good or very good score indicates that the national GES determinations are well aligned with the requirements of the GES Decision, providing qualitative and quantitative national environmental objectives to be achieved for their marine waters (Figure 14). Figure 14: Level of adequacy of GES determination by Denmark (ANS and BAL regions) with criteria set under the Commission GES Decision - Article 9 (2018 reporting exercise)

Denmark has two marine sub-regions: ANS-NE Atlantic, the Greater North Sea. In this sub-region, 6 out of 11 determinations of GES were assessed as good or very good. Denmark’s assessment of GES is coherent with the MSFD for 6 out of 11 descriptors. BAL, the Baltic Sea. In this marine sub-region, 4 out of 11 determinations of GES were assessed as good or very good. Denmark’s assessment of GES is coherent with the MSFD for 4 out of 11 descriptors. The MSFD also requires that Member States make an assessment of the current environmental status of their marine waters in relation to the GES determination. A good or very good score indicates that the Member State has good capabilities to assess their marine environment in accordance with the requirements set out in the Commission GES Decision (Figure 15). Figure 15: Level of adequacy of national assessment of Denmark’s marine environment (ANS and BAL regions) with criteria set under the Commission GES Decision - Article 8 (2018 reporting exercise) In the marine sub-region ANS-NE Atlantic, the Greater North Sea, 6 descriptors out of 11 were scored as good or very good. Denmark’s assessment of its marine environment is coherent with the requirements set under the Commission GES Decision for 6 out of 11 descriptors. In the marine sub-region BAL, the Baltic Sea, 7 descriptors out of 11 were scored as good or very good. Denmark’s assessment of its marine environment is coherent with the requirements set under the Commission GES Decision for 7 out of 11 descriptors. In the 2019 EIR, Denmark had a priority action to achieve timely reporting under the MFSD. It has made limited progress on this with several descriptors missing. As highlighted in the Commission’s report on the implementation of the MSFD, although regional cooperation has improved since the adoption of the MSFD, more cooperation is needed to meet the requirements under the Directive of full regional coherence of the marine strategies. Furthermore, in March 2022, the European Commission published a Communication with recommendations for Member States. The Commission assessment highlights that Member States need to step up their efforts to determine the good environmental status and the use of the criteria and methodological standards according to the Commission GES Decision. The above considerations form the basis for the 2022 priority actions. 2022 priority actions ·ensure regional cooperation with Member States sharing the same marine (sub)region to address the main environmental pressures; ·implement the recommendations made by the Commission in the staff working document accompanying the Communication on recommendations per Member States and region on the 2018 updated reports for Articles 8, 9 and 10 of the MSFD. Ecosystem assessment and accounting The EU biodiversity strategy for 2030 calls on Member States to better integrate biodiversity considerations into public and business decision making at all levels and to develop natural capital accounting. The EU needs a better performing biodiversity-observation network and more consistent reporting on the condition of ecosystems. As mentioned in the 2019 EIR, Denmark has been involved with MAES since 2014 in collaboration with universities. A report was published in 2017 illustrating the synergies and trade-offs for six different scenarios between six ecosystem services and biodiversity. A case study also showed that it is possible to combine existing spatial data layers and models to facilite analyses of the effects of land use changes across many ecosystem services and biodiversity indicators. A follow up project on two modelling components has been carried out. No progress has been recorded since January 2016 (Figure 16). This assessment is based on 27 implementation questions, updated every six months. Progress on ecosystem accounting implementation is assessed at national level based on 13 questions. Figure 16: ESMERALDA MAES Barometer (January 2016 - March 2021)

Denmark had a priority action in the 2019 EIR to start work on a nationwide MAES initiative to start a natural capital accounting systems. Only limited progress has been made so another priority action is proposed in 2022.

2022 priority actions ·Continue supporting the mapping and assessment of ecosystems and their services, and ecosystem accounting development, through appropriate indicators for integrating ecosystem extent, condition and services (including some monetary values) into national accounts; continue supporting the development of national business and biodiversity platforms, including natural capital accounting systems to monitor and value the impact of business on biodiversity. 3.Zero pollution Clean air EU clean-air policies and legislation need to significantly improve air quality in the EU, moving the EU closer to the quality recommended by the WHO and curbing emissions of key air pollutants. Air pollution and its impacts on ecosystems and biodiversity should be further reduced with the long-term aim of not exceeding critical loads and levels. This requires strengthening efforts to reach full compliance with EU clean-air legislation and defining strategic targets and actions for 2030 and beyond. The 2030 zero-pollution action-plan targets are to reduce the health impacts of air pollution by 55% and to reduce the EU ecosystems threatened by air pollution by 25%, compared to 2005. The EU has developed a comprehensive suite of air quality legislative measures, which set health-based air quality standards and emission reduction commitments per Member State for a number of air pollutants. Air quality in Denmark is generally good with exceptions. The latest available annual estimates by the European Environment Agency (for 2019) indicate about 2 900 premature deaths (or 30 700 years of life lost (YLL)) attributable to fine particulate matter concentrations and 150 (1600 YLL) to ozone concentrations. The emissions of key air pollutants have fallen significantly in Denmark over the last years, while GDP growth continued (see Figure 17). According to the latest projections as submitted under Article 10(2) of the National Emission Reduction Commitments Directive (NECD), Denmark expects to reach its emission reduction commitments for SOx, NOx and NMVOC for the period 2020 to 2029 and from 2030 onwards. The projections however do not demonstrate reaching emission reduction commitments for NH3 and PM2.5 for 2020 to 2029 and from 2030 onwards. Latest inventory data submitted by Denmark, prior to review by the Commission, indicate that Denmark is in compliance with the emission reduction commitments for NOx, NMVOC, SO2 and PM2.5, and in non-compliance with the emission reduction commitment for NH3 in 2020. Denmark has submitted a National Air Pollution Control Programme on 1 April 2019 and an update on 11 August 2021. Figure 17: Emission trends of main pollutants/GDP in Denmark, 2005-2019 Figure 18 shows the emissions of PM2.5 and NOx by economic sector. Figure 18: PM2.5 and NOx emissions by sector in Denmark (2019) In 2020, Denmark did not register any cases exceeding the limit values set under the Ambient Air Quality Directive..

According to latest air pollutant emission projections additional measures would be needed to achieve the NECD emission reduction commitments. In the 2019 EIR, Denmark had two priority actions. The first was to take specific action under the national air pollution control programme (NAPCP) to reduce the main emission sources, in particular to reduce PM2.5 and ammonia. The second was to reduce ammonia ceilings to comply with national emission ceilings, by shifting to low-emission agricultural measures. Denmark has achieved limited progress on both fronts. 2022 priority actions ·take action under the NAPCP to reduce emissions from the main sources mentioned above. ·ensure full compliance with the EU air quality standards and maintain downward emissions trends of air pollutants, to reduce adverse air pollution impacts on health and economy with a view to reaching WHO guideline values in the future. Industrial emissions The main objectives of EU policy on industrial emissions are to: (i) protect air, water and soil; (ii) prevent and manage waste; (iii) improve energy and resource efficiency; (iv) clean up contaminated sites. To achieve this, the EU takes an integrated approach to the prevention and control of routine and accidental industrial emissions. The cornerstone of the policy is the Industrial Emissions Directive (IED). The Commission tabled a proposal in April 2022 . The revision seeks to improve the Directive’s contribution to the zero-pollution objective, as well as its consistency with climate, energy and circular-economy policies. The overview of industrial activities regulated by the IED is based on data reported to the EU Registry (2018). In Denmark, around 2 350 industrial installations are required under the IED to have a permit. This represents an increase of about 70 installations since 2015, largely due to an increase in the intensive rearing of poultry or pigs but also in the waste management sector. The distribution of installations is shown in Figure 19. Industrial sectors in Denmark with the most installations in 2018 are intensive poultry and pig rearing (68%), followed by the waste management sector, including landfills (15%), the food, drink and milk sector (5%) and the energy sector (4%). Figure 19: Number of IED industrial installations per sector in Denmark, 2018 The industrial sectors identified as contributing the largest burden to the environment for emissions to air were the energy sector for sulphur oxides (SOx), nitrogen oxides (NOx) as well as for cadmium (Cd), chromium (Cr) and mercury (Hg); the waste management sector for lead (Pb), zinc (Zn), and dioxins; the mineral industry for arsenic (As); and intensive rearing of poultry and pigs for ammonia (NH3) and PM2.5. The breakdown is given in Figure 20.

Figure 20: Emissions to air from IED sectors and rest of national total air emissions in Denmark, 2018 The environmental burdens for industrial emissions to water mainly result from the waste management for total nitrogen, phosphorous, from landfills for polycyclic aromatic hydrocarbons (PAHs), from the energy sector for total organic carbon (TOC) and from the pulp and paper sector for heavy metals. Figure 21 provides the breakdown by substance based on E-PRTR data. Figure 21: Relative releases to water from industry in Denmark, 2018 The EU approach taken to enforcing the IED requirements creates strong rights for the public to have access to information and to participate in the permitting process. This empowers individuals and NGOs, to ensure that permits are appropriately granted and their conditions followed. As part of environmental inspection, competent authorities carry out site visits to IED installations to take samples and to collect the requisite information. According to Article 23(4) of the IED, site visits are carried out between once every year and once every three years, depending on the environmental risks posed by the installations. In 2018, Denmark carried out 1 597 site visits, the majority to installations for intensive poultry or pig rearing (66%), followed by the waste management sector, including landfills and the food drink milk sector (8%), as shown in Figure 22. Figure 22: Number of inspections in IED installations in Denmark in 2018 The development of Best Available Techniques (BAT) Reference Documents (BREFs) and BAT Conclusions ensures good collaboration with stakeholders and enables better implementation of IED. Since the last EIR report, BAT Conclusions were adopted for waste incineration, for the food, drink and milk industries and for surface treatment using organic solvents including wood and wood products preservation with chemicals. The Commission relies on the efforts of national competent authorities to implement the legally binding BAT conclusions and associated BAT emission levels in environmental permits, resulting in considerable and continuous reduction of pollution. On 16 November 2021, Denmark hosted the EIR peer to peer workshop on ammonia reducing technology and measures. In 2019, Denmark had priority actions to review permits to comply with new adopted BAT conclusions and to step up control and enforcement to ensure compliance with BAT conclusions. These actions have been followed up by the Commission through the reporting by Denmark to the EU Registry. The Commission is currently verifying with Denmark the reported information on the permits granted for each installation in the scope of the IED. Major industrial accidents prevention – SEVESO The main objectives of EU policy on the prevention of major industrial accidents are to:

(i) control major accident hazards involving dangerous substances, especially chemicals; (ii) limit the consequences of such accidents for human health and the environment; (iii) continuously improve prevention, preparedness and response to major accidents. The cornerstone of the policy is Directive 2012/18/EU (the Seveso-III Directive) . The overview below of industrial plants regulated by the Seveso-III Directive, hereafter ‘Seveso establishments’, is based on data reported to the eSPIRS database (2018) and the Denmark report on implementation of the Seveso-III Directive for the period 2015-2018 . In Denmark, of the 122 Seveso establishments, 61 are categorised as lower-tier establishments (LTE) and 61 as upper-tier establishments (UTE) – based on the quantity of hazardous substances likely to be present. The UTE are subject to more stringent requirements. The number of Seveso establishments is given in Figure 23. Figure 23: Number of Seveso establishments in Denmark, 2011, 2014 and 2018 According to Denmark, an external emergency plan (EEP) is required for 61 UTE. In 2018, 61 UTE had an EEP and 55 of these EEP had been tested over the last three years. The summary is shown in Figure 24. The establishment of EEPs is essential to allow proper preparation and effective implementation of the necessary actions to protect the environment and the population should a major industrial accident nevertheless happen. Figure 24: Situation regarding EEP in Denmark, 2018 The information to the public referred to in annex V to the Seveso-III Directive – especially about how the public concerned will be warned in case of a major accident; the appropriate behaviour in the event of a major accident ; and the date of the last site visit – are permanently available for 100% of Seveso establishments in Denmark. This is an important provision of the Seveso-III Directive as this public knowledge could reduce the consequences of a major industrial accident. Figure 25 gives the share of UTE on which information on safety measures and requisite behaviours were actively made available to the public in recent years. Figure 25: Share of UTE for which information on safety measures and requisite behaviours were actively made available to the public in Denmark, 2011, 2014 and 2018 2022 priority actions

·Strengthen control and enforcement to ensure compliance with Seveso-III Directive provisions, especially on information to the public and EEP. Noise The Environmental Noise Directive provides for a common approach to avoid, prevent and reduce the harmful effects of exposure to environmental noise, although it does not set noise limits as such. The main instruments it uses in this respect are strategic noise mapping and planning. A relevant 2030 zero pollution action plan target is a reduction by 30% of the share of people chronically disturbed by transport noise compared to 2017. Excessive noise from aircraft, railways and roads is one of the main causes of environmental health‐related issues in the EU. It produces ischaemic heart disease, stroke, interrupted sleep, cognitive impairment and stress. In Denmark, based on a limited set of data, environmental noise is estimated to cause at least around 100 premature deaths and 400 cases of ischaemic heart disease annually. Moreover, some 55 000 people suffer from disturbed sleep. In Denmark, the number of people exposed to noise increased by 15% between 2012 and 2017, based on reported data. Noise mapping of agglomerations, roads and railways is complete, and based on the latest full set of analysed information. Water quality and management EU legislation and policy requires that the impact of pressures on transitional, coastal and fresh waters (including surface and ground waters) be significantly reduced. Achieving, maintaining or enhancing a good status of water bodies as defined by the Water Framework Directive will ensure that EU citizens benefit from good quality and safe drinking and bathing water. It will further ensure that the nutrient cycle (nitrogen and phosphorus) is managed in a more sustainable and resource-efficient way. Water Framework Directive The Water Framework Directive is the cornerstone of the EU’s water policy in the 21st century. This Directive along with other water-related directives set the framework for sustainable and integrated water management. The aim is to achieve a high level of protection of water resources, to prevent of further deterioration and to restore water to good status. By March 2022, all Member States have to report the third generation of river basin management plans (RBMPs) under the Water Framework Directive. The Commission will assess the reported status and progress, and will check how the findings identified in the assessment of the second RBMPs have been addressed. Denmark has not yet reported the third RBMPs. The Commission published in December 2021 the sixth Implementation Report. It includes, an interim assessment on progress of the implementation of the programmes of measures and on monitoring of the new priority substances. The assessment report for Denmark showed that the planned and implemented measures in all four river basin districts (RBDs) contributed significantly to reaching the objectives of the Water Framework Directive in 2021. However, the pace had slowed in particular for planned measures related to wetlands, hydromorphological changes on rivers and lake restorations. In Denmark, 70 research projects took place in the 2nd management cycle to better identify pressure factors, potential areas for action and their significance for achieving the environmental objectives. Based on the second RBMPs reporting and data published in 2020, in Denmark 28.2% of all surface water bodiesachieved good ecological status (with unknown status 23.8%) and only 0.8% were in good chemical status (with 98.5% unknown). For groundwaters, 25.1% did not achieve good chemical status (30.6% were in unknown status) and 0.7% were in a poor status. Figure 26 illustrates the proportion of surface water bodies in Denmark and other European countries that failed to achieve good ecological status. Figure 26. Proportion of surface water bodies (rivers, lakes, transitional and coastal waters) in less than good ecological status per River Basin District Figure 27 presents the percentage of surface water bodies in Denmark and other European countries failing to achieve good chemical status. For Denmark, the percentage is 0.7%, including water bodies failing due to substances behaving as ubiquitous PBTs (persistent, bio-accumulative, or toxic). Excluding uPBTs, the percentage of surface water bodies that did not achieve good chemical status is unknown. Figure 27. Percentage of surface water bodies not achieving good chemical status Under the IED framework, Denmark achieved a significant decrease the last decade (20.1%) in industrial releases of heavy metals such as Cd, Hg, Ni, Pb and an increase (21.4%) in total organic carbon (TOC) to water.

The total volume of water abstracted annually in Denmark from surface and groundwater sources in 2018 was 868.77 hm3. By sector, the percentage of water abstraction was 56.86% for agriculture, 40.56% for public water supply, 0.07% for electricity cooling, 1.53% for manufacturing and 0.97% for mining and quarrying, as illustrated in Figure 28. It should be noted that 2018 was a particularly dry year, so the amount of water used for agriculture was higher than normal. Denmark uses a register to monitor water abstractions. All water abstractions require a permit, except for a broad owner's abstraction of surface water for cattle, under the Danish Water Supply Act. Figure 28: Water abstraction per sector in Denmark In Denmark, the water exploitation index plus (WEI+) was 1.49% in 2017, far less than the 20% that is generally considered as an indication of water scarcity (Figure 29); Denmark is ranked 18th (from high to low score) in the EU level in terms of WEI+ . Figure 29: Water exploitation index plus (WEI+) inside EU, 2017 Denmark has taken several measures (smart meters, intelligent pumps, intelligent valves, deployed noise loggers and much more) to reduce the level of non-revenue water (NRW), including creating an economic incentive for water utilities to keep their NRW level below 10%. Denmark has also taken action to create awareness of the importance of saving water. As a result, Denmark has managed to reduce its water consumption by over 40% since 1980. Doing so means that Denmark has achieved one of the world's lowest levels of NRW with a consistent national average of just 6 to 8% compared to some parts of the world where NRW is over 50%. Water loss has been kept low through systematic leakage detection and by implementing modern ICT tools to assist NRW performance monitoring and reporting Another good practice in Denmark is the Water Valley initiative for water technology that will enable water consumption to become more resource efficient, cost effective and quality assured. Floods Directive As mentioned, the Commission published in December 2021 the sixth Implementation Report. It includes the review and update of the Preliminary Flood Risk Assessments during the second cycle (2016-2021). The assessment report showed that in Denmark, the information provided in the Preliminary Flood Risk Assessment document in combination with the methodology report was informative and clear. Denmark also applied clear methodology to calculate APSFRs using a spatial process to rank areas of flood risk, factoring in climate change. However, pluvial floods should be also considered – at least in areas with high vulnerabilities. Denmark has made an attempt to overcome data scarcity for past fluvial flood events by conducting a survey amongst municipalities. Denmark has not yet adopted and reported the second generation of flood risk management plans (FRMPs) under the Floods Directive. The European Commission will assess progress since the adoption of the first flood risk management plans and publish a report. Drinking Water Directive As regards the Drinking Water Directive , no new assessment of the quality of Drinking Water is available since the EIR 2019. The quality of drinking water in Denmark has not been indicated as an area of concern. The recast Directive entered into force on 12 January 2021, Member States have until 12 January 2023 to transpose it into their national legal system. Denmark will have to comply with these reviewed quality standards. Bathing water Regarding the Bathing Water Directive, Figure 30 shows that in 2020, of the 1 026 Danish bathing waters, 90.7% were of excellent quality. The evolution is shown in Figure 31. Figure 30: Bathing water quality in Europe in the 2020 season Figure 31: Bathing water quality 2017-2020

Nitrates Directive The latest Commission Report on the Implementation of the Nitrates Directive, referring to the period 2016-2019 , warns that nitrates are still polluting water in the EU and causing harm. Excessive nitrates in water are harmful both to human health and to ecosystems, causing oxygen depletion and eutrophication. Where national authorities and farmers have cleaned up waters, it has had a positive impact on drinking water supply and biodiversity, and on sectors such as fisheries and tourism that depend on them. Nevertheless, excessive fertilisation remains a problem in many parts of the EU. Denmark has received a derogation under the Nitrates Directive for the application of more than 170 kg/ha of nitrogen from manure until 31 July 2024. According to the last report on the implementation of the Nitrates Directive, between periods 2008-11 and 2016-19, groundwater quality has slightly improved as compared to the previous reporting period, with the percentage of stations reaching or exceeding 40 or 50mg nitrate per litre that falling from 6.9% to 6.7% and from 19.3% to 14.3%, respectively. The situation concerning nitrates concentrations in surface water is stable with some improvements recorded in reducing of eutrophication. However, nutrient inputs to the Baltic Sea around Denmark however have significantly decreased for nitrogen in the Danish Straits and Kattegat, and for phosphorus in Kattegat. In 2020, the government reached a new agreement on nitrogen. In 2021, this was followed up by a deal on the green transition of Danish agriculture. Improving the nitrogen and phosphorus cycles helps improve the circularity of the economy. Nevertheless, the Commission is aware of the challenges that the nutrient surplus in Denmark poses on the local environment and for the Baltic Sea. It will continue its structured dialogue with the Danish authorities to ensure that appropriate measures are taken to implement EU legislation. However latest data for 2010-2020 shows increases in pollutant releases to water of 35.5% for nitrates, 30.8% for phosphorus and 21.4 for TOC. Urban wastewater treatment Regarding the Urban Wastewater Treatment Directive, in Denmark, the compliance rate is 99% much higher than the EU average of 76% in 2018. Further action is needed to provide biological treatment to additional 0.02 million p.e of urban wastewater (0.2%) and biological treatment with nitrogen and phosphorus removal to additional 0.07 million p.e. of urban wastewater (0.7%) (see Figure 32). Figure 32: Proportion of urban waste water that meets all requirements of the UWWTD (collection, biological treatment, biological treatment with nitrogen and/or phosphorus removal) in compliant urban areas of the UWWTD (‘compliance rate’), 2018 In the 2019 EIR Denmark had four priority actions. The first was to take steps to improve monitoring of surface waters and the second was to complete the development of assessment methods for biological quality elements. The Commission cannot evaluated this until Denmark submits the third RBMP. The third priority action was to adopt legislation on nutrient pollution from agriculture to address environmental pressures and water quality issues; Denmark has done so. The fourth 2019 priority action was to integrate flood risk management cycles amongst various levels of administration. 2022 priority actions ·Maintain progress to reduce agricultural pollution. Chemicals The EU seeks to ensure that chemicals are produced and used in a way that minimises any significant adverse effects on human health and the environment. In October 2020, the Commission published its chemicals strategy for sustainability - 'Towards a Toxic-Free Environment' which led to some systemic changes in EU chemicals legislation. The strategy is part of the EU's zero-pollution ambition – a key commitment of the European Green Deal. The EU’s chemicals legislation provides baseline protection for human health and the environment. It also ensures stability and predictability for businesses operating within the internal market. The Commission has collected information on the enforcement of REACH and CLP since 2007. In December 2020, the Commission assessed the Member States reports on implementation and enforcement of these Regulations, in line with REACH Article 117(1) and CLP Article 46(2). According to the latest available data, national enforcement structures have not changed much. However, it is apparent from this report that there are still many disparities in implementing REACH-CLP and notably in the area of the law enforcement. The recorded compliance levels seem to be quite stable over time, but they have worsened slightly possibly due to enforcement authorities being more effective in detecting noncompliant products/companies and more non-compliant products being put on the EU market. In August 2021, the Commission published a measurable assessment of the enforcement of the two main EU regulations on chemicals using a set of indicators tracking different aspects of enforcement. In Denmark, responsibility for checking compliance with REACH lies with the Danish Environmental Protection Agency : As a rule, all infringements of REACH are classed as serious or very serious environmental administrative offences. If the infringement is sufficiently serious, the competent authority may decide to impose further penalties in addition to a fine. Where necessary, it may also order the provisional seizure of assets and documents. In Denmark 4.5 person years are allocated to REACH and CLP enforcement . The enforcement strategy is based on risk-based prioritisation to focus on areas with the highest risk of a breach, and areas where breaches can lead to serious risk to health and the environment. Denmark was below the EU average in the % of non-compliance cases in 2019 (see Figure 33).

Figure 33: Percentage % of non-compliance cases out of the total number of REACH and CLP controls during 2019 per Member State and compared to the EU average In 2021, Denmark reached a political agreement on a strategy on pesticides. This was followed up in early 2022, with an agreement on biocides in agriculture and on a chemicals strategy. 2022 priority actions ·upgrade the implementation and enforcement administrative capacity toachieve a zero tolerance for non-compliances. 4.Climate action In line with the Paris Agreement and as part of the European Green Deal, the European Climate Law sets the EU target of reaching climate neutrality by 2050 and reducing greenhouse gas (GHG) emissions by 55% by 2030 compared to 1990. The law also limits the contribution that carbon removals can make towards emission reductions in 2030 to ensure a sufficient mitigation effort. The EU and its Member States submitted updated Nationally Determined Contribution (NDC) to the UNFCCC in December 2020. The EU is working across all sectors and policies to cut GHG emissions and make the transition to a climate-neutral and sustainable economy, as well as addressing the unavoidable consequences of climate change. EU climate legislation incentivises emissions reductions from power generation, industry, transport, the maritime sector and fluorinated gases (F-gases) used in products. For road transport, EU legislation requires the GHG intensity of vehicle fuels to be cut by 6% by 2020 compared to 2010 and sets binding GHG emission standards for different vehicle categories . Under the F-gas Regulation, the EU’s F-gas emissions will be cut by two thirds by 2030 compared with 2014 levels. From 2021, emissions and removals of GHGs from LULUCF have been included in the EU emission-reduction efforts. The EU adaptation policy is an integral part of the European Green Deal. From 2021, Member States are required to report on their national adaptation policies , as the EU Climate Law recognises adaptation as a key component of the long-term global response to climate change. Member States will be required to adopt national strategies, and the EU will regularly assess progress as part of its overall governance on climate action. The updated EU adaptation strategy, published in February 2021, sets out how the EU can adapt to the unavoidable impacts of climate change and become climate resilient by 2050. Key national climate policies and strategies In December 2019, Denmark adopted its integrated national energy and climate plan (NECP) for the 2021-2030 period covering decarbonisation, deployment of renewable energy and energy efficiency. The plan will contribute to Denmark’s domestic objective to reduce greenhouse gas emissions by 70% by 2030 (relative to 1990) and achieve carbon neutrality by 2050 at the latest. In its RRP Denmark allocates 59% of available resources to climate objectives and outlines crucial reforms and investments including in relation to sustainable transport and clean and efficient production and on energy efficiency in public buildings and households. A green tax reform is also being implemented (more details in section 5). Denmark’s first national adaptation strategy was adopted in March 2008. It is based on the principle that all parts of society contribute to climate adaptation.

Between 1990 and 2020, economy wide greenhouse gas emissions in Denmark fell by 41%. Danish greenhouse gas emissions per person are close to the EU average (see Figure 34). Figure 34: Total greenhouse gas emissions (incl. international aviation) in Denmark, 1990-2020 Effort sharing For emissions not covered by the EU ETS, Member States have binding national targets under the Effort Sharing legislation. Denmark’s target is to reduce emissions not covered by the EU emissions trading system (such as buildings, road transport, agriculture, small industry and waste) by 20% by 2020 and by 39% by 2030, relative to the 2005 levels. Denmark has met its 2020 target (see Figure 35). According to its NECP, Denmark intends to achieve reductions in line with its current Effort Sharing target for 2030. Figure 35: Emissions and targets under the Effort Sharing Decision/ Effort Sharing Regulation in Denmark 2020 and 2030 as percentage change from 2005 Figure 36: Emissions, annual emission allocations (AEAs) and accumulated surplus/ deficit of AEAs under the Effort Sharing Decision in Denmark 2013-2020 Key sectoral developments In 2019, road transport in Denmark accounted for 26% of greenhouse gas emissions. Little progress has been made in reducing emissions from fuels and cars; compared to 2005 emissions, it only decreased by 2%. The greenhouse gases (GHG) intensity of vehicle fuels in Denmark decreased by 2.7% from 2010 to 2019. The country needs to act swiftly to meet the current reduction target of 6% by 2020. In 2020 Denmark increased its blending mandates for the road transport sector, and by 2022 legislation has been altered to a greenhouse reduction target, which also aims to reduce the global emissions of the used bio and renewable fuels. The greenhouse gas reduction target is set to further increase in 2025, 2028 and 2030, and by 2025 the Danish government will include indirect land use criteria (ILUC), to further reduce the global impact of the use of biofuels. The Danish government presented a specific transport plan to tackle key road congestion problems and has taken action to roll out the European Rail Traffic Management System signalling on Danish railroads, which is a prerequisite for more frequent train schedules and for further electrification of the rail network. The plan also foresees investments in public transport and cycling. The Danish government also aims to phase out the sale of new traditional diesel and petrol cars as of 2030 and to increase the sale of electric vehicles. Figure 37: Greenhouse gas emissions by sector in Denmark – historical emissions 1990-2020, projections 2021-2030 On buildings, it is crucial to increase energy efficiency in order to reach climate goals. In agriculture, further measures are needed to reduce emissions, both CO2 and non-CO2 emissions. Figure 37 shows emission trends by sector. In the land use, land use change and forestry (LULUCF) sector, Denmark projects moderate net emissions by 2030. The quantities reported under the Kyoto Protocol for the LULUCF sector in Denmark show net emissions of, on average, 1.8 Mt CO2-eq for the period 2013 to 2019. In this regard, Denmark represents -0.5% of the annual average sink of -344.9 Mt CO2-eq of the EU-27. Accounting for the same period gives net average annual credits of -5.4Mt CO2-eq, which corresponds to 4.7% of the EU-27 accounted sink of -115.0 Mt CO2-eq. There is an overall increasing pattern of reported net emissions. Accounted net credits show no clear trend. Denmark is one of three EU Member States with average net emissions and one of six EU Member States that show net emissions for at least one year (see Figure 38). Figure 38: Reported and accounted emissions and removals from LULUCF in Denmark

Use of revenues from the auctioning of EU ETS allowances Total revenues from auctioning of emission allowances under the EU ETS over the years 2012-2021 exceeded EUR 1.1 billion. 100 % of auctioning revenue was spent on climate and energy purposes. In Denmark, revenues are not earmarked, for example projects have reported up to 100% of revenue each year. 2022 priority actions ·further invest in the electricity grid network to ensure that the increasing share of renewable energy can be used efficiently, for example, on system flexibility, smart grids and storage. Part II: Enabling framework: implementation tools 5.Financing Environmental investment needs in the European Union Financing environmental measures is essential for their success. Although most financing comes from national sources, various EU funds contribute significantly, helping to close the financing gaps. Post-2020, environmental implementation will also be supported by the EU’s COVID-19 Recovery Fund (via the RRF) and the ‘do no significant harm’ principle which runs across the EU budget. The renewed commitments made at COP26 (Glasgow, October-November 2021) and the Biodiversity Convention (April-May 2022) will also be reflected in the EU budget. Overall environmental investment gaps (EU27) The EU’s green transition investment needs cover a range of interlinked areas. The additional investment needs in addition to the baseline figures (i.e. the gap between what is needed and what is forecast to be invested if no additional action is taken) for climate, energy and transport were estimated at EUR 390 billion per year (EU27), with a further EUR 130 billion needed to achieve the EU's core environmental objectives. Climate adaptation costs can also be significant, reaching a total of EUR 35-62 billion (narrower scope) or EUR 158-518 billion (wider scope) per year. Those investment needs to reflect the implementation objectives for 2020 to 2030 (except for climate adaptation the costs of which are expected to be spread over a longer time horizon). A preliminary update of the EU’s core environmental investment gap is provided in Table 1. Almost 40% of the environmental investment needs relate to dealing with pollution, accounting for nearly two-thirds of the total gap if combined with water management. The investment gap in circular economy and waste is estimated to be between EUR 13-28 billion per year, depending on levels of circularity implemented. The annual biodiversity financing gap is estimated at around EUR 20 billion. Table 1: Estimated breakdown of the EU’s environmental investment gaps, by environmental objective, 2021-2030 per year Environmental objective Estimated investment gap (EU-27, per year) EUR billion % Pollution prevention & control 42.8 39% Water management & industries 26.6 24% Circular economy & waste 13.0 12% Biodiversity & ecosystems 21.5 20% R & D & I and other 6.2 6% Total 110.1 100% Environmental investment needs in Denmark

Climate is a political priority in Denmark. In 2020, the Danish parliament passed a climate law with a commitment to reducing greenhouse gas emissions by 70% (compared to 1990 levels) by 2030. The Danish Minister of Finance has positioned the green transition as a core policy priority. The following environmental investment needs have been identified by sector. Pollution prevention & control The EU’s First Clean Air Outlook under the clean air programme estimated that the total air pollution control costs for Denmark to reach the NECD Emission Reduction Requirements by 2030 amount to EUR 1 113 million per year, including EUR 807 million for capital investment (assuming it meets its 2030 climate and energy targets). The Second EU’s Clean Air Outlook suggests that, if all relevant legislation adopted up to 2018 (including all air pollution and the 2030 climate and energy targets set in 2018) delivered their full benefits and if Member States also implemented the measures announced in their NAPCPs, the EU would largely achieve the reductions of air pollutant emissions that correspond to the obligations under the NECD for 2030, except for ammonia (NH3) emissions in 15 Member States, including Denmark. Water management According to the OECD, in Denmark surface water is scarce. As a result, groundwater is the main source of drinking water. Although Denmark has abundant groundwater resources, some regions experience pressure on groundwater. Urbanisation and a significant increase in demand for irrigation will increase competition for water resources, including groundwater. Intrusion of saltwater from sea level rise may affect the quality of groundwater. Despite high levels of expenditure on water supply and sanitation, there remains a small compliance gap with wastewater treatment. EU funding has provided a significant share of past public funding over the past decade. It is also estimated that Denmark will need to invest an additional cumulative EUR 1 938 million by 2030 for drinking water and sanitation over current spending levels, corresponding to a need of around EUR 190 million investment (capital expenditure) per year, most of which (over 90%) for wastewater). Moreover, the recent sixth Water Framework Directive and Floods Directive Implementation Report and the financial - economic study accompanying it, are also a relevant source of information in this domain. Waste & the circular economy According to a Commission study to meet the recycling targets for municipal waste and packaging waste, Denmark still needs to invest an additional EUR 290 million (around EUR 41.5 million per year) between 2021-2027 in collection, recycling reprocessors, biowaste treatment, waste sorting facilities and waste registry digitalisation. Of this, biowaste treatment facility replacement costs are EUR 26 million for 2021-27 (or 3.7 million per year). This does not include investment necessary for other key waste streams (plastics, textiles, furniture) or to unlock a higher uptake of circularity and waste prevention across the economy. Biodiversity and ecosystems The prioritised action framework (PAF) adopted by the Member States under Article 8 of the Habitats Directive present the conservation priorities for the Natura 2000 network and its supporting green infrastructure, their costs and planned funding sources for the current budget (2021-2027). Denmark has not yet submitted a finalised PAF, which was expected by the end of 2021. To note that PAF costs exclude the additional costs to implement the biodiversity strategy to 2030, for instance on increased protection and restoration. EU environmental funding 2014-2020 The multiannual financial framework (MFF) for the years 2014-2020 allocated almost EUR 960 billion (in commitments, 2011 prices) for the EU. The commitment to achieving the green transition included a 20% climate spending target and funding opportunities for the environment, in particular, under the European Structural and Investment (ESI) Funds. The 2014-2020 budget was subsequently topped up with over EUR 50 billion (current prices) from REACT-EU programme for cohesion policy action against coronavirus (COVID-19). Denmark received EUR 1 955.6 million from the ESI funds over 2014-2020 to invest in job creation and a sustainable and healthy economy and environment. Planned direct environmental investment amounted to EUR 180.1 million with a further EUR 32.9 million identified as indirect environmental investment value, totalling EUR 213 million (Table 2). Figure 39 gives an overview of (planned) individual ESI funds earmarked specially for Denmark (EU amounts, without national amounts) for the 2014-2020 period and the environmental investments it comprises. REACT-EU investments are focused on green technologies and addressing climate change (carbon capture). Figure 39: ESI Funds allocated to Denmark, including environmental investments, 2014-2020 Table 2: Direct and indirect environmental investments under the ESI Funds in Denmark, 2014-2020 Instrument Allocations for the environment (EUR million) Under Cohesion policy (ERDF) Direct environmental investments Indirect environmental investments energy efficiency business development, R&I 23.1 0.0 23.1 18.5 4.6 Under EAFRD/rural development Direct environmental investments climate and risk management Indirect environmental investments renewable energy energy efficiency 52.8 43.1 43.1 9.8 4.2 5.6 Under EMFF Direct environmental investments environment protection & resource efficiency Indirect environmental investments 137.0 137.0 137.0 0.0 Under ESI Funds total Direct environmental investments Indirect environmental investments 213.0 180.1 32.9

Funding for the environment from the ESI funds has also been supplemented by other EU funding programmes available to all Member States, such as, the LIFE programme, Horizon 2020 or loans from the European Investment Bank (EIB), that add up to an estimated total of EU environmental financing of EUR 316 million for Denmark in 2014-2020 The LIFE programme is entirely dedicated to environmental and climate objectives. It finances demonstration and best practices to prepare the roll-out ofgreen solutions. Between 2014-2020 period, Denmark received EU funding for 11 LIFE projects (for nature and environment) with EUR 49 million from the LIFE programme (out of 1 028 EU27 LIFE projects with a total EU contribution of EUR 1.74 billion). In 2014-2020, the Horizon 2020 programme allocated some EUR 53.6 million to Denmark for the environment, in particular, for climate action, the circular economy and natural resources, with a total environmental share of 3.1% from Denmark’s Horizon 2020 allocation. Denmark did not use funding under the European Fund for Strategic Investments,for projects with a dedicated environmental objective. The environment-related EIB loans to Denmark amounted to 0.5 million (supporting waste and water), out of an overall EUR 4.7 billion EIB lent to Denmark in the period. The country ranks 17 in size in terms of total EIB lending. In 2020, the EIB provided EUR 24.2 billion to fight climate change, 37% of its total financing and EUR 1.8 billion (3% of financing) for the environment. EU environmental funding 2021-2027 The 2020 European Green Deal investment plan calls for upon EUR 1 trillion in green investments (public and private) by 2030. The EU’s multiannual budget for 2021-2027 and the NextGenerationEU (NGEU) Fund will mobilise EUR 2.018 trillion (in current prices) to support the COVID-19 recovery and the EU's long-term priorities, including environmental protection. Following the EU Green Deal’s ‘do no harm’ pledge and the Interinstitutional Agreement on the 2021-2027 MFF, 30% of the EU budget will support climate action efforts and 7.5% (as of 2024) and 10% (as of 2026) will support biodiversity. These latter targets require increased programming of financial resources for biodiversity, specifically under the 2021-2027 Cohesion policy and the 2023-2027 common agricultural policy. Sustainable finance significantly increases transparency on environmental sustainability (a goal promoted by the EU Taxonomy), strengthens non-financial reporting requirements and facilitates green bond issuance (by the EU green bond standard). Reinforced by the renewed sustainable finance strategy (2020) it will increase investment flows to climate and environmental action. To help finance climate adaptation measures, the new strategy on adaptation to climate change can help close the insurance protection gap from climate-related events that are uninsured. The EIB will align 50% of its lending with climate and environment by 2025 with an EUR 250 billion contribution to the Green Deal investment plan by 2027. Table 3: Key 2021-2027 EU funds allocated to Denmark (current prices) Instrument Country funding allocation (million EUR) Cohesion policy ERDF ESF+ ETC (ERDF) Total: 518.6 247.2 119.6 153 Just Transition Fund 88.9 EAFRD/rural development under CAP strategic plans 2023-2027 379.7 European Maritime, Fisheries and Aquaculture Fund (EMFAF) 201.0 Recovery and Resilience Facility (RRF) 2021 – 2026 1 551.4 (grants) As part of the EU’s Recovery Package, Denmark requested EUR 1.511 billion from the RRF, all in the form of grants. A 59.5% share of RRF funding for Denmark relates to measures that do contribute to the country’s climate and environmental objectives. This puts Denmark among the top Member States (EU average: 45.3%). Denmark also stands above the 37% climate expenditure target, the minimum level required under the RRF Regulation (see Figure 40). The main green priorities under the RRP for Denmark are to achieve a green transition in agriculture, energy efficiency and green heating, green tax reform, sustainable transport and to fund green research and development. Overall, the plan ensures that direct actions can be taken at local level to contribute to the green transition, while protecting or restoring the environment, and in compliance with the Do No Significant Harm (DNSH) principle . Figure 40: Climate expenditure in RRPs, 2021-2026



The partnership agreement 2021-27 for Denmark allocates ERDF funding to invest in promoting the circular economy and EMFAP to restore water bodies to good ecological status, both under priority objective 2 (low carbon). Denmark satisfies the enabling condition for a waste management plan allowing to fund investments in the circular economy. However, the enabling condition for a prioritised action framework for investments in nature and biodiversity is not fulfilled as a final version yet to be submitted. Under the NextGenerationEU Fund, the Commission will issue up to EUR 250 billion of EU green bonds (one third of the NGEU) until 2026 that meet the general spirit of the DNSH principle. But this will not be subject to the current delegated acts on the EU Taxonomy and will not fully align with the proposed EU green bond standard. In addition to EU funds earmarked specifically for Denmark in the 2021-2027 period, there are also funding programmes available at EU level and are open to all Member States. These include, among others, the LIFE programme (EUR 5.4 billion), Horizon Europe (EUR 95.5 billion) , the Connecting Europe Facility (EUR 33.7 billion) and the funds due to be mobilised under InvestEU . They will also support the green transition, including research and innovation projects on environmental protection (Horizon Europe) , clean transport and energy (the Connecting Europe Facility) or sustainable infrastructure (InvestEU) . National environmental protection expenditure

Total national spending on environmental protection (all current and capital expenditure) in the EU27 was EUR 272.6 billion in 2020, representing 2% of the common GDP and quite stable over time. Although in absolute figures expenditure is concentrated in a few countries , as a share of GDP, most countries spend between 1-2%; Denmark spends around 2%. Of the above total, the EU27’s capital expenditure (Capex) on environmental protection (i.e. investment) amounted to EUR 56.3 billion in 2018, falling to EUR 54.5 billion in 2020, representing around 0.4% of GDP. Most Member States invested 0.2-0.5% of their GDP in environmental protection. Denmark invested 0.4% of GDP in 2018. During 2014-2020, this totalled around EUR 376 billion of environmental investment in the EU27, and EUR 9.1 billion for Denmark (see Figure 41). Figure 41: Direct and indirect environmental protection investments in the EU-27 (EUR million and % of GDP), 2018

By institutional sector, 7.7% of Denmark’s environmental protection investments (capital expenditure) came from the general government, 86% from specialist producers (of environmental services, mainly waste and wastewater companies and 6.4% from the business sector’s (ancillary producers, i.e. whose environmental activities are usually ancillary to the core ones) expenditure. At EU level, 37% comes from governments, 33% from specialist producers and 30% from industry (business). Figure 42: EU-27 Member States' environmental protection investments (Capex) by institutional sectors (Total economy = 100%), 2018 A breakdown of investment by environmental topic is only partially available, at the level of institutional sectors (rather than at economy level), due to different reporting patterns. At Denmark’s general government level, a significant share of environmental protection investments (around 60%) went on environmental research and development and 21% on biodiversity in 2018 (based on available data that are not comprehensive or fully validated). In terms of the country’s specialist producers, 76% of investment were received by wastewater and 24% by waste management bodies. In the business sector, 41% of investment went on air protection, 20% on wastewater and 9% on waste, the most significant areas of investment (see Figure 42). The total annual European green bond issuance in 2020 was USD 156 billion (EUR 137 billion ), rising from USD 117 billion (EUR 105 billion) in 2019, including some non-EU European countries. By EU27 Member States only 2020 annual green bond issuance was EUR 124 billion, including EUR 1.95 billion issued by Denmark. 83% of the green bonds issued by European countries served energy, buildings or transport objectives between 2014-2020, 8% supported water and waste, and an additional 6% for land use – with links to ecosystem conservation & restoration, based on the Climate Bonds Taxonomy being broadly similar to the EU Taxonomy (see Figure 43). Figure 43: Annual EU green bond issuance in 2020 (EUR billion) Green budget tools Green taxation and tax reform In absolute terms, Denmark’s revenue from environmentally related taxes remains around the EU average in 2020, as shown in Figure 44. Within this, energy and transport taxation represent the highest share with 52.2% and 42.5% in 2020, while pollution/resource tax accounted for 5.3%. In terms of % of GDP, environmental taxes accounted for 3.17% in 2020, the third highest in the EU (EU average is 2.24 %). Figure 44: Environmental taxes in the EU-27, 2020

The 2019 European Green Deal underlines that well-designed tax reforms can boost economic growth and resilience, foster a fairer society and a just transition, by sending the right price signals and incentives to economic actors. The Green Deal creates the context for broad-based tax reforms, for the removal of fossil fuel subsidies, shifting the tax burden from labour to pollution, and for factoring in social considerations . The application of the ‘polluter pays principle’ stipulating that polluters should bear the cost of measures to prevent, control and remedy pollution is facilitated by the EU Commission’s TSI flagship on greening taxes. In Denmark there are many examples of green tax reform, notably on phosphorus and pesticides. Denmark could consider bringing in a system of tradable livestock rights to reduce ammonia. Environmentally-harmful subsidies

Addressing and removing environmentally harmful subsidies is a further step towards wider fiscal reforms . Fossil fuel subsidies are costly for public budgets and undermin the achievement of the Green Deal objectives. In many cases they also go against incentives for green investments and distort the playing field. Fossil fuel subsidies fluctuate around EUR 55 billion in the EU since 2015. They rose by 4% between 2015 and 2019, however some countries, such as Latvia, Lithuania Sweden, Greece or Ireland, managed to decrease them. In the EU, subsidies for petroleum products, in sectors such as transport and agriculture, continued to rise over this period, whereas subsidies on coal and lignite fell, largely owing to the falling role of solid fuels in electricity generation. As a share of GDP, fossil fuel subsidies ranged from 1.2% in Hungary to less than 0.1% in Luxembourg in 2019 (0.4% on EU average). Total fossil fuel subsidies amounted to EUR 1.4 billion in Denmark in 2019 – representing 0.4% of GDP (around the EU-average). In 2020, the total amount of fossil fuel subsidies fell to EUR 52 billion (due to falling consumption trends amid the COVID-19-related restrictions). Unless action is taken by the Member States , these subsidies are likely to rebound as economic activity picks up from 2020. Further details of the situation in Denmark are shown in Figure 45. Figure 45: Trends in natural gas, petroleum products and coal subsidies in Denmark % GDP 2013 2014 2015 2016 2017 2018 2019 2020 Natural gas No data No data No data No data 0,01 0,03 0,04 0,07 Petroleum products 0,30 0,29 0,29 0,27 0,34 0,34 0,34 0,34 Coal 0,05 0,05 No data No data No data No data No data No data Current green budgeting practices Green budgeting encompasses multiple climate and environmental tagging and tracking practices in budgets with some Member States already using green budgeting elements. Green budgeting helps identify and track green expenditure and green revenues to increase transparency on the environmental implications of budgetary policies, improve policy coherence and supporting green policies (including climate and environmental objectives). The EU has also developed climate proofing and sustainability proofing guidance to assess project eligibility and compliance with environmental legislation and criteria. The European Commission drew up a green budgeting reference framework and launched a technical support flagship (TSI) on green budgeting in 2021 to assist Member States in drafting or developing national green budgeting frameworks to improve policy coherence and for the green transition. Denmark participated in the European Commission’s green budgeting project with a training 24 February 2022. Denmark has a new macroeconomic model, GreenREFORM, under development (a dynamic computable general model). The aim with the model is to enable the fiscal and economic planning to support the green transition. The model is being developed by the independent governmental institution the DREAM group, and the project is primarily financed by the Danish Ministry of Finance, which also contributes to the model development and intends to implement and use the model when it is ready. The model is designed to assess the future economic and fiscal impacts of climate and environmental policies, and the climate and environmental impacts of economic policies. GreenREFORM describes the energy use and emission of pollutants in the energy and air emissions accounts produced by Statistics Denmark from all Danish businesses, households, and the public sector. The model also describes the effect on emissions from environmental taxes, subsidies, and other regulations. The model produces annual projections up to 2100, which aids medium-to-long-term fiscal and economic analysis. The projections enable an assessment of the effect of future economic developments on the climate and environment and whether these developments are consistent with climate and environmental targets. This functionality will enable Denmark to position climate and environmental policy centrally when preparing its medium-term fiscal framework. Overall financing compared to the needs The overall environmental financing for investments is estimated to reach 0.6-0.7% of GDP in the 2014-2020 period in the European Union, taking into account major EU funds and national financing. This ranged from 0.3% (Ireland) to 1.91% (Bulgaria), linked to the level of environmental challenges in the Member States. In the 2021-2027 period, the overall EU environmental investment needs are estimated to range between 0.9-1.5% of the projected GDP (2021-2027), suggesting a potential environmental financing gap of 0.6-0.8% of GDP at EU level, previous financing levels maintained (see Figure 46). Figure 46: Total environmental financing baseline (2014-2020) and estimated needs (2020 - 2030) in the EU27 (% of GDP) Denmark’s environmental financing for investments is estimated to have been 0.57% of GDP in 2014-2020, almost exclusively from national sources. From 2021-2027, the environmental investment needs of the country are estimated to be at least 0.72% of GDP (with partial information available at country level, excluding e.g. nature protection costs in the lack of a finalised PAF, water protection and ‘higher circularity needs’ for example related to 2022 Commission proposal on sustainable product policy and eco-design), suggesting an environmental financing gap of at least 0.15% of the GDP, likely to be higher when also accounting for needs currently estimated at EU level only (e.g. water protetion, circularity, biodiversity strategy etc.) to be addressed by mobilising additional financing for environmental implementation priorities. 2022 priority actions No priority actions were proposed for Denmark in the 2019 and none are proposed for 2022. It can be highlighted that, based on the data available, the share of private environmental financing in Denmark is high (over 80%) that can provide useful examples for other Member States on using more effectively the involvement of private financing.



6. Environmental governance Information, public participation and access to justice Citizens can more effectively protect the environment if they can rely on the three ‘pillars’ of the Aarhus Convention: (i) access to information; (ii) public participation in decision making; (iii) access to justice in environmental matters. It is of crucial importance to public authorities, the public and businesses that environmental information is shared efficiently and effectively . Public participation allows authorities to make decisions that take public concerns into account. Access to justice is a set of guarantees that allows citizens and NGOs to use national courts to protect the environment . It includes the right to bring legal challenges (‘legal standing’) . Environmental information This section focuses on Denmark’s implementation of the INSPIRE Directive. The aim of the INSPIRE (Infrastructure for Spatial Information in Europe) is to establish a European spatial data infrastructure to share environmental spatial information between public authorities across Europe, assist in policy-making across boundaries and facilitate public access to this information. Geographic information is needed for good governance at all levels and should be readily and transparently available. Denmark’s implementation of the INSPIRE Directive could be better. Slow progress has been made on data identification and documentation, and implementation levels are good. However, more efforts are needed to make data more widely accessible (see Table 4). Table 4: Country dashboard on the implementation of the INSPIRE Directive, 2016-2020 2016 2020 Legend Effective coordination and data sharing ■ Implementation of this provision is well advanced or (nearly) completed. Outstanding issues are minor and can be addressed easily. Percentage: >89% ■ Implementation of this provision has started and made some or substantial progress but is still not close to be complete. Percentage: 31–89% ■ Implementation of this provision is falling significantly behind. Serious efforts are necessary to close implementation gap. Percentage: <31% Ensure effective coordination ■ ■ Data sharing without obstacle ■ ■ INSPIRE performance indicators i. Conformity of metadata ■ ■ ii. Conformity of spatial data sets ■ ■ iii. Accessibility of spatial data sets through view and download services ■ ■ iv. Conformity of network services ■ ■ Denmark had a priority action in 2019 on the need to improve access to spatial data and services and make stronger links to the country INSPIRE portals, where some progress can be seen. Therefore no priority action is proposed in 2022. Public participation Planning authorities responsible for implementing Environmental Impact Assessment (EIA) may be at national, municipality, or local level, depending on the nature of the project. The planning authority in question must publish the hearing on its own website, and the process may be conducted using the national portal “Høringsportalen”. The long-te