COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019 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 2019: A Europe that protects its citizens and enhances their quality of life
Date: 2019-04-04
Institutions: Directorate-General for Environment, European Commission
Subjects: Denmark, EU environmental policy, application of EU law, climate change policy, environmental law, environmental protection, governance, green economy, public health, quality of the environment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.4.2019  SWD(2019) 134 final  COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019     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 2019:  A Europe that protects its citizens and enhances their quality of life   {COM(2019) 149 final} - {SWD(2019) 111 final} - {SWD(2019) 112 final} - {SWD(2019) 113 final} - {SWD(2019) 114 final} - {SWD(2019) 115 final} - {SWD(2019) 116 final} - {SWD(2019) 117 final} - {SWD(2019) 118 final} - {SWD(2019) 119 final} - {SWD(2019) 120 final} - {SWD(2019) 121 final} - {SWD(2019) 122 final} - {SWD(2019) 123 final} - {SWD(2019) 124 final} - {SWD(2019) 125 final} - {SWD(2019) 126 final} - {SWD(2019) 127 final} - {SWD(2019) 128 final} - {SWD(2019) 129 final} - {SWD(2019) 130 final} - {SWD(2019) 131 final} - {SWD(2019) 132 final} - {SWD(2019) 133 final} - {SWD(2019) 135 final} - {SWD(2019) 136 final} - {SWD(2019) 137 final} - {SWD(2019) 138 final} - {SWD(2019) 139 final}  
 
 
This  report  has  been  written  by  the  staff  of  the  Directorate-General  for  Environment,  European  Commission. 
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1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

3. 

2. 

TURNING  THE  EU  INTO  A  CIRCULAR,  RESOURCE-EFFICIENT,  GREEN  AND  COMPETITIVE  LOW-

EXECUTIVE SUMMARY ................................................................................................................................... 3 
PART I: THEMATIC AREAS .............................................................................................................................. 5 
1. 
CARBON ECONOMY ....................................................................................................................................... 5 
Measures towards a circular economy ...................................................................................................... 5 
Waste management ................................................................................................................................... 8 
Climate change ........................................................................................................................................... 9 
PROTECTING, CONSERVING AND ENHANCING NATURAL CAPITAL ................................................. 12 
Nature and biodiversity ............................................................................................................................ 12 
Maintaining and restoring ecosystems and their services ....................................................................... 13 
Estimating natural capital......................................................................................................................... 14 
Invasive alien species ............................................................................................................................... 15 
Soil protection .......................................................................................................................................... 15 
Marine protection .................................................................................................................................... 16 
ENSURING CITIZENS’ HEALTH AND QUALITY OF LIFE....................................................................... 18 
Air quality ................................................................................................................................................. 18 
Industrial emissions .................................................................................................................................. 19 
Noise......................................................................................................................................................... 20 
Water quality and management .............................................................................................................. 21 
Chemicals ................................................................................................................................................. 23 
Making cities more sustainable ................................................................................................................ 24 
PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ................................................................... 26 
4. 
INVESTMENTS .............................................................................................................................................. 26 
Green taxation and environmentally harmful subsidies .......................................................................... 26 
Green public procurement ....................................................................................................................... 27 
Environmental funding and investments ................................................................................................. 28 
STRENGTHENING ENVIRONMENTAL GOVERNANCE ........................................................................ 32 
Information, public participation and access to justice ........................................................................... 32 
Compliance assurance .............................................................................................................................. 33 
Effectiveness of environmental administrations ...................................................................................... 34 
International agreements......................................................................................................................... 35 
Sustainable development and the implementation of the UN SDGs ....................................................... 36 

GREEN  TAXATION,  GREEN  PUBLIC  PROCUREMENT,  ENVIRONMENTAL  FUNDING  AND 

5. 

2 

 
 
 
Environmental Implementation Report 2019 – Denmark 

Executive summary 

Denmark  and 
Review (EIR) 

the  Environmental 

Implementation 

In  the  2017  EIR,  the  main  challenges  identified  for  the 
implementation  of  EU  environmental  policy  and  law  in 
Denmark 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 
densely populated areas. 

in 

Since  the  2017  EIR,  Denmark  has  not  organised  an  EIR 
national  dialogue  that  would  have  made  it  possible  to 
address  the  above  challenges.  In  2017,  the  Commission 
launched  a  new  tool  to  promote  peer-to-peer  learning 
between  environmental  authorities.  The  tool  is  called 
‘Technical  Assistance  and 
TAIEX-EIR  P2P  (short  for 
Information  Exchange  –  Environmental 
Information 
Report  –  Peer-to-Peer). 
In  2018,  Denmark  has 
participated  in  several  peer-to-peer  events  organised 
through this tool. The events were organised to exchange 
knowledge  and  experience  on  waste  management, 
implementation  of  the  EU  Timber  Regulation,  and 
reducing emissions from domestic heating. 

Progress on meeting challenges since the 2017 EIR 

The  2019  EIR 
that  environmental  policy 
implementation in Denmark remains at a high standard.  

shows 

the  Nitrates  Directive.  The 

For  pressures  on  nature  from  intensive  agriculture,  the 
2019  EIR  shows  that  Denmark  is  changing  its  legislation 
implementing 
revised 
implementation  of  this  Directive 
legislation  moves 
towards  a  more  targeted  system.  Agricultural  pressures 
and  existing  water  quality  issues  mean  that  Denmark 
must  ensure that these changes are accompanied by: (i) 
clear  environmental  objectives  and  targets,  and  (ii) 
effective  enforcement  mechanisms.  These  objectives, 
targets  and  enforcement  mechanisms  must  ensure  the 
necessary  and  timely  reduction  in  nutrient  pollution  in 
Danish waters and in the Baltic Sea. Encouragingly, there 
have been recent reports of improvements in the status 
of species and habitats that were previously affected by 
nutrient pollution. 

For air quality, the emission of several air pollutants has 
decreased  significantly  in  Denmark  since  the  2017  EIR. 
Also  emissions  of  fine  particulate  matter  fell  between 
2000  and  2016.  Despite  these  emission  reductions, 
Denmark  must  make  additional  efforts  to  achieve  the 
emission reduction commitments for the period 2020 to 
2029  and  for  any  year  from  2030.  Although  in  Denmark 

3 

the  latest  data  is  encouraging  with  no  exceedences 
reported  in  2017,  air  quality  in  Denmark  continues  to 
give cause for concern, especially in certain urban areas, 
so much that the Commission has instituted infringement 
procedures  against  Denmark  among  other  Member 
States.  The  Danish  Government  launched  a  clean  air 
package in October 2018 to reduce air pollution in larger 
cities and phase-out  diesel and gasoline vehicles, and to 
meet the reduction targets under the NEC directive.  

On  waste  prevention,  Denmark  has  taken  appropriate 
steps to improve waste management and implement the 
current  European  waste  targets.  However,  this  limited 
progress  shows  that  more  effort  will  be  required  to 
ensure  compliance  with  the  recycling  targets  for  the 
post-2020 period. In particular, this will require action to 
incineration  (with  energy  recovery)  of 
reduce  the 
municipal waste. 

A  strong  driver  of  eco-innovation  in  Danish  exports  has 
been  green-energy  technology  and  services.  These 
exports  have  been  promoted  by  Denmark’s  strong 
export-financing  support.  The  government  also  provides 
other  forms  of  assistance  for  the  internationalisation  of 
innovation and business. 

Examples of good practice 

  On  urban  mobility,  private  vehicles  are  the  most 
frequently used mode of transport in Denmark, as is 
the case in most Member States. However, cycling is 
also  remarkably  popular,  accounting  for  more  than 
20 %  of  all  trips.  Public  transport  is  also  strong, 
providing transport to 13 % of Danish commuters. 

 

The percentage of SMEs that offer green products or 
services  is  significantly  higher  than  the  EU  average. 
In addition, the percentage of Danish companies that 
generate  a  majority  of  their  income  from  green 
products and services is greater than the EU average. 
There are two other factors that could help Denmark 
to  innovate  and  thrive  in  the  circular  economy:  the 
that  produce 
large  number  of 
advanced  green  products  and  services;  and  the 
country’s open cooperation culture. 

‘frontrunners’ 

liveable  urban  areas 
plays 

  Denmark  has  been  recognised  for  its  efforts  to 
in  which  green 
create 
infrastructure 
role. The 
an 
Copenhagen  municipality  has  adopted  a  policy  to 
make trees a greater priority in the city. In addition, 
the  2016  Nordic  Council  of  Ministers  gave  a  Nordic 
Built  Cities  Challenge  award 
in 
Copenhagen.  The  award  recognised  the  park’s 

to  a  park 

important 

 
Environmental Implementation Report 2019 – Denmark 

innovative  use  of 
manage rainwater from cloudbursts. 

‘blue-green 

infrastructure’  to 

  Denmark’s  consistent  culture  of  transparency  is  an 
in  environmental 

example  of  good  practice 
compliance assurance. 

4 

 
Environmental Implementation Report 2019 – Denmark 

Part I: Thematic areas 

1. 

Turning the EU into a circular, resource-efficient, green and 

competitive low-carbon economy 

Measures towards a circular economy 

The  Circular  Economy  Action  Plan  emphasises  the  need 
to  move  towards  a  life-cycle-driven  ‘circular’  economy, 
reusing  resources  as  much  as  possible  and  bringing 
residual  waste  close  to  zero.  This  can  be  facilitated  by 
developing  and  providing  access  to  innovative  financial 
instruments and funding for eco-innovation. 

Following  the  adoption  of  the  Circular  Economy  Action 
Plan in 2015 and the setting up of a related stakeholder 
platform  in  2017,  the  European  Commission  adopted  a 
new  package  of  deliverables  in  January  20181.  This 
included  additional  initiatives  such  as:  (i)  an  EU  strategy 
for plastics; (ii) a  Communication on how to address the 
interplay  between  chemical,  product  and  waste 
legislation; (iii) a report on critical raw materials; and (iv) 
a  framework  to  monitor  progress  towards  a  circular 
economy2. 

The circular (secondary) use of material in Denmark was 
8.2 %  in  2016  (below  the  EU-28  average  of  11.7 %).  The 
number  of  people  in  Denmark  employed  in  the  circular 
economy is slightly less than the EU-28 average (1.1.36 % 
of  total  employment  in  2016  compared  to  an  EU-28 
average of 1.73 %). 
In  the  2017  Special  Eurobarometer  4683  on  attitudes  of 
EU citizens towards the environment, 88 % of Danes said 
they  were  concerned  about  the  effects  of  plastic 
products on the environment (EU-28 average 87 %). 87 % 
said  they  were  worried  about  the  impact  of  chemicals 
(the  EU-28  average  was  90 %).  There  appears  to  be 
strong  support  in  Danish  society  for  circular  economy 
initiatives and environmental protection actions. 
resource  productivity4 

(how 
In  2017,  Denmark’s 
efficiently  the  economy  uses  material  resources  to 
produce  wealth)  in  value  produced  per  kg  of  resources 
used  was  1.98  EUR/kg.  This  was  just  below  the  EU 
average  of  2.04  EUR/kg  (Figure  1),  with  nine  countries 

1 European Commission, 2018 Circular Economy Package. 
2 COM(2018) 029. 
3 European Commission, Special 468 Eurobarometer, "Attitudes of 
European citizens towards the environment", 2017. 
4 Resource productivity is defined as the ratio between gross domestic 
product (GDP) and domestic material consumption (DMC). 

showing better results than Denmark. 
Figure 1: Resource productivity 2010-20175  

in 

has 

The 

2017. 

proposed 

The Danish Advisory Board for Circular Economy was set 
up 
27 
Board 
recommendations  to  promote  the  circular  economy  in 
Denmark.  In  September  2018,  the  Danish  government 
followed  up  on  the  recommendations  with  its  Strategy 
for circular economy, which was followed by a supporting 
political  agreement  in  October  2018.  The  strategy  and 
the  political  agreement  include  16  initiatives  funded  by 
DKK 116 million (approx. EUR 15.7 million) in 2019-22. 

The  Danish  government  has  started  to  include  the 
circular economy as a topic for discussion in international 
trips  made  by  government  ministers.  For  example,  the 
circular  economy  was  a  topic  addressed  by  Prime 
Minister Lars Løkke Rasmussen in his visits to  China  and 
Indonesia in 2017. 

In  2017,  the  Danish  government  announced  that 
Denmark  would  work  on  a  new  national  action  plan  on 
plastics  as  a  follow-up  to  the  2018  EU  strategy  for 
plastics.  Work  on  this  action  plan  was  ongoing  end  of 
2018. 

According to a recent survey of Danish companies on the 
circular  economy6,  88 %  of  Danish  companies  had 
positive  views  of  the  circular  economy.  The  survey 
showed  that  Danish  companies  believed  their  lack  of 

5 Eurostat, Resource productivity. 
6 Danish EPA, Miljøstyrelsen, Danskerne omfavner cirkulær økonomi, 
2017. 

5 

 
 
 
                                                                 
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

example,  the  percentage  of  companies  that  invested  in 
energy  saving  fell  16 %  to  55 %  of  all  companies.  This 
trend  will  likely  continue,  as  50 %  of  Danish  companies 
do  not  plan  to  make  further  investments  in  resource 
efficiency in the next 2 years — one of the highest rates 
in the EU.  
Figure 2: Environmental performance of SMEs10  

relevant  knowledge  was  the  main  barrier  preventing 
them  from  getting  more 
in  the  circular 
economy. 30 % of respondents to the  survey found that 
advice  and  consulting  services  were  crucial  in  helping 
them to engage in the circular economy. 

involved 

the  private 

in  a  country  can  give  a 

The number of EU Ecolabel products and EMAS licensed 
organisations7 
rough 
measurement  of  this  transition.  These  two  indicators 
show  to  what  extent  the  circular  economy  transition  is 
sector  and  other  national 
engaging 
stakeholders.  These  two 
indicators  also  show  the 
commitment of public authorities to policies that support 
the  circular  economy.  As  of  September  2018,  Denmark 
had  1166  products  and  56  licences  registered  in  the  EU 
Ecolabel  scheme  out  of  a  total  of  71  707  products  and 
2167 licences in the EU. This shows there has been a high 
take-up  of  these  schemes  in  Denmark8.  Moreover,  28 
organisations  from  Denmark  were  registered  as  of  May 
2018 in EMAS.  

SMEs and resource efficiency 

Danish SMEs  continue to score above the EU average in 
the environmental aspects of the small business act10, as 
shown  in  Figure  2.  The  share  of  Danish  SMEs  that 
recently took resource-efficiency measures and the share 
that  have  benefitted  from  public  support  measures  for 
production  of  green  products  are  slightly  below  the  EU 
average. 

The  percentage  of  SMEs  that  offer  green  products  or 
services  is  significantly  higher  than  the  EU  average.  A 
greater  percentage  of  Danish  companies  than  the  EU 
average generate a majority of their turnover from green 
products  and  services.  Denmark  has  been  a  strong 
performer  in  environmental  policies  for  many  years  and 
has well-established support programmes for innovators.  

The  latest  Eurobarometer  on  ‘SMEs,  resource  efficiency 
and green markets’9 asked companies about both recent 
resource-efficiency actions they had taken and additional 
resource-efficiency  actions  they  planned  to  take  in  the 
next two years. The Eurobarometer then compared these 
responses with responses given to the same questions in 
2015.  Only  15 %  of  surveyed  Danish  companies  had  not 
undertaken an investment in resource efficiency between 
2015  and  2017.  However,  there  was  a  decline  in  the 
investing.  For 
percentage  of  companies  that  were 

7 EMAS is the European Commission’s Eco-Management and Audit 
Scheme – a programme to encourage organisations to behave in a more 
environmentally sustainable way, Eco-Management and Audit Scheme. 
8 European Commission, Ecolabel Facts and Figures. 
9 Flash Eurobarometer 456 ‘SME, resource efficiency and green 
markets’ January 2018. The 8 dimension were Save energy; Minimise 
waste; Save materials; Save Water; Recycle by reusing material 
internally; Design products easier to maintain, repair or reuse; Use 
renewable energy; Sell scrap materials to another company. 

Only 27 % of Danish companies (against an EU average of 
22 %,  with  a  range  between  3 %  and  38 %)  relied  on 
‘external’  support  (help  from  outside  their  companies, 
whether  public  or  private)  in  their  efforts  to  be  more 
resource efficient. 64 % of Danish companies took advice 
from private consultants, the highest rate across the EU, 
while  54 %  of  Danish  companies  took  advice  from 
business  associations.  Public  administration  assistance 
played less of a role in Danish SMEs (used by only 19 % of 
companies),  and  public-sector  grants  played  a  marginal 
role (used by only 7 % of companies). 

30 % of Danish companies said that external consultancy 
on  resource  efficiency  was  helpful.  28 %  of  companies 
said  that  grants  and  subsidies  were  helpful.  Danish 
companies generally found other forms of support to be 
less  useful  than  the  EU  average,  with  the  exception  of 
reference databases (which were rated as helpful by 17 % 
of Danish companies against an EU average of 13 %) and 
self-assessment  tools  (which  were  rated  as  helpful  by 
19 %  of  Danish  companies  against  an  EU  average  of 
15 %). 

10 European Commission, 2018 SBA fact sheet - Denmark, p. 16. 

6 

                                                                 
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

Danish  SMEs  have  an  advanced  understanding  of 
resource efficiency, but their ambition to invest in it must 
be  maintained.  The  large  number  of  frontrunners  that 
produce  green  products  and  services,  and  Denmark’s 
open  cooperation  culture  could  give  Danish  SMEs  a 
strategic  advantage  in  producing  innovations  for  the 
circular economy. 

Danish  companies  find  their  high-performing  consulting 
sector to be very helpful, and these consulting companies 
should find additional markets across the EU. 

Eco-innovation 

In  2018,  Denmark  ranked  second  on  the  European 
Innovation  Scoreboard  2018,  and  was  the  18th-fastest 
growing  innovator  (only  0.7 %  increase  since  2010)11. 
However,  the  country  ranked  only  fifth  in  the  overall 
2017  EU  Eco-innovation  index  (see  Figure  3).  This  is  a 
slightly  lower  ranking  compared  to  the  fourth  position 
Denmark  occupied  in  2016  and  the  third  position  it 
occupied  in  2015.  Overall,  since  the  first  Eco-innovation 
Scoreboard  in  2010,  Denmark  has  never  been  ranked 
below fifth place and is considered to be among the lead 
countries in the EU. 

Figure 3: 2017 Eco-innovation index (EU=100)12 

However,  since  2010,  Denmark  has  seen 
its  eco-
innovation performance decline, from 149 points to a low 
of 120 in 2017 (see Figure 4). 

Figure 4: Denmark’s eco-innovation performance 

and 

Technology  and  services  for  green  energy  has  been  a 
in  Danish  exports. 
strong  driver  of  eco-innovation 
Denmark  has  a  strong  support  framework  of  export 
financing 
companies 
internationalise  their  innovations  and  other  commercial 
activities.  In  2016  Danish  companies  exported  energy 
technology  for  DKK  75.6  billion  and  services  for  DKK  8.2 
billion  (i.e.  respectively  around  EUR  10.13  and  1.09 
billion)13. 

assistance 

help 

to 

Overall, Denmark has a strong science base and a strong 
foundation  for  business 
innovation.  Denmark’s  R&D 
intensity (a measure of the percentage of  GDP spent  on 
R&D)  has  been  at  around  the  EU 2020  target  of  3 %  of 
GDP since 2009. In 2016, it reached 2.9 % of GDP, and in 
that year Denmark’s R&D intensity was the fourth highest 
in  the  EU  (Eurostat,  2018b).  Denmark  also  has  the 
second-highest  public  R&D  intensity,  following  a  small 
contraction  in  2016,  and  the  fourth  highest  Business 
enterprise  R&D  (BERD)  intensity  in  Europe.  SMEs  have 
good access to investment  and funding, both public and 
private.  However,  there  is  room  to  further  streamline 
public funding programmes for Danish SMEs. The private 
sector  accounts  roughly  for  2/3  of  total  public  R&D 
intensity,  and  more  initiatives  have  been  launched  to 
support start-ups and SMEs. 

Another area that has improved is cooperation  between 
universities and businesses.  This cooperation has sought 
to  ensure  that  Denmark’s  high  public  investment  in 
university-based  R&D 
ground-breaking 
leads 
innovation,  productivity,  employment  and  economic 
growth.  Denmark  already  sought  to  address  this  issue 
with  its  innovation  strategy,  entitled  ‘Denmark  —  a 
nation of solutions (2012-2020)’. The Danish government 
continues to work on this issue14. 

to 

is 

the  Danish 

Ecoinnovation.dk 
eco-innovation 
programme15.  It  began  in  2007.  Its  objective  is  to  help 
Danish  companies  develop,  test  and  demonstrate  new 
to  promote 
environmental 

technology. 

seeks 

It 

11 European Commission, European innovation Scoreboard 2018. 
12 European Commission, Eco-innovation Observatory: Eco-Innovation 
scoreboard 2018. 

13 Danish Ministry of Energy, Utilities and Climate, 2017. 
14 Denmark - Ready to seize future opportunities. 
15 In Danish: MUDP — Miljøteknologisk Udviklings- og 
Demonstrationsprojekt. 

7 

 
 
                                                                 
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

technology  that:  (i)  delivers  better  and  more  cost-
effective  environmental  solutions,  and  (ii)  has  the 
potential  to  contribute  to  increased  exports  and  more 
green jobs in Denmark. 

Denmark  has  a  number  of  established 
financing 
instruments  to  promote  eco-innovation.  Some  of  these 
instruments are described in more detail below. 

  The 

  The  Danish  Green 

Investment  Fund 

Innovation  Network 

(Danmarks 
Grønne  Investeringsfond)  is  an  independent  state 
loan  fund.  Its  purpose  is  to  co-finance  economically 
viable projects that support sustainable development 
in  Denmark.  The  fund  seeks  to  bridge  the  gap 
between traditional bank financing and equity capital. 
Environmental 
Technology  (Inno-MT)  is  a  partnership  that  supports 
projects  dealing  with  waste,  air,  water  and  soil.  A 
involve  any  form  of  technological 
project  may 
development, 
similar 
environmental  technology.  Funding  of  between  DKK 
100 000 (EUR 13 400) and DKK 400 000 (EUR 53 600) 
is  available  for  each  project.  This  money  can  cover 
costs  for  advice  and  technical  assistance  from  the 
network’s knowledge partners. 

innovation 

service 

for 

or 

It  provides  funding  for 

  Technology  Demands  is  a  new  fund  set  up  by  Inno-
MT. 
innovation  projects 
involving  universities  and  SMEs.  Technology  Demand 
is  aimed  at  companies  that  either:  (i)  possess 
technological knowledge that is in high demand, or (ii) 
face  environmental  challenges.  Technology  Demand 
gives funding of up to DKK 150 000 (EUR 20 100) per 
project.  This 
for  advice  and 
technological assistance 16. 

funding  pays 

 

  The 

Technology 

Programme 

Development 

and 
Energy 
Demonstration 
(Energiteknologisk 
udvikling og demonstration) is a public grant scheme. 
The  scheme  supports  new  energy  technologies  that 
can help meet Denmark’s energy and climate goals.  
Innovation  Fund  Denmark  (Innovationsfonden)  was 
set  up  in  2014.  The  fund  invests  in  new  knowledge 
and  early-stage  technology,  when  other  funding 
institutions  might  not  be  convinced  of  its  potential. 
Innovation Fund Denmark does not take any stake in 
the  project  nor  does  it  request  repayment  of  its 
grants. 

  The  Danish  Growth  Fund  (Vækstfonden)  is  a  state 
investment  fund  that  contributes  to  the  creation  of 
new  companies  by  providing  capital  and  expertise. 
The  Danish  Growth  Fund  invests  equity,  and  also 
provides 
in 
collaboration  with  private  partners  and  Danish 
financial  institutions.  Since  1992,  the  Danish  Growth 
Fund  and  private  investors  have  co-financed  growth 

loans  and  guarantees 

for  SMEs 

16 Innovation Network for Environmental Technologies. 

8 

in  more  than  6 600  Danish  companies  with  a  total 
commitment  of  more  than  DKK  20  billion  (EUR  2.7 
billion) (www.vf.dk) 

  The FORSK2025 (RESEARCH2025) catalogue identifies 
promising  Danish  research  areas  that  could  be 
sources  of  growth,  employment  and  welfare  in  the 
future.  Its  search  criteria  are  based  on  a  number  of 
significant  challenges  facing  society  in  general  and 
Denmark in particular. 

Waste management 

Turning waste into a resource is supported by: 
(i)  fully 
legislation,  which 
implementing  EU  waste 
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; and  
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
and  phasing  out  landfilling  of  recyclable  or  recoverable 
waste. 

This  section  focuses  on  management  of  municipal 
waste17  for  which  EU  law  sets  mandatory  recycling 
targets18. 

In  2017,  the  amount  of  municipal  waste  generated  in 
Denmark was the highest in the EU (781 kg per year per 
inhabitant  compared  to  the  EU  average  of  487 kg  per 
year  per  inhabitant).  However,  this  high  figure  is  partly 
linked  to  a  methodological  issue  about  how  to  define 
municipal waste. 

in 
Figure  5  depicts  municipal  waste  by  treatment 
Denmark in kg per capita. It shows that levels of recycling 
is  increasing  and  incineration  is  decreasing,  although 
levels remained stable in 2017, with landfill continuously 
at a low level.  

Denmark  has  a  high  percentage  of  incinerated  waste  in 
the  EU  (52.8 %)  (EU  average  is  around  28 %),  but  in 
Denmark  incineration  has  to  include  energy  recovery, 
which is not the case in a number of other EU countries. 
46 %  of  municipal  waste  was  recycled  in  2017,  which  is 
the same figure than the EU average (46 %). Denmark has 
one  of  the  lowest  proportions  of  landfilled  municipal 
waste in the EU (1 %) (EU average is around 24 %). 

Figure  6  shows  that  Denmark  almost  achieved 

its 

17 Municipal waste consists of mixed waste and separately collected 
waste from households and from other sources, where such waste is 
similar in nature and composition to waste from households. This is 
without prejudice to the allocation of responsibilities for waste 
management between public and private sectors. 
18 See Article 11.2 of Directive 2008/98/EC. This Directive was amended 
in 2018 by Directive (EU) 2018/851, and more ambitious recycling 
targets were introduced for the period up to 2035. 

                                                                 
                                                                 
Environmental Implementation Report 2019 – Denmark 

recycling rate to achieve the EU 2020 target of 50 %19. 

Figure  5:  Municipal  waste  by  treatment  in  Denmark 
2010-201720 

targets for the post-2020 period22. This will require action 
to reduce incineration with energy recovery of municipal 
waste in particular. 

Investments will be needed higher in the waste hierarchy 
as  well  as  for  recycling  in  order  to  meet  the  more 
ambitious post 2020 targets and to promote the circular 
economy.  Moreover,  projects 
improving  waste  data 
reporting and extended producer responsibility would be 
crucial,  as  well  as  capacity  building  projects 
for 
municipalities 
necessary  waste 
realise 
management  reforms  in  the  country.  The  investments 
in  waste  prevention, 
should  also  prioritise  projects 
including 
raising. 
re-use  projects  and  awareness 
Investments  should  not  be  directed  to  the  treatment  of 
residual waste in incinerators with energy recovery. 

the 

to 

Figure 6: Recycling rate of municipal waste 2010-201721 

Denmark  has  taken  appropriate  steps  to  improve  waste 
management and implement the current European waste 
targets.  It  remains  one  of  the  countries  in  the  EU  that 
produces more municipal waste per capita, and much of 
this  waste 
recovery. 
Denmark’s  waste  management  plan  aims  to  shift  away 
from  incineration  with  energy  recovery  towards  more 
recycling.  However,  it  is  clear  that  Denmark  must  make 
more  effort  to  ensure  compliance  with  the  recycling 

incinerated  with  energy 

is 

2019 priority actions 

 

Introduce new policy instruments, including economic 
instruments.  These  instruments  should:  (i)  promote 
waste prevention, (ii) make waste reuse and recycling 
more economically attractive. 

  Shift  reusable  and  recyclable  waste  away  from 

incineration with energy recovery. 

Climate change 

The EU has committed to undertaking ambitious climate 
action internationally as well as in the EU, having ratified 
the Paris Climate Agreement  on 5 October 2016. The EU 
targets are to reduce greenhouse gas (GHG) emissions by 
20 % by 2020 and by at least 40 % by 2030, compared to 
1990.  As  a  long-term  target,  the  EU  aims  to  reduce  its 
emissions  by  80-95 %  by  2050,  as  part  of  the  efforts 
required by developed countries as a group. Adapting to 
the adverse effects of climate change is vital to alleviate 
its  already  visible  effects  and  improve  preparedness  for 
and resilience to future impacts. 

For emissions not covered by the EU ETS, Member States 
have  binding  national  targets  under  the  effort  sharing 
legislation.  Denmark  has  had  lower  emissions  than  its 
annual  targets  in  each  of  the  years  from  2013  to  2017. 
For  2020,  Denmark’s  national  target  under  this  Decision 
is to reduce emissions by 20 % compared to 2005, and for 
2030 it is to reduce emissions by 39 % compared to 2005. 

The  current  energy  plan  ends  in  2020  and  in  June  2018 
the  government  and  the  Parliament  signed  an  energy 
agreement  for  the  period  after  2020.  Funding  has  been 
agreed  that  sets  a  course  towards  a  share  of  renewable 

19 Member States may choose a different method than the one used by 
ESTAT (and referred to in this report) to calculate their recycling rates 
and track compliance with the 2020 target of 50 % recycling of 
municipal waste. 
20 Eurostat, Municipal waste by waste operations. 
21 Eurostat, Recycling rate of municipal waste. 

22 Directive (EU) 2018/851, Directive (EU) 2018/852, Directive (EU) 
2018/850 and Directive (EU) 2018/849 amend the previous waste 
legislation and set more ambitious recycling targets for the period up to 
2035. These targets will be taken into consideration to assess progress 
in future Environmental Implementation Reports. 

9 

 
 
                                                                 
                                                                 
Environmental Implementation Report 2019 – Denmark 

energy of approximately 55% by 2030. The plan will also 
phase out coal-based power and give Denmark a share of 
renewable  energy 
in  electricity  above  100%  of 
consumption, while ensuring that at least 90% of district 
heating  consumption  is  based  on  energy  sources  other 
than coal, oil or gas by 2030. In accordance with the Paris 
Agreement,  Denmark  will  work  towards  net  zero 
emissions in the EU and Denmark by 2050 at the latest.  

In  October  2018,  the  Government  presented  a  climate 
and  air  proposal  “Together  for  a  greener  future”  to 
ensure that Denmark  continues to enjoy access to clean 
air and a stable climate.  

Figure  7:  Change  in  total  GHG  emissions  1990-2017 
(1990=100 %)23. 

2012 to 2015. 

The  F-gas  Regulation  requires  Member  States  to  run 
training and certification programmes, introduce rules for 
penalties  and  notify  these  measures  to  the  Commission 
by 2017. Denmark has notified both measures.  

The  accounting  of  GHG  emissions  and  removals  from 
forests and agriculture is governed by the Kyoto Protocol. 
A  preliminary  accounting  exercise  for  the  period  2013-
2016 shows that Denmark had net credits of, on average, 
-2.8 Mt CO2-eq, which corresponds to 2.4% of the EU-28 
accounted sink of -115.7 Mt CO2-eq.  

The  EU  Strategy  on  adaptation  to  climate  change, 
adopted  in  2013,  aims  to  make  Europe  more  climate-
resilient, by promoting action by Member States, better-
informed  decision  making,  and  promoting  adaptation  in 
key vulnerable sectors. By adopting a coherent approach 
and  providing  for  improved  coordination,  it  seeks  to 
enhance the preparedness and capacity of all governance 
levels to respond to the impacts of climate change.  

Figure 8: Targets and emissions for Denmark under the 
Effort Sharing Decision and Effort Sharing Regulation24. 

The proposal includes 38 concrete initiatives to spur the 
green transition in Denmark towards 2030. These include 
a  stop on the sale of new petrol and diesel cars in 2030 
and plug-in-hybrid cars in 2035 – and other initiatives for 
cleaner  transport  in  cities  and  the  countryside,  a  more 
efficient and modern agriculture, more environmentally-
friendly  shipping,  and  a  green  transition  in  housing  and 
industry. 

The  draft  national  energy  and  climate  plan,  which  is 
developed  in  the  context  of  the  Energy  Union  initiative, 
builds on the energy agreement  and the climate and air 
proposal. 

Transport  emissions  in  Denmark  increased  by  2 %  from 

23 Annual European Union greenhouse gas inventory 1990–2016 (EEA 
greenhouse gas data viewer). Proxy GHG emission estimates for 
2017Approximated EU greenhouse gas inventory 2017 (European 
Environment Agency). Member States national projections, reviewed by 
the European Environment Agency. 

The  Danish  national  adaptation  strategy  was  adopted  in 
2008.  It  identifies  14  priority  sectors:  construction  and 
housing,  coasts  and  ports,  transport,  water,  agriculture, 
forestry,  fisheries,  energy,  tourism,  nature,  health, 
emergency preparedness, insurance and spatial planning. 
An action plan for a climate-proof Denmark was launched 
in  2012,  based  on  the  belief  that  a  responsible  climate 
policy  must 
long-term 
actions. So far, Denmark does not appear to have set up 

involve  both  short-term  and 

24 Proxy GHG emission estimates for 2017Approximated EU greenhouse 
gas inventory 2017 (European Environment Agency). Member States 
national projections, reviewed by the European Environment Agency. 

10 

 
                                                                 
 
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

an  overall  monitoring  and  evaluation  mechanism  for 
climate-change adaptation. Nor does Denmark appear to 
have  produced  clear  reports  detailing  its  progress  on 
adaptation in different sectors. 

Figure  9:  GHG  emissions  by  sector  (Mt.  CO2-eq.) 
(historical data 1990-2016; projections 2017-2030)25.  

The  total  revenue  from  the  auctioning  of  emission 
allowances under the EU ETS in the years 2013-2017 was 
EUR 301  million.  Denmark  does  not  earmark  auctioning 
revenues  for  specific  uses.  On  average,  100 %  of  the 
auctioning  revenues  is  reported  to  have  been  spent  on 
climate and energy policies.  

2019 priority action 

In this report, no priority actions have been included on 
climate action, as the Commission will first need to assess 
the  draft  national  energy  and  climate  plans  which  the 
Member  States  needed  to  send  by  end  of  2018.  These 
plans  should  increase  the  consistency  between  energy 
and climate policies and could therefore become a good 
example  of  how  to  link  sector-specific  policies  on  other 
interlinked  themes  such  as  agriculture-nature-water  and 
transport-air-health.  

25 Annual European Union greenhouse gas inventory 1990–2016 (EEA 
greenhouse gas data viewer). Proxy GHG emission estimates for 2017. 
Approximated EU greenhouse gas inventory 2017 (European 
Environment Agency). Member States national projections, reviewed by 
the European Environment Agency. 

11 

 
                                                                 
Environmental Implementation Report 2019 – Denmark 

2. 

Protecting, conserving and enhancing natural capital 

Nature and biodiversity 

in  the  EU  by  2020. 

The  EU  biodiversity  strategy  aims  to  halt  the  loss  of 
biodiversity 
full 
implementation  of  the  Birds  and  Habitats  Directives  to 
achieve  favourable  conservation  status  of  protected 
species and habitats. It also requires that the agricultural 
improve 
and  forest  sectors  help  to  maintain  and 
biodiversity. 

It  requires 

Biodiversity strategy 

Denmark’s  national  biodiversity  strategy  is  entitled  ‘The 
Danish Nature Policy  — Our  Shared Nature’. Adopted in 
2014, it contains a long-term vision to 2050 and serves as 
Denmark’s  revised  national  biodiversity  strategy  and 
action plan. Since 2016, it has been under revision by the 
Danish government. 

Setting up a coherent network of Natura 2000 sites 

On  the  basis  of  the  latest  update  on  the  assessment  of 
The  Birds  and  Habitats  directives,  Denmark’s  terrestrial 
Natura  2000  network  under  the  Birds  and  Habitats 
Directives is now considered to be complete. 

The  Danish  government  has  initiated  a  procedure  to 
adjust the boundaries of the sites within its Natura 2000 
network.  This  procedure  will  be  finished  by  the  end  of 
2018.  The  Commission  will  then  carry  out  a  detailed 
analysis of the proposed changes. 

In early 2016, 8.3 % of the Danish national territory was 
covered  by  Natura  2000  sites  (the  EU  average  was 
18.1 %).  Birds  Directive  special  protection  areas  (SPAs) 
covered 6.0 % (EU average 12.3 %) and Habitats Directive 
sites  of  community  importance  (SCIs)  covered  7.4 %  (EU 
average  13.8 %).  Furthermore,  Denmark  has  designated 
substantial marine areas, covering around 17 % of Danish 
waters.  Altogether,  there  are  364 Natura  2000  sites  in 
Denmark 
(113  SPAs  and  261  Special  Areas  of 
Conservation), although many of these overlap with each 
other. 

Designating Natura 2000 sites and setting conservation 
objectives and measures 

Based  on  an  assessment  of  the  sufficiency  of  the  SCI 
network26  for  Annex  II  species  and  Annex  I  habitats 

26 For each Member State, the Commission assesses whether the 
species and habitat types on Annexes I and II of the Habitats Directive, 
are sufficiently represented by the sites designated to date. This is 

occurring  in  Denmark,  the  Natura  2000  network  in 
Denmark is almost complete and close to complete in the 
Atlantic  and  Continental  terrestrial  region,  the  Marine 
Atlantic region and the Baltic region. 

All  these  sites  have  been  designated  as  special  areas  of 
conservation 
and 
measures have been drawn up for each of these sites. 

(SAC).  Conservation  objectives 

Denmark  is  an  agricultural  country,  with  approximately 
two thirds of the land area under cultivation, though this 
has  been  declining  steadily  for  many  years.  The  area  of 
open natural habitat has also declined considerably over 
the  past  century,  but  is  now  relatively  stable  at  around 
10 %  of  Denmark’s 
territory.  The  Danish  marine 
environment is of great importance: its relatively shallow 
waters  contain  marine  habitat  types  that  sustain 
internationally significant numbers of waterfowl. 

27 %  of  Denmark’s  plant  and  animal  species  that  have 
been  studied  or  assessed  are  ‘red-listed’27.  54 %  of  red-
listed species are associated with forest habitats. Threats 
facing  these  protected  species  and  habitats  include 
fragmentation of populations, deteriorating habitats and 
climate change. Intensive agriculture, including the use of 
impact 
pesticides 
biodiversity,  the  aquatic  environment,  and  drinking 
water.  The  nitrogen  load  has  decreased  in  recent  years. 
Although the use of pesticides has been increasing since 
2014, pesticides  with a  higher impact on health and the 
environment have been substituted for pesticides with a 
lower impact. 

and  nutrients, 

continues 

to 

The  2017  EIR  referred  to  the  latest  report  on  the 
conservation  status  of  habitats  and  species.  New  data 
will be available for the next EIR. 

One  especially  alarming  fact  is  that  all  forest  habitat 
assessments  are  unfavourable.  Most  of  Denmark’s 
grassland,  bog,  mire  and  coastal  habitat  types  also  have 
unfavourable  status.  Denmark  is  one  of  the  countries  in 
the  EU  that  reports  the  most  habitat  assessments  with 
unfavourable  status.  Agriculture  and  pollution  are  the 
most frequently reported pressures of high importance in 

expressed as a percentage of species and habitats for which further 
areas need to be designated in order to complete the network in that 
country. A scientific reserve is given when further research is needed to 
identify the most appropriate sites to be added for a species or habitat. 
The current data, which were assessed in 2014-2015, reflect the 
situation up until December 2013. 
27 The IUCN Red List is the world’s most comprehensive inventory of the 
global conservation status of biological species. It is set upon precise 
criteria to evaluate the extinction risk of thousands of species. 

12 

 
 
                                                                 
 
                                                                                                        
Environmental Implementation Report 2019 – Denmark 

Denmark. The structures and functions of all forest types 
are reported to be in highly unfavourable status. The high 
levels of airborne deposition of nitrogen are indicated as 
a threat. 

Marine  habitats  in  Denmark  are  still  being  affected  by 
nutrients  supplied 
from 
atmospheric  deposition.  However,  in  recent  years  there 
have been good efforts to limit emissions. 

from  surface  water  and 

Species assessments are generally more favourable than 
habitat  assessments  in  Denmark.  34 %  of  species  (other 
than  birds)  have  favourable  status  (against  an  EU-27 
average  of  23 %).  13 %  of  species  other  than  birds  are 
assessed  as  having  unfavourable-inadequate  status 
(against  an  EU-27  average  of  42 %).  However  28 %  of 
species  other  than  birds  have  unfavourable-bad  status 
(against an EU-27 average of 18 %). 

The  Danish  government  has  informed  the  Commission 
that  national  initiatives  planned  in  the  country’s  Nature 
Package (Naturpakken) include an additional 13 300 ha of 
high-nature-value  forest  in  the  national  forests  (owned 
by  the  government)  and  at  least  900  additional  ha  of 
high-nature-value  privately  owned 
forests.  National 
funding  for  2016-2021  is  DKK  87.9  million  and  DKK  20 
million  annually  from  2021  (not  including  EU-funding). 
The overall financial framework for the Natura 2000 sites 
for  the  management  planning  period  2016-2021  was 
decided  with  the  political  agreement  on  the  Food  and 
Agricultural Package with c.  1.8 billion DKK allocated for 
Natura  2000,  mainly  via 
the  Rural  Development 
Programme.  The  Government  has  also  pledged  to 
contribute DKK 48 million (c. EUR 6.5 million) to two new 
LIFE projects in Denmark, co-financed by the EU. 

Progress 
restoring 
in  maintaining  or 
conservation status of species and habitats 

favourable 

Considering that Member States report every 6 years on 
the  progress  made  under  both  directives,  no  new 
information  is  available  on  the  state  of  natural  habitats 
and  species,  or  on  progress  made  in  improving  the 
conservation  status  of  species  and  habitats  in  Denmark, 
as compared to the 2017 EIR. 

Overall,  it  is  acknowledged  that  improvements  in  the 
status  of  species  and  habitats  have  recently  been 
reported in Denmark. 

2019 priority actions 

  Make  further  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  the  pressures 
from agriculture. 

  Put  in  place  clearly  defined  conservation  objectives, 
and  the  necessary  conservation  measures  for  the 
sites.  Provide  adequate  resources  so  that  they  may 
meet  their  objective  of  maintaining  or  restoring 
species  and  habitats  of  community  interest  to  a 
favourable  conservation  status  across  their  natural 
range. 

Maintaining and restoring ecosystems and 
their services 

The EU biodiversity strategy aims to maintain and restore 
ecosystems  and  their  services  by 
including  green 
infrastructure  in  spatial  planning  and  restoring  at  least 
15 %  of  degraded  ecosystems  by  2020.  The  EU  green 
infrastructure  strategy  promotes  the  incorporation  of 
green infrastructure into related plans and programmes. 

The EU has provided guidance on the further deployment 
of  green  and  blue  infrastructure  in  Denmark28  and  a 
country page on the Biodiversity Information System for 
Europe  (BISE)29.  This  information  will  also  contribute  to 
the  final  evaluation  of  the  EU  Biodiversity  Strategy  to 
2020. 

In  Denmark,  green  infrastructure  is  addressed  in  several 
national  and  regional  documents  that  deal  with  spatial 
planning.  Green  infrastructure  is  also  referred  to  in 
legislation  dealing  with  nature  protection,  forestry, 
national parks and land distribution. 

liveable  urban  areas 

Denmark has been recognised and awarded for its efforts 
in  which  green 
to  create 
infrastructure  plays  an  important  role. The  Copenhagen 
municipality has adopted a policy to make trees a greater 
priority  in  the  city  between  2016  and  2025.  In  addition, 
the 2016 Nordic Council of Ministers gave a Nordic Built 
Cities  Challenge  award  to  a  park  in  Copenhagen.  The 
award  recognised  the  park’s  innovative  use  of  ‘blue-
green 
from 
cloudbursts in the Hans Tavsens Park in Copenhagen. 

infrastructure’ 

to  manage 

rainwater 

28 The recommendations of the green infrastructure strategy review 
report and the EU Guidance on a strategic framework for further 
supporting the deployment of EU-level green and blue infrastructure. 
29 Biodiversity Information System for Europe. 

13 

 
                                                                 
Environmental Implementation Report 2019 – Denmark 

‘green  map’  of 
To  help  municipalities  develop  a 
Denmark30  and  improve  land-use  planning,  the  Danish 
Environmental  Protection  Agency  developed  a  new 
digital  mapping  service  of  biodiversity 
in  Denmark 
information 
(‘biodiversitetskort’).  This  map  provides 
about  the  distribution  of  threatened  and  vulnerable 
species. It also provides an overview of high-value natural 
areas. It  is part  of a  suite of  mapping services known as 
the Nature Map (‘naturkort’). 

The  Danish  government  agreed  on  a  package  of  nature 
policies 
in  May  2016  and  a  package  of  food  and 
agriculture  policies31  in  December  2016.  These  policies 
will  constitute  the  framework  for  promoting  green 
infrastructure  in  agriculture.  In  2016-2019,  a  national 
scheme is being implemented to support hedgerows. Its 
in  open 
main  purpose 
agricultural  land.  In  addition,  4 500 ha  of  carbon-rich 
organic  soils  will  be  set  aside  by  2020  to  restore  or 
improve  natural  habitats  to  support  biodiversity  and 
climate-change mitigation. 

increase  biodiversity 

is  to 

The government’s reforestation scheme has been funded 
via  the  Danish  Nature  Protection  Act,  and  co-funded  by 
water  utilities  and  municipal  funds.  The  Nature  Fund 
(‘Den Danske Naturfond’32) is a public-private partnership 
that  supports  projects  that  expand  and/or 
improve 
natural  areas.  Other  green  infrastructure  initiatives  can 
be  financed  by  EAFRD  measures  and  national  budgets. 
The  government  has  pledged  to  contribute  DKK  48 
million (around EUR 6.5 million) to two new LIFE projects 
in Denmark that are co-financed by the EU. 

As  a  densely  populated  and  highly  urban  and  suburban 
country,  Denmark  faces  high  competition  for  space  and 
potentially  limited  opportunities  for the  development  of 
green  infrastructure.  ‘Greening’  agricultural  land  and 
management  practices 
for 
developing green infrastructure. 

remains  a 

challenge 

is  required  to  provide 

Denmark 
information  about 
progress on a prioritisation framework for the restoration 
of  biodiversity,  as  provided  for  under  Action  6(a)  of  the 
EU  biodiversity  strategy.  It  is  also  required  to  provide 
information on other strategic approaches to biodiversity 
restoration. 

Estimating natural capital 

The  EU  biodiversity  strategy  calls  on  Member  States  to 
map  and  assess  the  state  of  ecosystems  and  their 
services33 in their national territories by 2014, assess the 
economic  value  of  such  services  and  integrate  these 
values  into  accounting  and  reporting  systems  at  EU  and 
national level by 2020. 

Denmark  has  its  own  MAES  website  on  the  Biodiversity 
Information  System  for  Europe  platform  (BISE).  Since 
2015, Denmark has not provided any new information on 
its  work  on  the  mapping  and 
this  website  about 
assessment of ecosystems and their services. 

Denmark  has  accomplished  a  full-scale  mapping  of  its 
ecosystems,  and  provided  an  overview  of  the  status  of 
for  16 
the  ongoing  ecosystem-service  mapping 
ecosystem services. An overview of existing data sources 
and  methods  used  is  synthesised  in  tables.  The  report 
shows  that  there 
is  an  unexploited  potential  for 
combining  modelling  and  mapping  of  ecosystems 
services  and  economic  valuation  of  biodiversity  and 
ecosystem  services 
the 
distribution of species shows a clear correlation between 
land use categories and biodiversity.  

in  Denmark.  Mapping  of 

A follow-up MAES project started 2015 and a report was 
published  in  201734.  It  illustrates  in  which  cases  and 
under  which  circumstances  synergies  and  trade-offs  are 
found  for  six  different  scenarios  between  six  ecosystem 
services and biodiversity.  

Overall,  the  project  has  shown  that  it  is  possible  to 
combine  existing  spatial  data  layers  and  models  and 
thereby  facilitating  analyses  of  the  effects  of  land  use 
changes across many ecosystem services and biodiversity 
indicators.  Moreover,  it  has  been  shown  that  it  is 
possible to combine bio-physical modelling of ecosystem 
services  with  spatially  specific  data  and  economic 
valuation.  

Figure 10: Implementation of MAES (September 2018) 

30 The idea of a Green Map of Denmark (‘Grønt Danmarkskort’) was 
introduced in the Danish Spatial Planning Act in 2015 with the aim to, 
for instance, ensure that the most valuable Danish nature is sufficiently 
interconnected to allow species to spread and thrive. 
31 Fødevare- og landbrugspakke. 
32 The Danish Nature Fund.  

Business  and  biodiversity  platforms,  networks  and 
communities of practice are key tools for promoting and 

33 Ecosystem services are benefits provided by nature such as food, 
clean water and pollination on which human society depends. 
34 BISE, Green Infrastructure in Denmark. 

14 

 
                                                                 
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

facilitating  natural  capital  assessments  among  business 
and  financial  service  providers,  for  instance  via  the 
Natural  Capital  Coalition’s  protocol35.  The  assessments 
contribute  to  the  EU  biodiversity  strategy  by  helping 
private  businesses  better  understand  and  value  both 
their  impact  and  dependence  on  nature.  Biodiversity 
platforms  have  been  established  at  EU  level36  and  in  a 
number of Member States. 

Invasive  Alien  Species  Regulation  whenever  an  invasive 
alien species of Union concern not previously present in a 
country  is  detected  in  a  country  for  the  first  time. 
Notifications  are  also  required  when  an  invasive  alien 
species of Union concern that was previously believed to 
be  eradicated  from  a  country  reappears.  The  Danish 
notification  was  for  ruddy  duck  (Oxyura  jamaicensis). 
Eradication measures are ongoing. 

Denmark has not yet established such a platform. 

2019 priority action 

  Denmark 

is  encouraged  to  start  working  on  a 
nationwide MAES-type initiative to develop a natural 
capital accounting system. 

Invasive alien species 

Under  the  EU  biodiversity  strategy,  the  following  are  to 
be achieved by 2020:  
(i) invasive alien species identified;  
(ii) priority species controlled or eradicated; and  
(iii)  pathways  managed  to  prevent  new  invasive  species 
from disrupting European biodiversity.  
This  is  supported  by  the  Invasive  Alien  Species  (IAS) 
Regulation, which entered into force on 1 January 2015. 

In  2017,  the  EU  released  a  report  on  the  baseline 
distribution  of  invasive  alien  species  of  Union  concern 
(Figure 11). Denmark reviewed its country and grid-level 
data  to  contribute  to  this  report.  The  report  shows  that 
of  the  37  species  on  the  first  Union  list,  13  have  been 
observed in the environment in Denmark. 10 of these 13 
invasive  alien  species  are  considered  as  ‘established’  in 
Denmark  (a  species  being  established  in  a  new  habitat 
means  it  can  successfully  produce  viable  offspring  with 
the  likelihood  of  continued  survival).  None  of  these 
established invasive alien species seem to be very widely 
spread  across  the  country.  According  to  the  data, 
Denmark  appears  to  be  less  subject  to  invasive  alien 
species  than  its  neighbouring  countries.  However,  this 
may  simply  indicate  that  less  data  are  available  in 
Denmark  due  to  listed  species  not  being  subject  to 
surveillance  before  the  adoption  of  the  Union  list.  The 
country  is  facing  a  high  invasion  pressure  of  raccoon 
(Procyon lotor) from Germany. 

Between  the  entry  into  force  of  the  Union  list  and 
18 May  2018  Denmark  submitted  one  early  detection 
notification 
the  European  Commission.  These 
notifications  are  required  under  Article 16(2)  of  the 

to 

35 Natural Capital Coalition, Natural Capital Protocol. 
36 Business and Biodiversity, The European Business and Biodiversity 
Campaign aims to promote the business case for biodiversity in the EU 
Member States through workshops, seminars and a cross media 
communication strategy. 

Figure  11:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Denmark37 

responsible 

implementing 

Denmark  has  notified  the  Commission  of  its  competent 
IAS 
authorities 
the 
for 
Regulation  as  required  by  Article 24(2)  of  the 
IAS 
Regulation. It has communicated to the Commission the 
national  provisions  on  penalties 
to 
infringements,  as  required  by  Article 30(4)  of  the  IAS 
Regulation  and  has  therefore  fulfilled  its  notification 
obligations in this regard. 

applicable 

2019 priority action 

 

Investigate  the  apparent  lack  of  data  and  seek  ways 
of improving the surveillance system 

Soil protection 

The  EU  soil  thematic  strategy  underlines  the  need  to 
ensure a  sustainable use of soils.  This  entails preventing 
further  soil  degradation  and  preserving  its  functions,  as 
well as restoring degraded soils. The 2011 Roadmap to a 
Resource Efficient Europe states that by 2020, EU policies 
must  take  into  account  their  direct  and  indirect  impact 
on land use. 

37 Tsiamis K; Gervasini E; Deriu I; D`amico F; Nunes A; Addamo A; De 
Jesus Cardoso A. Baseline Distribution of Invasive Alien Species of Union 
concern. Ispra (Italy): Publications Office of the European Union; 2017, 
EUR 28596 EN, doi:10.2760/772692. 

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Environmental Implementation Report 2019 – Denmark 

Soil  is  a  finite  and  extremely  fragile  resource  and  it  is 
increasingly degrading in the EU. 
The percentage of artificial land38 in Denmark (Figure 12) 
relative  pressure  on  nature  and 
can  show 
biodiversity,  and  the  environmental  pressure  on  people 
living in urbanised areas. 

the 

Soil  organic  matter  plays  an  important  role  as  a  carbon 
sink in the carbon cycle and in climate change.  Denmark 
has  an  average  concentration  of  soil  organic  carbon  of 
29.6 g/kg  (across  all  land  cover  types)  compared  to  a 
European mean of 47 g/kg. 
Figure 12: Proportion of artificial land cover, 201542 

Denmark  ranks  around  the  EU  average  for  artificial  land 
coverage,  with  6.7 %  of  artificial  land  (EU-28  average: 
4.1 %). Denmark’s population density is 136.4/km2, which 
is also above the EU average of 118/km239. 

Contamination  can  severely  reduce  soil  quality  and 
threaten  human  health  or  the  environment.  A  recent 
report  of  the  European  Commission40  estimated  that 
potentially  polluting  activities  have  taken  or  are  still 
taking place on approximately 2.8 million sites in the EU. 
At EU level,  650 000 of these sites have been registered 
in national or regional inventories. 65 500  contaminated 
sites  already  have  been  remediated.  Denmark  has 
registered  16 865  sites  where  potentially  polluting 
activities have taken or are taking place, and already has 
remediated or applied aftercare measures on 2 483 sites. 

Soil erosion by water is a natural process, but this natural 
process can be aggravated by climate change and human 
activities  such  as  inappropriate  agricultural  practices, 
deforestation,  forest  fires  or  construction  works.  High 
levels  of  soil  erosion  can  reduce  productivity 
in 
agriculture  and  can  have  negative  and  transboundary 
impacts  on  biodiversity  and  ecosystem  services.  High 
levels  of  soil  erosion  can  also  have  negative  and 
lakes  (due  to 
transboundary  effects  on  rivers  and 
transport  of 
and 
volumes 
increased 
contaminants).  According  to  the  RUSLE2015  model41, 
Denmark  has  an  average  soil  loss  rate  by  water  of  0.50 
tonnes per hectare per year (t ha−a yr−y), compared to the 
EU  mean  of  2.46 t ha−a yr−y.  This 
indicates  that  soil 
erosion  in  Denmark  is  under  control.  Note  that  these 
figures  are  the  output  of  an  EU-level  model  and  can 
therefore not be considered as values measured in-field. 
The  actual  rate  of  soil  loss  can  vary  strongly  within  a 
Member State depending on local conditions. 

sediment 

38 Artifical land cover is defined as the total of roofed built-up areas 
(including buildings and greenhouses), artificial non built-up areas 
(including sealed area features, such as yards, farmyards, cemeteries, 
car parking areas etc. and linear features, such as streets, roads, 
railways, runways, bridges) and other artificial areas (including bridges 
and viaducts, mobile homes, solar panels, power plants, electrical 
substations, pipelines, water sewage plants, and open dump sites). 
39 Eurostat, Population density by NUTS 3 region. 
40 Ana Paya Perez, Natalia Rodriguez Eugenio (2018), Status of local soil 
contamination in Europe: Revision of the indicator “Progress in the 
management Contaminated Sites in Europe”. 
41 Panagos, P., Borrelli, P., Poesen, J., Ballabio, C., Lugato, E., 
Meusburger, K., Montanarella, L., Alewell, C., The new assessment of 
soil loss by water erosion in Europe, Environmental Science and Policy, 
2015, 54, pp. 438-447. 

Marine protection 

EU coastal and marine policy and legislation require that 
by  2020  the  impact  of  pressures  on  marine  waters  be 
reduced  to  achieve  or  maintain  good  environmental 
status (GES) and ensure that coastal zones are managed 
sustainably. 

The Marine Strategy Framework Directive (MSFD)43 aims 
to achieve good environmental status of the EU’s marine 
waters  by  2020.  To  that  end,  Member  States  must 
develop  a  marine  strategy  for  their  marine  waters,  and 
cooperate  with  the  EU  countries  that  share  the  same 
marine (sub)region. 

These  marine  strategies  comprise  different  steps  that 
must  be  developed  and 
implemented  over  six-year 
cycles. The latest step required Member States to set up 

42 Eurostat, Land covered by artificial surfaces by NUTS 2 regions. 
43 Directive 2008/56/EC. 

16 

                                                                 
 
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

and  report  to  the  Commission  their  programme  of 
measures by 31 March 2016. 

The  Commission  could  not  assess  whether  Danish 
measures  were  appropriate  to  reach  GES44  given  that 
Denmark  reported 
for  the 
Commission 
this  assessment 
exercise45. 

its  measures  too 
them 

include 

late 

to 

in 

For  Denmark,  the  Convention  for  the  Protection  of  the 
Marine  Environment  of  the  North-East  Atlantic  (OSPAR 
Convention)  and 
the  Baltic  Marine  Environment 
Protection  Commission  (Helsinki  Commission)  make  a 
significant contribution to achieving the goals required by 
the Marine Strategy Framework Directive.  

2019 priority action 

  Ensure  timely  reporting  of  the  different  elements 
under  the  Marine  Strategy  Framework  Directive  so 
that  Denmark  can  be  part  of  future  Commission 
assessments. 

44 COM(2018) 562 and SWD(2018) 393. 
45 Denmark reported its programme of measures to the Commission on 
30 May 2017 whereas the due date was 31 March 2016. 

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Environmental Implementation Report 2019 – Denmark 

3. 

Ensuring citizens’ health and quality of life 

Air quality 

EU clean air  policy and legislation require the significant 
improvement  of  air  quality  in  the  EU,  moving  the  EU 
closer to the quality  recommended by the World Health 
Organisation.  Air  pollution  and  its  impacts  on  human 
health,  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  air  quality  legislation  and 
defining strategic targets and actions beyond 2020. 

The  EU  has  developed  a  comprehensive  body  of  air 
legislation46,  which  establishes  health-based 
quality 
standards and objectives for a number of air pollutants. 

(NMVOCs) 

The  emissions  of  several  air  pollutants  have  decreased 
in  Denmark47.  The  emission  reductions 
significantly 
between 1990 and 2014, mentioned in the previous EIR, 
continued  between  2014  and  2016.  Emissions  of  sulfur 
oxides  (SOx)  fell  by  2.85 %,  emissions  of  nitrogen  oxides 
(NOx)  fell  by  0.71  and  emissions  of  volatile  organic 
compounds 
fell  by  0.36 %.  Meanwhile, 
emissions  ammonia  (NH3)  increased  by  1.76 %  between 
2014  and  2016  and  emissions  of  fine  particulate  matter 
PM2.5  have  increased  over  the  period.  This  is  however 
mainly  due  to  an  alteration  in  the  method  for  taking 
stock  of  wood  burning  stoves  in  private  households. 
Residential heating constitutes approximately two thirds 
of PM2.5 emissions (see also Figure 13 on the total PM2.5 
and NOx emissions per sector). 

According to a special report from the European Court of 
Auditors (ECA)48, EU action to protect human health from 
air  pollution has not  had its expected impact.  There is a 
risk  that  air  pollution  is  being  underestimated  in  some 
instances because it may not always be monitored in the 
right  places.  Member  States  are  now  required  to  report 
both  real-time  and  validated  air  quality  data  to  the 
Commission49. 

Hence,  additional  efforts  are  needed  to  attain  the 

46 European Commission, Air Quality Standards, 2016. 
47 See EIONET Central Data Repository and Air pollutant emissions data 
viewer (NEC Directive). 
48 European Court of Auditors, Special report no 23/2018: Air pollution: 
Our health still insufficiently protected. 
49 Article 5 of Commission Implementing Decision 2011/850/EU of 12 
December2011 laying down rules for Directives 2004/107/EC and 
2008/50/EC of the European Parliament and of the Council as regards 
the reciprocal exchange of information and reporting on ambient air 
quality (OJ L 335, 17.12.2011, p. 86) requires Member States to provide 
Up-To-Date data. 

emission  reduction  commitments  for  NH3  and  PM2,5 
(compared  2005  emission  levels)  laid  down  in  the  new 
National  Emissions  Ceilings  Directive50  for  the  period 
2020 to 2029 and for any year from 2030.  

Figure  13:  PM2.5  and  NOx  emissions  by  sector  in 
Denmark51 

According  to  the  ECA52,  EU  action  to  protect  human 
health  from  air  pollution  has  not  delivered  its  expected 
impact. There is notably a  risk  that air  pollution is being 
underestimated  in  some  instances  because  it  may  not 
always be monitored in the right places. Indeed, Member 
States  are  required  to  report  both  real-time  and 
validated air quality data to the Commission.  

Air  quality  in  Denmark  is  reported  to  be  generally  good 
with  exceptions..  For  2015,  the  European  Environment 

50 Directive 2016/2284/EU. 
51 2016 NECD data submitted by Member State to the EEA. 
52 European Court of Auditors, Special report no 23/2018, Air pollution: 
Our health still insufficiently protected, p.41. 

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Environmental Implementation Report 2019 – Denmark 

Agency estimated that about 2 800 premature deaths in 
Denmark  were  attributable  to  fine  particulate  matter53 
concentrations,  90  premature  deaths  were  attributable 
to  ozone54  concentrations,  and  80  premature  deaths 
were attributable  to nitrogen55 dioxide concentrations56. 
For  2017,  no  exceedances  above  the  EU  air  quality 
standards have been reported. 

The  past  persistent  breach  of  air  quality  requirements 
(for  NO2,)  which  have  severe  negative  effects  on  health 
and  the  environment,  are  being  followed  up  by  the 
European  Commission  through  infringement  procedures 
covering  in  all  the  Member  States  concerned,  including 
Denmark.  The  aim  of  these  infringement  procedures  is 
that to encourage countries to put adequate measures in 
place  to  bring  all  zones 
into  compliance.  Demark 
reported  no  exceedances  in  2017,  which  is  encouraging 
for the future.  

Figure  14:  Air  quality  zones  exceeding  EU  air  quality 
standards in 201757 

in 

The Danish Government  launched a  clean air  package in 
October  201858,  especially  dedicated  to  reduce  air 
pollution 
larger  cities  and  phase-out  diesel  and 
gasoline  vehicles.  Further,  it  has  committed  meet  the 
reduction  targets  under  the  NEC  directive.  Concrete 
objectives include no new diesel or gasoline cars sold by 
2030;  no  hybrid  cars  by  2035;  cleaner  transportation  in 
urban  and  rural  areas;  more  environment  friendly 
shipping at sea and in harbours; an effective and modern 
agricultural sector; greener residential heating. 

53 PM is a mixture of aerosol particles (solid and liquid) covering a wide 
range of sizes and chemical compositions. PM10 (PM2.5) refers to 
particles with a diameter of 10 (2.5) micrometres or less. PM is emitted 
from many anthropogenic sources, including combustion. 
54 Low level ozone is produced by photochemical action on pollution. 
55 NOx is emitted during fuel combustion e.g. from industrial facilities 
and the road transport sector. NOx is a group of gases comprising 
nitrogen monoxide (NO) and nitrogen dioxide (NO2). 
56 European Environment Agency, Air Quality in Europe – 2018 Report, 
p.64. Please see details in this report as regards the underpinning 
methodology. 
57 EEA, EIONET Central Data Repository. Data reflects the reporting 
situation as of 26 November 2018. 
58 Together for a greener future.  

2019 priority actions 

  Take  action, 

in  the  context  of  the  forthcoming 
National Air Pollution Control Programme (NAPCP), to 
reduce  the  main  emission  sources,  while  giving 
special  attention  to  measures  reducing  PM2.5  and 
ammonia. 

  Reduce  ammonia  (NH3)  emissions  to  comply  with 
currently  applicable  national  emission  ceilings,  for 
example by introducing or expanding the use of low-
emission agricultural techniques. 

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; and  
(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 Directive59 (IED). 

The  below  overview  of  industrial  activities  regulated  by 
the  IED  is  based  on  the  ‘industrial  emissions  policy 
country profiles’ project60. 

In  Denmark,  around  1 800  industrial  installations  are 
required  to  have  a  permit  based  on  the  IED61.  The 
industrial  sectors 
IED 
installations in 2015 were the intensive rearing of poultry 
or pigs (70 % of total), followed by non-hazardous waste 
management (13 %). 

in  Denmark  with  the  most 

The industrial sectors contributing the most emissions to 
air in Denmark are: (i) energy-power for most pollutants, 
and  (ii)  ‘other  activities’  (mostly  the  intensive  rearing  of 
poultry  or  pigs  and  surface  treatment)  mainly  for  non-
methane  volatile  organic  compounds  (NMVOC)  and 
ammonia (NH3) emissions. Iron and steel production for 
most  heavy  metals  also  made  a  significant  contribution, 
as  did  energy  refining  for  several  pollutants.  The 
breakdown is shown in Figure 16. 

59 Directive 2010/75/EU covers industrial activities carried out above 
certain thresholds. It covers energy industry, metal production, mineral 
and chemical industry and waste management, as well as a wide range 
of industrial and agricultural sectors (e.g. intensive rearing of pig and 
poultry, pulp and paper production, painting and cleaning). 
60 European Commission, Industrial emissions policy country profile – 
Denmark. 
61 European Commission, Industrial emissions policy country profile – 
Denmark. 

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Environmental Implementation Report 2019 – Denmark 

Figure  15:  Number  of  IED  industrial  installations  by 
sector, Denmark (2015)62 

Figure 16: Emissions to air from IED sectors and all other 
national total air emissions, Denmark (2015) 

The  chemical  industry  has  quite  a  significant  role  in 
emissions  to  water  according  to  reported  E-PRTR  data 
(although  there  are  major  data  gaps).  However,  most 
Danish  industrial  wastewater  is  treated  in  municipal 
water treatment plants. The waste management sector is 
the  main  contributor  to  hazardous  and  non-hazardous 
waste generation. 

The enforcement approach under the IED creates strong 
rights for citizens to have access to relevant information 
and  to  participate  in  the  permitting  process  for  IED 
installations. This empowers NGOs and the general public 
to  ensure  that  permits  are  appropriately  granted  and 
their conditions respected. 

Best available techniques (BAT) reference documents and 
BAT conclusions are developed through the exchange of 
industrial 
information  between  Member 
associations,  NGOs  and  the  Commission.  This  ensures  a 
good  collaboration  with  stakeholders  and  a  better 
application of the IED rules. 

States, 

Thanks  to  the  national  competent  authorities’  efforts  to 
apply the legally binding BAT conclusions and associated 
BAT  emission  levels  in  environmental  permits,  pollution 
has decreased considerably and continuously in the EU. 

For  example,  by  applying  the  recently  adopted  BAT 
emission levels for large combustion plants, emissions of 
sulphur dioxide  will be  cut  on average by between 25 % 
and  81 %,  nitrogen  oxide  between  8 %  and  56 %,  dust 
between 31 % and 78 % and mercury between 19 % and 
71 % at EU level. The extent of the reduction depends on 
the situation in individual plants. 

2019 priority actions 

  Review  permits  to  ensure  that  they  comply  with  the 

newly adopted BAT conclusions. 

  Strengthen  control  and  enforcement  to  ensure 

compliance with the BAT conclusions. 

Noise 
The  Environmental  Noise  Directive63  provides  for  a 
common  approach  to  avoiding,  preventing  and  reducing 
the harmful effects of exposure to environmental noise. 

Excessive noise from aircraft, railways and roads is one of 
the  main  causes  of  environmental  health-related  issues 
in the EU64. 
Based  on  a  limited  set  of  data65,  environmental  noise 
causes  around  100  premature  deaths  per  year 
in 
Denmark,  and  is  responsible  for  around  700  hospital 
admissions.  Noise  also  disturbs  the  sleep  of  roughly 
180 000 in Denmark. The noise mapping for the previous 
reporting round (reference year 2011) is complete as are 
the action plans (reference year 2013). 

These  instruments,  adopted  after  a  public  consultation 
had  been  carried  out,  should  include  the  measures  to 
keep noise low or reduce it.  

62 European Commission, Industrial emissions policy country profile – 
Denmark. 

63 Directive 2002/49/EC. 
64 WHO/JRC, Burden of disease from environmental noise, Fritschi, L., 
Brown, A.L., Kim, R., Schwela, D., Kephalopoulos, S. (eds), World Health 
Organisation, Regional Office for Europe, 2011, Copenhagen, Denmark. 
65 European Environment Agency, Noise Fact Sheets 2017. 

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Environmental Implementation Report 2019 – Denmark 

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. 

The  existing  EU  water  legislation66  puts  in  place  a 
protective  framework  to  ensure  high  standards  for  all 
water  bodies  in  the  EU  and  addresses  specific  pollution 
sources  (for  example,  from  agriculture,  urban  areas  and 
industrial  activities).  It  also  requires  that  the  projected 
into  the 
impacts  of  climate  change  are 
corresponding  planning 
risk 
management  plans  and  river  basin  management  plans, 
including  programme  of  measures  which  include  the 
actions  that  Member  States  plan  to  take  in  order  to 
achieve the environmental objectives. 

instruments  e.g. flood 

integrated 

Water Framework Directive 

water bodies and for lakes water bodies it was 62%. The 
most  significant  impact  on  ground  water  was  chemical 
pollution (25%).  

Overall  it  appears  that  there  are  gaps  in  the  quality 
elements  reported  to  be  monitored  in  Denmark  in 
relation  to  the  ecological  status  and  the  chemical 
status.The  ecological  status/potential  of  surface  water 
bodies is illustrated in Figure 17. It is difficult to compare 
the  status  between  the  first  and  second  River  Basin 
Management  Plans  due  to  the  re-delineation  of  water 
bodies and change in assessment methods, nevertheless 
in 
the  overall  picture 
status/potential  since  the  revised  first  River  Basin 
Management Plans with 5-20% more water bodies in less 
than  good  status/potential  in  the  second  River  Basin 
Management  Plans,  except  coastal  waters  around 
Zealand, which has a slight improvement. 

indicates  a  deterioration 

Figure 17: Ecological status or potential of surface water 
bodies in Denmark67 

reported 

Framework  Directive  and 

Denmark  has  adopted  and 
the  second 
generation  of  River  Basin  Management  Plans  under  the 
the  European 
Water 
Commission  has  assessed 
the 
development  since  the  adoption  of  the  first  River  Basin 
Management  Plans,  including  suggested  actions  in  the 
EIR report 2017. 

status  and 

the 

The  most  significant  pressures  on  surface  water  bodies 
overall  were  discharges  not  connected  to  sewerage 
network  (49%),  followed  by  dams,  barriers  and  locks 
(26%), which was mainly applicable to river water bodies. 
Diffuse  pollution  from  agriculture  is  not  reported  as  a 
significant pressure overall for surface water bodies (4%). 
However,  when  it  comes  to  coastal  water  bodies  98% 
have  diffuse  pollution  from  agriculture  and  30%  of  lake 
water  bodies.  For  groundwater  bodies  the  most 
significant  pressure  is  unknown  anthropogenic  pressure 
(25%) and pressures due to abstractions. 

Organic pollution was the  most significant impact on all 
surface water (49%), followed by altered habitats due to 
morphological  changes  (33%).  For  coastal  water  bodies 
the main impact was nutrient pollution affection 98% of 

66 This includes the Bathing Waters Directive (2006/7/EC), the Urban 
Waste Water Treatment Directive (91/271/EEC) (on discharges of 
municipal and some industrial wastewaters), the Drinking Water 
Directive (98/83/EC) (on potable water quality), the Water Framework 
Directive (2000/60/EC) (on water resources management), the Nitrates 
Directive (91/676/EEC) and the Floods Directive (2007/60/EC). 

For  chemical  status  changes  have  been  minimal  with  a 
large majority of sites in unknown status (98.5% reduced 
from  99.3%  in  the  first  cycle),  which  is  due  to  the  fact 
that less than 1% of surface water bodies are monitored 
for  chemical  status.  The  proportion  of  surface  water 
bodies  with  good  chemical  status  is  0.8%  and  the 
proportion  failing  to  achieve  good  chemical  status  is 
0.7%.  

The  assessment  of  the  chemical  status  of  groundwater 
bodies  shows  that  44%  of  groundwater  bodies  are  in 
good  chemical  status,  25%  are  failing  good  status  and 
31% are of unknown status. 

67. EEA, WISE dashboard. 

21 

                                                                 
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

The  number  of  groundwater  bodies  monitored  for 
quantitative  status 
increased  slightly  and  the  total 
groundwater  body  area  failing  good  quantitative  status 
decreased  significantly  from  42%  to  2%.  The  water 
balance  is  calculated  differently  compared  to  the  first 
River basin management Plans where the water balance 
was  assessed  by  screening  criterion  of  the  maximum 
abstraction/exploitation  of  groundwater,  which  should 
not exceed 35% of the natural recharge of groundwater. 
This criterion was now changed to 30%. 

information  on  the  Danish  bathing  waters  is  available 
from  a  national  portal70  and  via  an  interactive  map 
viewer on the European Environment Agency’s website71.  
Figure 18: Bathing water quality 2014–201772 

There  is  a  shortage  of  meaningful  information  reported 
regarding measures so it is not possible to judge whether 
progress  has  been  made  other  than  the  indication  that 
some  measures  have  been  completed.  There  is  a  clear 
financial  commitment 
implementation  of 
Programmes of Measures.  

the 

for 

Nitrates Directive 

To  fulfil  its  obligations  under  the  Nitrates  Directive, 
Denmark  applies  mandatory  measures  on  its  whole 
territory.  On  water  quality  and  nitrate  concentrations, 
data  show  that  progress  has  slowed  in  recent  years. 
Denmark  still  has  problems  with  nitrate  concentrations, 
in  particular  in  groundwater.  It  also  still  has  problems 
with  the  eutrophication  of  surface  waters.  In  addition, 
agricultural  activities  remain  the  main  cause  for  Danish 
land-based  nitrogen  load  to  coastal  waters.  This  is  a 
particularly  serious  issue  considering  that  approximately 
half  of  the  country’s  rivers  drain  into  the  Baltic  Sea  is 
already 
largely  eutrophic  and  strongly  affected  by 
nutrient pollution. 

Denmark  is  changing  its  legislation  towards  a  more 
targeted  implementation  system.  Agricultural  pressures 
and the existing water quality issues mean that Denmark 
must  ensure  that  these  changes  are  accompanied  by 
clear environmental objectives and targets and effective 
enforcement mechanisms. This will ensure the necessary 
and  timely  reduction  of  nutrient  pollution  in  Danish 
waters and in the Baltic Sea. 

Drinking Water Directive 

On  drinking  water,  no  new  data  are  available  since  the 
2017 EIR report68. 

Bathing Water Directive 

Figure  18  shows  that  in  2017,  out  of  the  1 029  Danish 
bathing waters, 86.7 % were of excellent quality, 8.5 % of 
good  quality  and  2.7 %  of  sufficient  quality  (85.9 %,  8 % 
and  2.9 %  respectively  in  2016).  In  2017,  there  were  10 
bathing  waters  of  poor  quality  in  Denmark69.  Detailed 

68 Compliance with the Drinking Water Directive microbiological and 
chemical parameters as last reported was very high. 
69 European Environment Agency, European bathing water quality in 
2016, 2017, p. 17. 

Urban Waste Water Treatment Directive  

Denmark  demonstrates  excellent  levels  of  compliance 
with  the  requirements  of  the  Urban  Waste  Water 
Treatment Directive. Overall in Denmark, 100 % of waste 
water  is  collected,  and  99.8 %  of  the  load  collected  is 
subjected  to  secondary  treatment.  95.4 %  of  the  waste 
water  load  collected  undergoes  even  more  stringent 
treatment.  Investment  in  water  treatment  in  2017  is 
greater  than  in  previous  years,  but  this  increase  in 
investment is expected to slow in the coming years73. 

Floods Directive 

Significant  investment  needs  still  exist  in  Denmark  to 
accelerate  the  implementation  of  the  Water  Framework 
Directive and the Floods Directive, such as the removal of 
obstacles to fish migration, renaturalisation of the flow of 
rivers,  and  various  measures  for  flood  prevention  and 
mitigation. 

The  Floods  Directive  established  a  framework  for  the 
assessment and management of flood risks, aiming at the 
reduction  of  the  adverse  consequences  associated  with 
significant floods. 

Denmark  has  adopted  and  reported  its  first  Flood  Risk 
Management Plans under the Directive and the European 
Commission conducted an assessment. 

70 Badevandskvaliteten ved de danske strande i 2017.  
71 European Environment Agency, State of bathing waters.  
72European Environment Agency, European bathing water quality in 
2017, 2018, p. 21. 
73 European Commission, Ninth Report on the Implementation Status 
and the Programmes for Implementation of the Urban Waste Water 
Treatment Directive (COM(2017)749) and Commission Staff Working 
Document accompanying the report (SWD(2017)445). 

22 

                                                                 
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

The  Commission’s  assessment  found  that  good  efforts 
were made with positive results in setting objectives and 
devising  measures  focusing  on  prevention,  protection 
and  preparedness.  The  assessment  also  showed  that,  as 
was the case for other Member States, Denmark’s Flood 
Risk  Management  Plans  do  not  yet 
include  clearly 
prioritised  measures  and  an  as  complete  as  possible 
estimation of the cost of measures with identification of 
specific sources of funding. In addition, there is scope for 
improving  the  integration  of  the  flood  risk  management 
cycle 
levels  of 
administration. 

including  amongst 

various 

the 

2019 priority actions 

  Take steps in order to improve monitoring of surface 
waters  by  covering  all  relevant  biological,  physico-
chemical and hydromorphological quality elements in 
all  water  categories  and  increase  the  proportion  of 
water  bodies  covered  by  monitoring  for  River  Basin 
Specific Pollutants. 

  Complete  the  development  of  assessment  methods 
in  all  water 
for  all  biological  quality  elements 
categories,  including  methods  that  are  sensitive  to 
nutrients  in  rivers  and  include  hydromorphological 
quality  elements  in  the  classification  of  ecological 
status. 

  Ensure  that  legislation  addressing  nutrients  pollution 
from  agriculture  includes  measures  proportionate  to 
the  Danish  agricultural  pressures  and  water  quality 
implement  the 
issues.  The  measures  chosen  to 
Directives  should  improve  water  quality  both  in  the 
short and long term. 

  Consider to improve the integration of the flood risk 
management  cycle  including  amongst  the  various 
levels of administration. 

Chemicals 

The  EU  seeks  to  ensure  that  by  2020  chemicals  are 
produced and used in ways that minimise any significant 
adverse  effects  on  human  health  and  the  environment. 
An  EU  strategy  for  a  non-toxic  environment  that  is 
conducive  to  innovation  and  to  developing  sustainable 
substitutes,  including  non-chemical  options,  is  being 
prepared. 

legislation74  provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating within the internal market. 

In  2016,  the  European  Chemicals  Agency 
(ECHA) 
published  a  report  on  REACH  and  the  CLP  Regulation75 
that showed that enforcement activities are still evolving. 
Member  States  cooperate  closely  within  the  Forum  for 
Exchange of Information on Enforcement76. This dialogue 
increase  the 
has  shown  that  there 
effectiveness  of  enforcement  activities,  particularly  for 
registration obligations and safety data sheets where the 
level of non-compliance is still relatively high. 

is  scope  to 

While progress has been made, there is room to further 
improve and harmonise enforcement activities across the 
EU,  including  controls  on  imported  goods.  Enforcement 
remains  weak  in  some  Member  States,  particularly  for 
controls  on  imports  and  supply  chain  obligations.  The 
enforcement  architecture 
in  most  EU 
countries and enforcement projects reveal differences in 
compliance between Member States. 

is  complex 

A  2015  Commission  study  already  emphasised  the 
importance  of  harmonised  market  surveillance  and 
enforcement  when  implementing  REACH  at  Member 
State  level,  deeming  it  a  critical  success  factor  in  the 
operation of a harmonised single market77. 

In March 2018, the Commission published an evaluation 
of  REACH78.  The  evaluation  concludes  that  REACH 
delivers  on  its  objectives,  but  that  progress  made  is 
slower  than  anticipated.  In  addition,  the  registration 
dossiers often are incomplete. The evaluation underlines 
the need to enhance enforcement by all actors, including 
in  particular  for 
registrants,  downstream  users  and 

74 Principally for chemicals: REACH (OJ L 396, 30.12.2006, p.1.); for 
Classification, Labelling and Packaging, the CLP Regulation (: OJ L 252, 
31.12.2006, p.1.), together with legislation on biocidal products and 
plant protection products. 
75 European Chemicals Agency, Report on the Operation of REACH and 
CLP 2016. 
76 ECHA, On the basis of the projects REF-1, REF-2 and REF-3. 
77 European Commission, Monitoring the Impacts of REACH on 
Innovation, Competitiveness and SMEs, Final Report, 2015. 
78 COM(2018) 116. 

23 

 
                                                                 
Environmental Implementation Report 2019 – Denmark 

importers,  to  ensure  a  level  playing  field,  meet  the 
objectives  of  REACH  and  ensure  consistency  with  the 
actions envisaged to improve environmental compliance 
and  governance.  Consistent  reporting  of  Member  State 
enforcement activities  was considered  important  in that 
respect. 

authority 

In  Denmark,  the  Chemical  Inspection  Service  at  the 
Danish  Environmental  Protection  Agency  is  the  prime 
enforcement 
regulating 
for 
chemicals.  The  main  legislation  regulating  chemicals  is 
the Danish Act on Chemical Substances and Products. In 
addition, chemicals are regulated by statutory orders and 
EU  chemical  regulations.  Some  parts  of  the  regulations 
are enforced by other authorities. 

legislation 

The  Chemical  Inspection  Service  conducts  enforcement 
campaigns  every  year  for  different  chemical  substances, 
products  and  articles. 
the  Chemical 
Inspection  Service  receives  and  responds  to  complaints 
about  chemical  products  from  companies,  NGOs,  the 
general public, and other authorities79. 

In  addition, 

Making cities more sustainable  

EU policy on the urban environment encourages cities to 
put  policies  in  place  for  sustainable  urban  planning  and 
design.  These  should  include  innovative  approaches  to 
urban  public 
sustainable 
buildings,  energy  efficiency  and  urban  biodiversity 
conservation. 

transport  and  mobility, 

living 

in  Europe 

in  urban  areas 

The  population 
is 
projected to rise to just over 80% by 205080. Urban areas 
pose  particular  challenges  for  the  environment  and 
human  health,  but  they  also  provide  opportunities  for 
using  resources  more  efficiently.  The  EU  encourages 
municipalities to become greener through initiatives such 
as  the  Green  Capital  Award81,  the  Green  Leaf  Award82 
and the Green City Tool83. 

The  Green  City  Tool,  launched  during  the  European 
Commission’s  Green  Week  2018,  allows  cities  to  assess 
and benchmark their environmental performance. It also 
offers  advice  and  recommendations  with  examples  of 
good practice on how to green cities.  

Financing greener cities 

Denmark 
European  Urban 
in 
Development  Network  (UDN)84.  This  network  includes 

participates 

the 

79 ECHA, National Inspectorates - Denmark. 
80 European Commission,  Pollution, by degree of urbanisation. 
81 European Commission, European Green Capital. 
82 European Commission, European Green Leaf Award. 
83 European Commission, Green City Tool. 
84 European Commission, The Urban Development Network. 

24 

more  than  500  cities  across  the  EU  that  are  responsible 
for implementing integrated actions based on sustainable 
urban development  strategies financed by the European 
Regional  Development  Fund  (ERDF)  in  the  2014-2020 
period. 

One  of  the  UDN  initiatives  supported  by  the  ERDF  is 
Urban  Innovative  Actions  (UIA).  UIAs  are  a  way  to  test 
new and unproven solutions to address urban challenges. 
The  total  ERDF  budget  for  UIAs  is  EUR 372  million  for 
2014-202085. 

One  of  the  UIA  projects  is  called  TUPPAC  (Transforming 
Urban  Planning  Providing  Autonomous  Collective 
mobility). TUPPAC will receive EUR 3.4 million in funding, 
and  is  taking  place  in  Albertslund  in  the  suburbs  of 
Copenhagen.  The  TUPPAC  project  will  address  the  ‘first-
and-last-mile’ challenge, the  name given to the problem 
of public transport rarely stopping directly in front of the 
passenger’s  destination  (whether  that  destination 
is 
work, home or a shop). The TUPPAC project will address 
this  challenge  via  LOOP  City  —  a  collaboration  between 
10 municipalities on the outskirts of Copenhagen. In the 
years  2018-2024  a  new  light-rail  system  with  29  new 
stations will be built in LOOP City. Its goal is to encourage 
passengers  to  make  use  of  public  transport  focusing  on 
the physical environment and station proximity.  

The  project  will  address  future  challenges  of  urban 
transport  related  to  the 
introduction  of  driverless 
technology.  Driverless  technology  is  developing  fast  and 
will disrupt urban mobility in the coming decades. But it 
also  raises  questions  such  as:  how  can  autonomous 
vehicles  be  an  integrated  part  of  public  transportation 
and  how  will  they  affect  urban  planning?  The  TUPPAC 
project  will  make  it  easier  for  completely  new  types  of 
innovative mobility services to appear. It will achieve this 
by  addressing  the 
in 
proximity to the new light-rail stations being built. 

‘first-and-last-mile’  challenge 

Participation in EU urban initiatives and networks 

Danish  municipalities  are  generally 
in  EU 
initiatives  on  environmental  protection  and  climate 

involved 

85 European Commission, Urban Innovative Actions. 

                                                                 
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

change. 

Nature and cities 

Four Danish cities, communities and regions are involved 
in  the  URBACT  initiative  to  support  sustainable  urban 
development.  They  are  involved  in  10  of  URBACT’s 
thematic networks86. 

Several  Horizon  2020  network  projects  have  also 
contributed  to  the  sustainability  of  Danish  cities.  The 
three  municipalities 
CIVITAS 
representing  Denmark  in  a  common  effort  to  achieve 
cleaner and better transport in cities87. 

includes 

project 

Danish cities are also actively involved in initiatives such 
as Eurocities and the EU Covenant of Mayors. 37 Danish 
cities are involved with the EU Covenant of Mayors under 
the coordination of the central Denmark region, the  KKR 
Zealand  and  Region  Zealand.  As  of  May  2018, 
Frederikshavn,  Helsingør,  Norddjurs,  Ringkøbing-Skjern, 
Ringsted,  Slagelse,  Solrød,  Sønderborg  and  Vordingborg 
have  already  submitted  their  2020  action  plans.  The 
results  of  these  action  plans  are  now  being  monitored. 
Another  6  cities  have  at  least  presented  their  climate 
action plan and commitments for 2020 or 203088. 

Figure  19:  Proportion  of  Natura  2000  network  in 
Functional Urban Areas (FUA) 89 

These  urban 
initiatives  and  networks  should  be 
welcomed and encouraged, as they contribute to a better 
urban  environment.  In  2017,  12.7 %  of  the  Danish 
population living in cities considered that their residential 
area  was  affected  by  pollution,  grime  or  other 
environmental  problems.  This  is  an  increase  from  2015 
and 2016 when 10.0 % of the Danish population living in 
cities  were  of  this  view.  However,  these  figures  are 
significantly  lower  than  the  EU-28  levels  (20%  in  2017, 
18.9 %  in  2016  and  19.2 %  in  2015),  and  similar  to  the 
results seen in Sweden and Finland90. 

86 URBACT, Associated Networks by country. 
87 European Commission, Horizon 2020 Civitas Project. 
88 Covenant of Mayors for Climate and Energy, Country signatories. 
89 European Commission, the 7th Report on Economic, Social and 
Territorial Cohesion, 2017, p. 121. 
90. European Commission, Eurostat, Pollution, grime or other 
environmental problems by degree of urbanisation. 

25 

More than 46 % of the Natura 2000 network in Denmark 
is  within  functional  urban  areas91,  well  above  the  EU 
average of 15 % (see Figure 19). 

Urban sprawl 

Denmark had a weighted urban proliferation rate, at 3.04 
UPU/m2 92 in 2009 compared to a European average (EU-
28+4)  of  1.64  UPU/m2,  having  increased  by  2 %  from 
2006 to 200993. 

Traffic congestion and urban mobility 

Traffic  congestion  is  not  one  of  the  main  environmental 
issues  affecting  Denmark.  However,  many  subjects 
addressed  in  this  report  are  to  some  extent  related  to 
traffic congestion, especially air quality and noise. 

The  total  number  of  road  vehicles  in  Denmark  reached 
2.8  million  in  2015,  increasing  the  rate  of  vehicles  per 
1 000  habitants  from  494  in  2014  to  501  in  2015.  This 
increase  has  resulted  in  more  hours  spent  annually  in 
road congestion by the average driver, from 21.5 hours in 
2014 to 22.1 hours in 2016. Denmark is far below the UK, 
which  is  the  EU’s  worst  performer  on  this  measure  at 
45.1 hours94. 

Road traffic intensity per unit of GDP in Denmark in 2014 
was 248 vehicle kilometres per 1 000 USD, which is close 
to  the  OECD  Europe  average  of  254  vehicle  kilometres 
per 1 000 USD95. 

On  urban  mobility,  in  2016  around  65 %  of  Danish 
employees commuted more than 5 km to work96. Private 
vehicles are the most frequently used mode of transport 
in Denmark, accounting for 60 % of all commuter trips in 
2009.  However,  bicycles  made  up  a  remarkable  share, 
accounting  for  more  than  20 %  of  all  trips.  Public 
transport is also a major contributor, providing transport 
to 13 % of the commuters97. 

The  modal  split  of  passenger  transport  in  2015  shows 
that  passenger  cars  accounted  for  80.8 %  of  inland 
passenger  transport  in  Denmark  (EU-28  83.4 %).  Buses 
and  trolley  buses  accounted  for  around  9.9 %  (EU-28 
9.1 %) and trains for 9.3 % (EU-28 7.6 %)98. 

91 European Commission, Definition of Functional Urban Areas. 
92 Urban Permeation Units measure the size of the built-up area as well 
as its degree of dispersion throughout the region. 
93 EEA, Urban Sprawl in Europe, Annex I, 2014, pp.4-5. 
94 European Commission, Hours spent in road congestion annually. 
95 OECD, Road traffic intensity per unit of GDP, 2014 or latest available 
year », in Sectoral and Economic Trends of Environmental Significance, 
OECD publications, Paris, 2015. 
96 Statistics Denmark, Employed persons (end November 2016) by area 
of workplace, time, commuting distance and sex. 
97 Danish Ministry of Transport, The Danish Transport System, Facts and 
Figures, 2011. 
98 Eurostat, Passenger transport Statistics by modal split. 

 
                                                                 
                                                                 
Environmental Implementation Report 2019 – Denmark 

Part II: Enabling framework: implementation tools 

4.  Green taxation, green public procurement, environmental 
funding and investments 

Green taxation and environmentally harmful 
subsidies 

incentives, 

taxation  and  other  economic 
Financial 
instruments  are  effective  and  efficient  ways  to  meet 
environmental  policy  objectives.  The  circular  economy 
action  plan  encourages  their  use.  Environmentally 
harmful  subsidies  are  monitored  in  the  context  of  the 
European  Semester  and  the  energy  union  governance 
process. 

Denmark’s revenues from environmentally relevant taxes 
remain among the highest in the EU. Environmental taxes 
accounted  for  3.72 %  of  GDP  in  2017  (EU-28  average: 
2.4 %)  as  shown  in  Figure  20.  In  the  same  year,  energy 
taxes accounted for 2 % of GDP against an EU average of 
1.84 %99.  Environmental  tax  revenues  in  2017  were 
7.98 %  of  total  revenues  from  taxes  and  social-security 
contributions (higher than the EU-28 average of 5.97 %). 

The structure of taxation in Denmark shows the share of 
revenues  from  labour  taxation  in  total  tax  revenues  is 
high, at 50.7 % in 2016. The implicit tax burden on labour 
in  2016  was  34.6 %100.  Consumption  taxes  remained 
relatively  low  (31.1 %,  19th  in  the  EU-28).  This  suggests 
there is considerable potential to shift taxes from labour 
to  consumption  and  in  particular  to  environmentally 
harmful  consumption  in  cases  where  charges  and  fees 
are the right instrument. 

in  Denmark 

The Commission has repeatedly stressed in the European 
Semester  that  taxation  on  pollution  and  taxation  to 
combat  climate  change 
is  higher  than 
elsewhere in Europe. However, the Commission has also 
pointed  out  that  previous  increases  in  the  duty  on 
emissions of nitrogen oxides are being rolled back101. One 
of the most effective environmental taxes in the country 
is the pesticide tax, which has helped reduce the load of 
pesticides on the environment and human health by 40 % 
between  2011  and  2016102.  Another  environmentally 
beneficial tax is the animal feed mineral-phosphorus tax, 
which  has  helped  reduce  the  consumption  of  mineral 
phosphate in animal feeds by 15 % since 2005. However, 
the tax on phosphorus might have been environmentally 

and  economically  more  effective  if  it  applied  to  all 
sources, including mineral fertilisers103. 

Figure  20:  Environmental  tax  revenues  as  %  of  GDP, 
2017104 

Meanwhile,  fossil  fuel  subsidies  fell  in  the  past  decade, 
thanks  to  the  phasing  out  of  indirect  tax  subsidy  for 
diesel,  which  has  a  reduced  energy  duty  compared  to 
petrol105. In 2016, fossil fuel subsidies, essentially the the 
reduced  energy  duty  on  diesel,  amounted  to  EUR 1.2 
billion. 

However, little progress has been made on reducing the 
‘diesel  differential’  (the  difference  in  the  price  of  diesel 
versus petrol) since 2005. In 2016, there was still a 46 % 
gap  between  petrol  and  diesel  tax  rates,  one  of  the 
highest  diesel  differentials  in  the  EU106.  However,  it 

99 Eurostat, Environmental tax revenues, 2018. 
100 European Commission, Taxation Trends Report, 2017. 
101 SWD(2018) 203., p.39. 
102 Evaluering af den differentierede pesticidafgift. 

103 IEEP, Animal feed mineral phosphorus tax in Denmark. 
104 Eurostat, Environmental tax revenues, 2018. 
105 OECD, Inventory of Support Measures for Fossil Fuels, 2018. 
106 European Environment Agency, Environmental taxation and EU 
environmental policies, 2016, p. 27. 

26 

 
 
                                                                 
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

that  a  compensatory 

fee  or 
should  be  noted 
countervailing charge for certain diesel vehicles is applied 
in  Denmark 
‘diesel 
that  on  average  offsets 
differential’. Excise tax rates levied on petrol and diesel in 
2016  were  similar  to  those  levied  in  2015  (EUR 0.61  per 
litre for petrol and EUR 0.44 for diesel)107. 

the 

The  tax  treatment  of  company  cars  is  not  cause  for 
concern  in  Denmark.  New  tax  rules  for  company  cars 
were  introduced  in  2018.  The  most  significant  of  these 
increased annual road tax, cut taxes on electric cars108. 

Denmark  imposes  CO2-based  motor  vehicle  taxes.  The 
annual  circulation  tax  (also  known  as  the  green  owners’ 
tax)  is  based  on  the  car’s  average  fuel  consumption  per 
kilometre. Biogas- and natural gas-powered vehicles have 
the  same  tax  treatment  as  diesel  cars,  while  petrol  cars 
pay more on average109. Incentives to purchase cars with 
lower  CO2  emissions  were  common  in  2016.  Some  of 
these incentives  were linked  to annual circulation taxes, 
road  tolls,  congestion  zones  or 
low-emission  zone 
charges. Other incentives were related to the acquisition 
of cars or use of public infrastructure110. 

This EIR 2019 report also suggests that the tax system can 
be  used  for  environmental  policy  while  simultaneously 
raising  revenue.  In  particular  (see  Chapter  3  on  Air 
Quality) more equal tax treatment of transport fuels (for 
example,  diesel)  would  improve  the  environment  and 
create incentives to reduce nitrogen dioxide pollution. 

Denmark  has  adjusted  an  agreement  on  future  tax 
conditions  for  electric  cars,  plug-in  hybrid  cars  and  fuel-
cell cars by more slowly phasing in taxes on electric, plug-
in hybrid and hydrogen cars. One of the main elements of 
this adjustment is in the registration fee for electric cars, 
which  will  now  remain  at  20 %  of  the  level  of  ordinary 
fees (plus a basic deduction of 10 000 DKK) until 5 000 of 
these cars are newly registered or no later than 1 January 
2019.  After  that,  the  fee  will  be  gradually  increased 
annually  until  2022  when  it  is  fully  phased  in.  In  2017-
2021  there  will  be  a  temporary  reduction 
in  the 
registration  fee  of  DKK  1 700  per  kWh  battery  capacity 
(for batteries with a capacity not exceeding 45 kWh). The 
phase-in  schemes  for  plug-in  hybrid  cars  and  hydrogen 
cars are similar to the phase-in scheme for electric cars. 

The use of alternative fuels in new passenger cars sold in 
Denmark  has  been  increasing  in  recent  years.  In  2015, 
the number of new passenger cars using alternative fuels 
was  10  times  greater  than  in  2011.  However,  2016  was 
the  first  year  since  2013  when  the  market  share  of 
alternative-fuel  passenger  cars  fell  (from  2.42 %  in  2015 
to 0.66 %). The decrease is mainly because the subsidy on 
electric  cars  was  removed 
in  2015.  The  Danish 
government  wants  to  stop  the  sale  of  new  petrol  and 
diesel  cars  in  2030  and  plug-in-hybrid  cars  in  2035.  The 
Government  is  also  working  for  a  climate  neutral  (net 
zero  emissions)  society  by  2050  at  the  latest,  meaning 
that  Denmark  will  absorb  at  least  as  much  greenhouse 
gas as emitted111. 

Green public procurement 

The  EU  green  public  procurement  policies  encourage 
Member  States  to  take  further  steps  to  apply  green 
procurement  criteria  to  at  least  50 %  of  public  tenders. 
The European Commission is helping to increase the use 
of  public  procurement  as  a  strategic  tool  to  support 
environmental protection. 

The purchasing power of public procurement amounts to 
around  EUR 1.8  trillion  in  the  EU  (approximately  14%  of 
GDP).  A  substantial  proportion  of  this  money  goes  to 
sectors  with  a  high  environmental 
impact  such  as 
construction  or  transport.  Therefore,  green  public 
procurement  (GPP)  can  help  to  significantly  lower  the 
negative  impact  of  public  spending  on  the  environment 
and  can  help  support  sustainable  innovative  businesses. 
The Commission has proposed EU GPP criteria112. 

107European Commission, Search tax. 
108 Fleet Europe, Major changes to company car taxation in Europe, 
2018. 
109 ACEA, Co2 Based Motor Vehicle Taxes in the EU. 
110 European Environmental Agency, Appropriate taxes and incentives 
do affect purchases of new cars, 2018. 

111 European Commission, Transport in the European Union Current 
Trends and Issues, 2018, pp.27-28. 
112In the Communication ‘Public procurement for a better environment’ 
(COM (2008) 400) the Commission recommended the creation of a 
process for setting common GPP criteria. The basic concept of GPP 
relies on having clear, verifiable, justifiable and ambitious 

27 

 
                                                                 
                                                                 
 
Environmental Implementation Report 2019 – Denmark 

A national strategy on GPP is being implemented as part 
‘intelligent  public 
of  the  government  strategy  on 
procurement’.  Denmark  has  adopted  an 
indicative 
political target that 50 % of all public procurement should 
be green. 

Mandatory  rules  on  GPP  have  been  drawn  up  for 
purchases  of  wood  and  wood-based  products;  energy-
using  products;  and  road  transport  vehicles.  The  Danish 
government  recommends  that  EU  GPP  criteria  be  used 
for  the  product  groups  where  there  is  no  national 
guidance. 

A national task force was launched in 2016 with the aim 
of  helping  public 
to 
institutions 
implement GPP. The national task force is supplementing 
the  Partnership  for  Green  Public  Procurement  and  a 
Forum on Sustainable Purchasing. 

(municipalities) 

To  help  procurers  assess  the  total  cost  of  ownership, 
specific  tools  have  been  developed  in  Denmark  for  13 
different  product  groups.  These  product  groups  are 
computers,  computer  displays,  multi-function  devices, 
servers,  storage  devices,  projectors, 
large  network 
equipment,  small  network  equipment,  UPS,  add-on 
bidets,  lighting,  self-service  machines  and  fridges  and 
freezers.  More  tools  are  developed  as  a  part  of  the 
government’s Strategy for circular economy. 

The  Danish  government  conducted  a  national-level 
investigation of GPP in 2013. The report covered nine of 
the product areas that are subject  to the  50 % target. It 
published  a  report  on  this  investigation  in  2016.  The 
report  finds  that  in  24 %  of  the  tenders  covered  all 
relevant  green  criteria  were  applied,  and  in  71 %  of  the 
tenders one or more criteria were applied.  

A  separate  study  on  GPP  by  the  European  Parliament 
shows  that  Denmark  is  amongst  the  frontrunners  in  the 
EU  on  the  implementation  of  its  GPP  national  action 
plan113. 

Environmental funding and investments 

European  Structural  and  Investment  Fund  (ESIF)  rules 
oblige  Member  States  to  promote  environment  and 
climate  in  their  funding  strategies  and  programmes  for 
rural 
economic, 
development and maritime policy. 

social  and 

territorial 

cohesion, 

Achieving  sustainability  involves  mobilising  public  and 
private  financing  sources114.  Use  of  the  European 

environmental criteria for products and services, based on a life-cycle 
approach and scientific evidence base. 
113 European Parliament, Green Public Procurement and the Action Plan 
for the Circular Economy, 2017, pp. 79-80. 
114 See, for example, Action plan on financing sustainable growth 
(COM(2018) 97).  

28 

these 

Structural  and  Investment  Funds  (ESIFs)115  is  essential  if 
countries  are  to  achieve  their  environmental  goals  and 
integrate 
into  other  policy  areas.  Other 
instruments such as Horizon 2020, the LIFE programme116 
and the European Fund for Strategic Investments (EFSI)117 
may also support the implementation and spread of good 
practices. 
Making  good  use  of  ESIF118  is  essential  to  achieve  the 
environmental goals and integrate these into other policy 
areas.  Other  instruments  such  as  the  Horizon  2020,  the 
LIFE  programme  and  the  EFSI119  may  also  support 
implementation and spread of good practice. 
In the 2017 Special Eurobarometer120 on attitudes of EU 
citizens  towards  the  environment,  87 %  of  Danes 
supported  greater  EU 
in  environmental 
protection in general (the EU-28 average was 85 %). 

investment 

European Structural and Investment Funds 2014-2020 

Figure  21:  ESIF  2014-2020  –  EU  allocation  by  theme, 
Denmark (EUR billion)121 

Through  four  national  programmes,  Denmark  has  been 
allocated EUR 1.25 billion from ESIF funds for 2014-2020. 
This means that, with its national contribution of EUR 722 

115 i.e. the European Regional Development Fund (ERDF), the Cohesion 
Fund (CF), the European Social Fund (ESF), the European Agricultural 
Fund for Rural Development (EAFRD) and the European Maritime and 
Fisheries Fund (EMFF). The ERDF, the CF and the ESF are referred to as 
the ‘cohesion policy funds’. 
116 European Commission, LIFE programme. 
117European Investment Bank, European Fund for Strategic Investments, 
2016. 
118 ESIF comprises five funds — the European Regional Development 
Funds (ERDF), the Cohesion Fund (CF), the European Social Fund (ESF), 
the European Agricultural Fund for Rural Development (EAFRD), and the 
European Maritime and Fisheries Fund (EMFF). The ERDF, the CF and 
the ESF together form the Cohesion Policy funds. 
119 European Investment Bank, European Fund for Strategic 
Investments, 2016. 
120 European Commission, Special 468 Eurobarometer, ‘Attitudes of 
European citizens towards the environment’, 2017. 
121 European Commission, European Structural and Investment Funds 
Data by Country. 

                                                                                                        
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

million, Denmark has a total budget of EUR 1.97 billion to 
invest  in  various  areas,  such  as  SME  support  to  social 
inclusion, the low-carbon economy and aquaculture. 

Cohesion policy 

For  2014-2020,  Denmark  manages  two  operational 
programmes under EU cohesion policy. Of these, one will 
receive 
Regional 
Development  Fund  (ERDF)  and  one  from  the  European 
Social Fund (ESF). 

European 

funding 

from 

the 

For  2014-2020,  Denmark  has  been  allocated  around 
EUR 553  million  in  total  cohesion  policy  funding.  This 
money is being distributed as follows: 

 
 

 

for  more  developed 

EUR 84 million for transition regions (Zealand); 
EUR 329  million 
regions 
(northern  Jutland,  mid-Jutland,  southern  Denmark, 
the  capital 
(greater  Copenhagen)  and 
Bornholm); 
EUR 140  million 
Cooperation. 

Territorial 

European 

region 

for 

Of  this  553  million,  the  ESF  in  Denmark  will  represent  a 
minimum  of  EUR 206.6  million.  The  precise  amount  of 
ESF funding will be set  in light  of the  specific  challenges 
the country needs to address in the areas covered by the 
ESF. 

The EU investments will boost competitiveness. They will 
also  promote  employment  and  growth  by  supporting 
innovation,  the 
low-carbon  economy,  training  and 
education.  In  addition,  the  EU  investments  will  promote 
entrepreneurship,  fight  social  exclusion,  and  help  build 
resource-efficient 
an  environmentally-friendly 
economy. 

and 

Rural development 

Denmark  faces  several  environmental  pressures  in  rural 
areas.  These  pressures  are  mainly  caused  by  emissions 
due to intensive crop and livestock production. 

The  Danish  Rural  Development  Programme 
(RDP) 
outlines  the  country’s  priorities  for  using  EUR 1.191 
billion  available  for  2014-2020.  This  funding  includes 
EUR 919  million  from  the  EAFRD,  EUR 268 million  in 
national  co-funding,  and  EUR 4  million  of  additional 
national funding top-ups. 

The  RDP  plans 
investments in the following areas. 

to  provide 

funding  support 

for 

  At farm level, support is available for the installation 
of new, more resource-efficient equipment in stables 
for  animal  production.  For  example,  this  equipment 
might  lead  to:  more  precise  feeding  of  animals; 
lower  electricity  and  water  consumption;  reduced 
emissions; and better animal welfare. Support is also 
provided  for  new  farm  machinery  that  allows  for 

more precise (and therefore reduced) application of 
fertiliser  and  pesticides.  Machinery  with  lower  fuel 
consumption (and therefore lower emissions) is also 
eligible  for  support.  In  total,  there  are  plans  to 
support  2 400  projects  during  the  programming 
period. 

  Another  important  area  that  will  receive  support  is 
the  creation  of  wetlands.  The  aim  is  for  these 
wetlands to  extract nitrogen  and phosphorous from 
drain  water  before  it  runs  into  lakes,  rivers  and  the 
sea.  Two  types  of  wetlands  are  planned:  large 
wetlands  established  mainly  by  municipalities  and 
landowners,  and  constructed 
involving  several 
wetlands at the level of individual  farms.  The aim is 
to establish 1 000 constructed wetlands.  
Support 
for 
extensification  of  farming  in  low-lying  areas  and 
peaty or organogenic soils.  

is  also  being  given 

to  projects 

 

  Other  types  of  projects  eligible  for  funding  are:  (i) 
the  preparation  of  Natura  2000  areas  for  grazing, 
and  (ii)  the  establishment  of  areas  to  improve  the 
conditions  for  species  listed  in  Annex  IV  of  the 
Habitats Directive. 

  Afforestation  is  another  initiative  to  enhance  the 
environment  and  promote  the  attractiveness  of  the 
landscape.  In  total,  the  RDP  contains  plans  to  plant 
7 500 ha of new forest.  

The  RDP  also  contains  plans  for  area-based  support 
schemes, two of which are discussed below. 

 

 

The  biggest  measure  under  the  area-based  support 
schemes  is  support  to  organic  farming  with  about 
250.000  ha  covered  by  organic  farming  methods  in 
2017,  an  increase  of  100.000  ha  in  10  years.  The 
support is provided for conversion to organic farming 
and for maintaining organic farming practices.  
The other primary area-related scheme is support for 
the management by grazing or mowing of grassland 
and nature areas. The targeted areas for this scheme 
are  Natura  2000  areas,  high-nature-value  (HNV) 
lowland  and 
areas,  and 
wetland  areas.  The  grassland  management  scheme 
helps  fulfil  the  Natura  2000  plans  and  the  EU 
objective  of  maintaining  biodiversity.  Denmark’s 
target is to have at least 90 000 ha contracted under 
this scheme primarily located within the Nature 2000 
areas by 2020.  

lying  organogenic 

low 

To  ensure  that  these  different  environmental  schemes 
implemented, 
are  well  understood  and  correctly 
Denmark  has  provided  training  for  advisors  and  local 
authorities since 2015. The current training is planned for 
a three year period from 2017-2019 as a measure in the 
government agreement on Nature Package from 2016. In 
total  more  than  1 600  people    have  received  training  in 
management  of  nature  and  nature  friendly  farming 

29 

Environmental Implementation Report 2019 – Denmark 

methods in the period from 2015-2018.. 

LIFE programme 

European Maritime and Fisheries Fund 

For  2014-2020,  Denmark’s  investment  package  for  its 
maritime,  fisheries  and  aquaculture  sectors  totalled 
EUR 267.6 million, 
including  EUR 208.4 million  of  EU 
funds. 

One  of  the  main  objectives  of  the  Danish  programme  is 
to  promote  implementation  of  the  discard  ban.  Support 
from  the  European  Maritime  and  Fisheries  Fund  will 
therefore  target  investments  that  aim  to  decrease  and 
handle  unwanted  catches.  Other  areas  that  will  receive 
signiﬁcant  support  are:  (i)  the  protection  of  marine 
biodiversity,  and  (ii)  the  restoration  of  rivers  to  protect 
biodiversity and facilitate the migration of ﬁsh. 

The Connecting Europe Facility (CEF) 

The  CEF  is  a  key  EU  funding  instrument  developed 
specifically  to  direct 
investment  towards  European 
transport,  energy  and  digital  infrastructure  to  address 
identified  missing  links  and  bottlenecks  and  promote 
sustainability. 

By the end of 2017, Denmark had signed agreements for 
EUR 668 million for projects under the CEF122. 

Horizon 2020 

Denmark has benefited from Horizon 2020 funding since 
the programme started in 2014. As of January 2019, 681 
participants  have  been  granted  a  maximum  amount  of 
the  Societal 
EUR 282.3  million 
for  projects 
Challenges 
with 
work 
environmental issues123 124.  

programmes 

dealing 

from 

The  LIFE  programme  is  the  EU’s  funding  instrument  for 
the  environment  and  climate.  Since  its  launch  in  1992, 
the  LIFE  programme  has  co-financed  a  total  of  95 
in  Denmark126.  Altogether,  these  projects 
projects 
account  for  a  total  investment  of  EUR 242  million,  of 
which  EUR 108  million  has  been  provided  by  the  EU.  Of 
these  projects,  57  have  focused  on  environmental 
innovation; 35 have focused on nature conservation and 
biodiversity;  two  have  focused  on 
information  and 
communication;  and  one  has  focused  on  technical 
assistance. 

For  2014-2017,  the  EU  has  allocated  EUR 13  million  to 
Danish projects127. RigKilde-LIFE is one of these projects. 
It  involves  actions  to  restore  and  conserve  petrifying 
springs,  calcareous  fens  and  alkaline  fens  in  Denmark. 
The contribution requested from the EU for Rigkilde-LIFE 
is more than EUR 3.5 million128. 

European Investment Bank 

loans 

Investment  Bank  (EIB) 

European 
in  Denmark 
amounted  to  nearly  EUR 3.5  billion  (DKK  26  billion)  in 
2013-2017129. 
In  2018  alone,  the  EIB  Group  (the 
European Investment Bank and the European Investment 
Fund)130 loaned Danish businesses and public institutions 
about  EUR 560.8  million,  as  shown  in  Figure  22.  Of  this 
amount, EUR 92.4 million (16 %) was directly invested in 
environment-related projects. 
Figure 22: EIB loans to Denmark in 2018131 

In  addition  to  the  abovementioned  work  programmes, 
climate and biodiversity expenditure is present across the 
entire  Horizon  2020.  In  Denmark,  projects  accepted  for 
funding  in  all  Horizon  2020  working  programmes  until 
December  2018  included  EUR  284  million  destined  to 
climate  action  (28.5 %  of  the  total  Horizon  2020 
contribution  to  the  country)  and  EUR  64  million  for 
biodiversity-related  actions  (6.5 %  of  the  Horizon  2020 
contribution to the country)125. 

122 European Commission, European Semester Country Report for 
Denmark, 2018, p. 13. 
123 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). A maximum grant amount is the maximum 
grant amount decided by the Commission. It normally corresponds to 
the requested grant, but it may be lower. 
124 i.e. (ii) Food security, sustainable agriculture and forestry, marine 
and maritime and inland water research and the bioeconomy; (iii) 
Secure, clean and efficient energy; (iv) Smart, green and integrated 
transport; and (v) Climate action, environment, resource efficiency and 
raw materials. 
125 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). 

In 2018, the EIB signed a EUR 100 million loan agreement 
for  the  development  of  two  residential  complexes  with 
nearly-zero-energy-building 
The 
project  comprises  six  buildings,  which  together  will 
provide  660  new  apartments 
in  the  Copenhagen 
metropolitan area. The new buildings will already comply 

standards. 

(NZEB) 

126 European Commission, LIFE in Denmark, 2017. 
127 Commission services based on data provided by EASME. 
128 European Commission, RigKilde-LIFE. 
129 European Investment Bank, 2017 — a record year in Denmark, 2018. 
130 The EIB Group includes EIB and EFSI investments and loans. 
131 EIB, Denmark and the EIB, 2018. 

30 

 
                                                                 
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

with the future NZEB requirements for Denmark, as they 
will  have  significantly 
lower  net  primary  energy 
consumption  than  current  Danish  NZEB  standards.  The 
average  value  for  energy  consumption  in  these  new 
apartments is expected to be around 18 kWh per m2 per 
year.  It  is  expected  that  the  project  will  yield  overall 
primary  energy  savings  of  764  MWh/year  (for  all  six 
buildings)  when  compared  with  the  existing  building 
standards regulation. 

European Fund for Strategic Investments 

The  European  Fund  for  Strategic  Investments  is  an 
initiative to help overcome the current investment gap in 
the  EU.  As  of  January  2019,  it  has  mobilised  EUR 748 
million 
investment 
in  Denmark,  and  the  secondary 
triggered by this is expected to be EUR 4.6 billion132. 

One of the investment funds supported by the EFSI is an 
EFSI  infrastructure  fund  that  invests  in  large  energy-
related projects, with a focus on offshore wind, biomass 
and  electricity  transmission,  mainly  in  northern  and 
western  Europe.  This  will  benefit  Denmark,  which  has  a 
variety of such offshore projects. 

National environmental financing 

government 

spending  on 

environmental 
Danish 
protection  in  2016  was  EUR 1.7  billion,  a  1 %  increase 
from  2015133.  6 %  of  these  payments  were  allocated  to 
waste management activities (the average in the EU was 
49.7 %).  EUR 25.7  million  was  allocated  to  wastewater 
management  (2.2 %  of  the  EUR 1.7  billion  total)  and 
EUR 144.8  million  to  pollution  abatement  (12.4 %  of  the 
EUR 1.7 billion total). EUR 561.2 million of environmental 
the  protection  of 
expenditure  was  allocated 
biodiversity  and  landscape  (48  %  of  the  EUR 1.7  billion 
total).  Between  2012  and  2016,  general  government 
funding 
for  environmental  protection  was  EUR 5.8 
billion134. 

to 

spending 

Total 
and  public)  on 
(both  private 
environmental  protection  in  Denmark  came  to  EUR 5.83 
billion  in  2015,  a  fall  of  2.5 %  from  2013135.  20.3 %  of 
these payments came from the public sector (the average 
in the EU is 26.3 %), and 45.9 % came from business. 

Green  infrastructure  initiatives  (such  as  afforestation, 
carbon-wetlands  and  wetlands)  are  financed  through 
EARDF 
(see  above)  measures  at  75-100 %.  Other 
initiatives,  such  as  hedgerows,  are  financed  entirely 
nationally. 

132 European Investment Bank, EFSI project map. 
133 Eurostat, General Government Expenditure by function, 2018. 
134 Eurostat, General Government Expenditure by function, 2018. 
135 Eurostat, National expenditure on environmental protection by 
institutional sector. 

31 

 
                                                                 
Environmental Implementation Report 2019 – Denmark 

5. 

Strengthening 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; and  
(iii) access to justice in environmental matters.  

It is of crucial importance to public authorities, the public 
and  business  that  environmental  information  is  shared 
efficiently  and  effectively136.  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 environment137. It includes the right to bring 
legal challenges (‘legal standing’)138. 

Environmental information 

needs  to  search  for  certain  data  on  the  website  of  the 
Danish Environmental Protection Agency. 

reviewed  based  on 

Denmark’s  performance  on  the  implementation  of  the 
INSPIRE  Directive  leaves  room  for  improvement.  Its 
performance  was 
its  2016 
implementation report139 and its most recent monitoring 
data  from  2017140.  Denmark  has  made  good  progress  in 
coordination,  data  policies,  dataset  identification  and 
documentation of data. Additional efforts are needed to 
make  data  accessible  through  services.  More  effort  is 
also  needed  (and  is  indeed  underway)  to  prioritise 
environmental  datasets,  in  particular  those  identified  as 
high-value  spatial  datasets  for  the  implementation  of 
environmental legislation141. 

Figure  23:  Access  to  spatial  data  through  view  and 
download services in Denmark (2017)  

In Denmark, environmental information is provided by a 
number  of  different  organisations.  This  has  created  a 
that  are  not  strongly 
number  of  online  portals 
interconnected  – each online portal has its own identity 
and  approach.  The  official  Danish  Natural  Environment 
Portal 
(Danmarks  Miljøportal,  www.miljoeportal.dk) 
explicitly  caters  for  different  types  of  users.  The  Danish 
Environmental Protection Agency covers a broad number 
of  environmental  subjects 
(mst.dk). 
Denmark’s  Agency  for  Data  Supply  and  Efficiency 
INSPIRE-compliant  metadata  portal 
maintains  an 
(geodata-info.dk).  

its  portal 

in 

Environmental information is easier to access for certain 
environmental  topics.  For  example,  there  is  a  lot  of 
less 
information  available  on  air  quality,  whereas 
information  is  available  for  other  areas.  Although  the 
Danish  government  has  created  a  central  official 
environmental  data  portal,  it  does  not  contain  all  of 
Denmark’s  officially  available  information:  the  user  still 

136 The Aarhus Convention, the Access to Environmental Information 
Directive, 2003/4/EC and the INSPIRE Directive, 2007/2 together create 
a legal foundation for the sharing of environmental information 
between public authorities and with the public. This EIR focuses on 
INSPIRE. 
137 The guarantees are explained in Commission Notice on access to 
justice in environmental matters, OJL 275, 18.8.2017 and a related 
Citizen's Guide. 
138 This EIR looks at how well Member States explain access to justice 
rights to the public, and at legal standing and other major barriers to 
bringing cases on nature and air pollution. 

Public participation 

Denmark  has  mainly  regulated  public  participation  in 
decision  making  through  the  Danish  Environmental 
Assessment  Act  and  some  sectoral 
legislation.  The 
National Planning Law also contains provisions governing 
the  involvement  of  the  public  in  local  planning.  These 
provisions  require  stakeholder  consultation;  publication 
of  plans  with  time  to  consult  in  advance;  minimum 
consultation  periods;  consideration  of 
input;  and 
publication  of  comments  and  revisions.  The  2017 
Eurobarometer142  shows  there  is  a  strong  agreement  in 
Denmark  (88 %  of  respondents)  that  an  individual  can 

139 INSPIRE DK country sheet 2017. 
140 INSPIRE, Monitoring dashboard. 
141 List of high value spatial data sets. 
142 European Commission, Special 468 Eurobarometer, "Attitudes of 
European citizens towards the environment", 2017. 

32 

 
 
 
                                                                 
 
                                                                 
Environmental Implementation Report 2019 – Denmark 

play  a  role 
percentage is largely unchanged compared to 2014. 

in  protecting  the  environment.  This 

Access to justice 

Denmark provides clear, user-friendly information to the 
public  about  access-to-justice  rights.  It  provides  this 
information  through  the  MEF  website,  a  joint  website 
created  by  two  state  bodies,  the  Environment  and  Food 
Appeals  Board  and  the  Energy  Appeals  Board.  Denmark 
has relatively liberal legal  standing rights,  which  make it 
possible for individuals and/or NGOs to bring both nature 
and air pollution cases to court. 

2019 priority action 

 

Improve access to spatial data and services by making 
INSPIRE 
linkages  between  the  country 
stronger 
portals  ,  identify  and  document  all  spatial  datasets 
required to implement environmental law, and make 
the data and documentation at least accessible 'as is' 
to other public authorities and the public through the 
digital services envisaged in the INSPIRE Directive. 

Compliance assurance 

to  ensure 

Environmental compliance assurance covers all the work 
undertaken  by  public  authorities 
that 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect  water,  air  and  nature,  and  manage  waste143.  It 
includes  support  measures  provided  by  the  authorities, 
such as:  
(i) compliance promotion144;  
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring145; and  
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement146.  
Citizen  science  and  complaints  enable  authorities  to 
liability147 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage. 

Compliance promotion and monitoring 

Online information is given to farmers on how to comply 
with  obligations  on  nitrates  and  nature.  The  quality  of 
this 
indicator  of  how  actively 
authorities  promote  compliance  in  areas  with  serious 

information 

is  an 

143 The concept is explained in detail in the Communication on ‘EU 
actions to improve environmental compliance and governance’ 
COM(2018)10 and the related Commission Staff Working Document, 
SWD(2018)10. 
144 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation. 
145 This EIR focuses on inspections of major industrial installations. 
146This EIR focuses on the availability of enforcement data and co-
ordination between authorities to tackle environmental crime. 
147 Directive 2004/35/CE, creates the framework. 

33 

implementation gaps. Detailed information is available to 
Danish farmers on their obligations when using fertiliser 
and storing manure in nitrate vulnerable zones148. Online 
information  is  also  available  to  Danish  farmers  about 
their nature obligations149. 

industrial 

Major 
installations  can  present  serious 
pollution  risks.  Public  authorities  are  required  to  have 
installations  and  to  make 
plans  to 
individual  inspection  reports  available  to  the  public150. 
Denmark publishes both plans151 and reports152 online. 

inspect  these 

Citizen science and complaint handling 

in  their  work.  The 

Engaging  the  general  public  through  citizen  science  can 
promote knowledge about the environment and help the 
‘Biodiversity  Now’153 
authorities 
project  uses  citizen  volunteers  to  track  biodiversity  in 
Denmark via a mobile app. The availability of clear online 
information  about  how  to  make  a  complaint  is  an 
indicator of how responsive authorities are to complaints 
from the public. Denmark clearly  explains to the general 
public  how  to  submit  complaints  about  environmental 
problems,  for  example  on  the  citizen  portals  for 
pollution154,  agricultural  pollution155,  noise156,  and 
waste157. 

Enforcement 

When  monitoring 
identifies  problems,  a  range  of 
responses  may  be  appropriate.  The  Danish  government 
makes  available  reports  that  provide  an  overview  of 
administrative  warnings  and 
the  application  of 
sanctions158. It also publishes statistics on environmental 
crimes159. However, there is no published information on 
responses  to  cross-compliance  breaches  on  nitrates  and 
nature. 

is  especially  challenging. 

Tackling  waste,  wildlife  crimes  and  other  environmental 
offences 
It  requires  close 
cooperation  between  inspectors,  customs  authorities, 
police  and  prosecutors.  Following  a  2011  report  by  the 
Environmental  Protection  Agency  giving  guidance  to 

148 Ministry of Environment and Food of Denmark, Gødningsplan. 
149 Ministry of Environment and Food of Denmark, Beskyttelse af Natura 
2000-områderne. 
150 Article 23, Directive, 2010/75/EU. 
151 Ministry of Environment and Food of Denmark, Den fælles 
kontrolstrategi – kontrol baseret på tillid, 2017. 
152 Miljøministeren og KL's aftale om minimumsfrekvenser for samlede 
tilsyn med virksomheder og landbrug. 
153 Projekt Biodiversitet Nu. 
154 Borger, Industri og forurening. 
155Borger, Landbrug og forurening. 
156 Ministry of Environment and Food of Denmark, Hvem kan jeg klage 
til? 
157 Borger, Affald. 
158 Ministry of Environment and Food of Denmark, Digital 
MiljøAdministration. 
159 Danmarks Statistik, Domme. 

                                                                 
                                                                 
Environmental Implementation Report 2019 – Denmark 

inter-agency  cooperation160, 
the  Danish 
strengthen 
Attorney General drew up guidelines on the prosecution 
of  environmental  crimes.  These  guidelines  aim  to 
coordinate  the  roles  of  the  police,  the  relevant 
prosecuting 
administrative 
authority161. 

authorities 

and 

the 

Denmark’s  consistent  culture  of 
in 
environmental-compliance  assurance  can  be  considered 
as a good practice. 

transparency 

Environmental liability 

The  Environmental  Liability  Directive  (ELD)  establishes  a 
framework  based  on  the  ‘polluter  pays’  principle  to 
prevent  and  remedy  environmental  damage.  The  2017 
EIR  focused  on  better  information  on  environmental 
damage, financial security and guidance. The Commission 
is still collecting evidence on the progress made in other 
areas. 

2019 priority actions 

  Better 

inform 

the  public  about 

compliance 

promotion, monitoring and enforcement. 
  Take  further  steps  to  encourage  the 

insurance 
industry to further develop and popularize insurance 
instruments  covering  environmental  damage  under 
the ELD. 
Improve  financial  security  for  liabilities  and  ELD-
guidance  and  publish  information  on  environmental 
damage. 

 

  Publish  information  on  the  outcome  of  enforcement 
action  and  on  the  follow-up  to  detected  cross-
compliance breaches on nitrates and nature. 

Effectiveness of environmental 
administrations 

in 

involved 

implementing 

Those 
environmental 
legislation at EU, national, regional and local levels need 
to have the knowledge, tools and capacity to ensure that 
the  legislation  and  the  governance  of  the  enforcement 
process bring about the intended benefits. 

Administrative capacity and quality 

Central, regional and local administrations must have the 
ability  to  carry  out  their  own  tasks  and  work  effectively 
with  each  other  within  a  system  of  multi-level 
governance. 

In  order  to  ensure  effective  environmental  governance, 
environmental 
the 
appropriate administrative and technical knowledge and 

authorities  need 

staff  with 

skills. With the EIR 2017, the Commission has introduced 
TAIEX-EIR  P2P  as  a  new  instrument  facilitating  peer-
learning  between  experts 
from  the  environmental 
authorities of Member States. 

Denmark  has  participated  in  a  number  of  TAIEX-EIR  P2P 
events, some of which are described below. 

  A  TAIEX-EIR  P2P  study  visit  to  Belgium  by  experts 
working in Danish municipal waste took place on 24–
25 September 2018. The purpose of the visit  was to 
learn  about  networks  for  waste  prevention,  waste 
reuse,  waste  repair,  and  waste  recycling  in  Belgian 
regions and municipalities. 

 

Experts  from  the  competent  authorities  of  the 
Netherlands  and  Denmark  shared  their  experiences 
from  the  Nordic-Baltic  network  of  EU  Timber 
Regulation  competent  authorities  (EUTRCAs)  in  a 
TAIEX-EIR  peer-to-peer  workshop 
in  2018.  The 
workshop  aimed  to  strengthen  cooperation  among 
the competent authorities from eight Mediterranean 
EU  Member  States  to 
improve  and  harmonise 
implementation  of  the  EU  Timber  Regulation  in  the 
Mediterranean region. 

  A TAIEX-EIR P2P workshop was held in Bratislava on 
2–3 July  2018.  The  workshop  was  attended  by 
experts  from  Slovakia,  Hungary,  Czech  Republic, 
Estonia, Latvia, Lithuania, Germany, Belgium, Poland, 
Ireland,  United  Kingdom,  Denmark  and  Bulgaria.  At 
the  workshop,  experts  exchanged  knowledge  and 
experience on effective measures and good practices 
in reducing emissions from domestic heating. 

Coordination and integration 

Environmental 

As  mentioned  in  the  2017  EIR,  the  transposition  of  the 
revised 
(EIA) 
Directive162  2014/52/EU  provides  an  opportunity  for 
countries  to  streamline  their  regulatory  framework  on 
environmental assessments.  

Impact  Assessment 

Denmark  did  not  meet  the  May  2017  deadline  for  full 
transposition of the EIA Directive and the SEA-Directive in 
a  new  Environmental  Impact  Assessment  Act  (EIA  Act). 
However, Denmark has now fully transposed the revised 
Directive.  

the 

The  Commission  encourages 
streamlining  of 
environmental  assessments  to  reduce  duplication  and 
avoid  overlaps 
for 
projects.  Streamlining  helps  to  reduce  unnecessary 
administrative  burden. 
It  also  accelerates  decision 
making,  without  compromising  the  quality  of  the 

in  environmental  assessments 

160 Ministry of Environment, Kommunernes, miljøcentrenes og politiets 
håndhævelse af miljølovgivningen, 2011. 
161Miljø-Behandling af sager om overtrædelse af miljølovgivningen. 

162 Directive 2014/52/EU. 

34 

                                                                 
                                                                 
Environmental Implementation Report 2019 – Denmark 

environmental  assessment  procedure163.  Denmark  has 
introduced  a  streamlined  procedure  for  assessments 
under the EIA and Habitats Directives. 

Adaptability, 
(eGovernment) 

reform 

dynamics 

and 

innovation 

On  digital  public  services,  Denmark  performs  very  well. 
The  country  is  a  frontrunner  in  the  delivery  of  digital 
public  services  among  EU  countries  with  a  score  of 
73.2/100 based on Europe's Digital Progress Report 2017, 
higher  than  the  EU28  average  (57.5/100)164.  In  the  DESI 
Report  2018,  Denmark  had  a  score  of  73  out  of  100  on 
digital  public  services,  higher  than  the  EU  average  of 
58165. 

In  terms  of  open  data,  Denmark  continued  to  make 
considerable progress over the last year (after launching 
a  new  platform).  Thanks  to  a  high  score 
in  their 
completeness  of  online  services  (94  out  of  100)166, 
Denmark  provides  a  good  and  user-friendly  framework 
for eGovernment service for its citizens.  

Enabling financing and effective use of funds 

The  Danish  authorities,  at  national  and  regional  level, 
have good experience in the management of EU funding 
and no major problems arise in this respect.  

2019 priority action 

  Denmark 

can 

further 

overall 
environmental  governance  (such  as  transparency, 
citizen engagement, compliance and enforcement, as 
well as administrative capacity and coordination). 

improve 

its 

International agreements 

The  EU  Treaties  require  the  EU  environmental  policy  to 
promote  measures  at  international  level  to  deal  with 
regional or worldwide environmental problems. 

The EU is committed to strengthening environmental law 
and its implementation globally. It therefore continues to 
support  the  Global  Pact  for  the  Environment  process, 
which  was  launched  by  the  United  Nations  General 

163 The Commission issued a guidance document in 2016 regarding the 
setting up of coordinated and/or joint procedures that are 
simultaneously subject to assessments under the EIA Directive, Habitats 
Directive, Water Framework Directive, and the Industrial Emissions 
Directive, OJ C 273, 27.7.2016, p. 1. 
164 European Commission, Europe's Digital Progress Report (EDPR) 2018 
Country Profile Denmark, p. 10. 
165 European Commission, Digital Economy and Society Index Report 
2018, Digital Public Services. 
166 European Commission, Europe's Digital Progress Report (EDPR) 2018 
Country Profile Denmark, p. 10. 

and 

Assembly  in  May  2018167.  The  EIR  is  one  of  the  tools  to 
ensure  that  the  Member  States  set  a  good  example  by 
respecting  European  Union  environmental  policies  and 
agreements.  Denmark’s 
laws 
ratifying  multilateral 
performance 
environmental agreements is one of the best in the EU. 
Forests:  EU  Timber  Regulation  (EUTR)168/  Forest  Law 
(FLEGT) 
Enforcement,  Governance 
Regulation169 

international 
in  signing  and 

Trade 

and 

Denmark  has  a  relatively 
large  number  of  people 
employed in the implementation and enforcement of the 
EUTR. 

From  March  2015  to  February  2017,  Denmark  planned 
and performed one check on businesses placing domestic 
timber  on  the  EU  market.  In  the  same  period,  Denmark 
conducted 98 checks on operators importing timber. This 
is  145  %  more  checks  than  Denmark  had  originally 
planned  to  carry  out  at  the  start  of  this  period.  These 
numbers are low compared to the number of businesses 
placing  timber  on  the  EU  market  for  the  first  time  in 
Denmark  over  the  same  period170.  Denmark  performed 
one check on timber traders the whole two-year period. 

Denmark  issued  the  highest  number  of  penalties  for 
imported timber, with penalties issued in nearly 60 cases. 
These  penalties  included  remedial  actions  that  led  to 
penalties  and  court  cases.  In  addition,  Denmark  has 
worked to improve the quality of inspections and of due 
diligence  systems.  This  has  involved  participation  in 
informal  meetings  in  third  countries  and  study  trips. 
Denmark  has  also  developed  EUTR  guidelines  for  forest 
owners171. 

Article 12 of EUTR requires Member States to cooperate 
with  each  other  and  with  third  countries  to  implement 
the regulation. Denmark reported that it had exchanged 
from 
information  and 
governmental  institutions  outside  Denmark,  in  addition 
to  cooperation  with  national  customs  and  national 
CITES/regional and other government agencies. 

technical  support 

received 

Genetic  resources:  Nagoya  Protocol  on  Access  to 
Genetic Resources and the Fair and Equitable Sharing of 
Benefits Arising (ABS)172  

The EU ABS Regulation transposes into the EU legal order 
the  required  compliance  measures  under  the  Nagoya 

167 UN General Assembly Resolution 72/277 and Organizational session 
of the ad hoc open-ended working group.  
168 Regulation (EU) No 995/2010. 
169 Regulation (EC) No 2173/2005. 
170 On the basis of customs’ data, it was estimated that 28’000 Danish 
operators placed domestic timber onto the EU market and 2 800 
imported timber. 
171 Ministry of Environment and Food of Denmark, Guideline for Danish 
forest owners on the EU Timber Regulation (EUTR), 2016. 
172 Regulation (EU) No 511/2014. 

35 

                                                                 
                                                                 
Environmental Implementation Report 2019 – Denmark 

Protocol  on  access  to  genetic  resources.  Denmark  is  a 
party to the Nagoya Protocol since the protocol entered 
into  force  10  October  2014.  Denmark  has  designated 
competent  authorities  and  enacted  sanctions 
for 
infringements  of  the  EU  ABS  Regulation.  Denmark  has 
not  yet  submitted  a  due  diligence  declaration  and  no 
penalties have been applied;  nevertheless, Denmark  has 
a plan for conducting checks on user compliance and has 
started  inspections  on  user  compliance.  In  late  2017, 
Denmark submitted its first report to the Commission on 
implementation of the EU ABS Regulation. 

the  Convention  on 
trade: 
International  wildlife 
International  Trade  in  Endangered  Species  of  Wild 
Fauna and Flora (CITES)173 

In  line  with  the  obligations  laid  down  in  the  Basic 
Regulation174,  which  transposes  the  major  obligations  of 
the  Convention  on  International  Trade  in  Endangered 
Species  of  Wild  Fauna  and  Flora  (CITES)  into  EU  law, 
Denmark  has  established  relevant  national  authorities 
and  is  processing  (requests  for)  import,  (re-)  export  and 
intra-EU trade documents on a regular basis. Reports on 
seizures  of  illegal  wildlife  shipments  (in  particular  those 
reported  every  6  months  to  TRAFFIC  under  its  contract 
with the  Commission, and those  exchanged through the 
EU-TWIX  platform)  show 
the  activity  of  customs 
authorities. 

Sustainable 
implementation of the UN SDGs 

development 

and 

the 

Sustainable development links environmental, social and 
economic policies in a coherent framework and therefore 
helps  to 
legislation  and 
policies. 

implement  environmental 

In  2009,  the  Danish  government  published  its  most 
recent  national  strategy  for  sustainable  development. 
The sub-national levels of government were consulted in 
the  preparation  of  the  document.  Municipalities  have 
their own sustainable development strategies, which are 
required by the Planning Act. However, there is no direct 
link between these strategies and the national strategy. 

In  2017  the  government  published  an  action  plan  to 
implement  the  SDGs175.  The  action  plan  contains  37 
largely 
concrete  (mostly)  national  targets  that  are 
measurable  and  quantifiable.  This  will  allow  systematic 
stocktaking  and  evaluation  of  progress,  but  it  does  not 
detail  specific  funding  for 
implementing  the  SDGs. 
Denmark  already  assesses  new  legislative  proposals  in 
terms  of  their  economic,  environmental  and  gender 

173 European Commission, The European Union and Trade in Wild Fauna 
and Flora. 
174 Regulation (EC) No 338/97. 
175  Handlingsplan  for FN’s  verdensmål. 

integrate 

equality  consequences.  The  government  supports  policy 
consistency  in  sustainable  development,  and  ministries 
must 
their 
policymaking176. As part of the action plan to implement 
the  SDGs,  the  government  will  in  future  assess  the 
consequences of new legislation and major initiatives for 
the SDGs in case the impact is significant. 

sustainable  development 

in 

is 

for 

responsible 

the 
The  Ministry  of  Finance 
coordination of the national implementation of the SDGs 
and the government’s action plan. However, government 
ministries  are  responsible  for  integrating  the  SDGs  in 
policy.  The  Ministry  of  Foreign  Affairs  is  responsible  for 
the SDGs at the United Nations and in other international 
fora.  It  is  also  responsible  for  implementing  the  SDGs  in 
Danish  foreign,  security  policy,  trade  and  development 
policy. 

in  general 

Implementation  of  the  action  plan  and  sustainable 
development 
is  funded  by  the  budget 
allocations  approved  by  the  Danish  parliament  in  the 
annual  budget  negotiations  for  the  coming  fiscal  year. 
The government will continue to provide 0.7 per cent of 
Gross  National 
promote 
implementation  of  the  SDGs.  The  government  is  also 
in 
committed 
developing  countries,  and  in  2017  launched  an  SDG 
fund177.  This  fund  will  combine  public  and  private  funds 
to mobilise private capital to help achieve the SDGs. 

to  mobilising 

significant 

resources 

in  ODA 

Income 

to 

In  2017,  a  Nordic  Council  working  group  prepared  a 
report  on  the  most  relevant  SDGs  and  their  state  of 
implementation  in  the  Nordic  countries178.  The  Nordic 
Council is encouraging the integration of the SDGs into its 
own work, and across the countries of the region. 

Following the publication of the action plan in 2017, the 
government  will  publish  annual  progress  reports  on  the 
37  targets,  which  will  be  sent  to  the  Danish  parliament. 
Every four years, the progress report will be replaced by 
a  more  comprehensive  status  report,  which  will  also 
contain  initiatives  for  achieving  the  SDGs  and  possible 
changes  to  the  action  plan179.  Denmark  submitted  a 
voluntary  national  review  on  the  SDGs  to  the  UN  in 
2017180. 

176 The Danish Government, Report for the Voluntary National Review, 
2017. 
177 UN City Copenhagen, New DKK 4bn fund contributes to UN 
Sustainable Development Goals in developing countries.   
178  Norden og FNs 2030-mål. 
179 The Danish Government, Report for the Voluntary National Review, 
2017. 
180 The Danish Government, Report for the Voluntary National Review, 
2017. 

36