COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022 Country Report - DENMARK Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance
Date: 2022-09-08
Institutions: Directorate-General for Environment, European Commission
Subjects: Denmark, EU environmental policy, application of EU law, biodiversity, circular economy, climate change policy, environmental law, governance, pollution control measures, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.9.2022  SWD(2022) 253 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022       Country Report - DENMARK               Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance        {COM(2022) 438 final} - {SWD(2022) 252 final} - {SWD(2022) 254 final} - {SWD(2022) 255 final} - {SWD(2022) 256 final} - {SWD(2022) 257 final} - {SWD(2022) 258 final} - {SWD(2022) 259 final} - {SWD(2022) 260 final} - {SWD(2022) 261 final} - {SWD(2022) 262 final} - {SWD(2022) 263 final} - {SWD(2022) 264 final} - {SWD(2022) 265 final} - {SWD(2022) 266 final} - {SWD(2022) 267 final} - {SWD(2022) 268 final} - {SWD(2022) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 272 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
Denmark  1 

This  report  has  been  written  by  the  staff  of  the  Directorate-General  for  Environment,  European  Commission. 
Any comments are welcome to the following e-mail address: ENV-EIR@ec.europa.eu  

More information on the European Union is available on the internet (http://europa.eu). 

Photographs:  

For reproduction or use of these photos, permission must be sought directly from the copyright holder. 

©European Union, 2022 

Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Denmark  2 

Table of Contents 

EXECUTIVE SUMMARY ........................................................................................................................................... 3 

PART I: THEMATIC AREAS ...................................................................................................................................... 4 

1. 

2. 

3. 

4. 

CIRCULAR ECONOMY AND WASTE MANAGEMENT ........................................................................................................ 4 
Measures towards a circular economy ................................................................................................................ 4 
Waste management ............................................................................................................................................. 6 
BIODIVERSITY AND NATURAL CAPITAL ........................................................................................................................ 9 
Nature protection and restoration ....................................................................................................................... 9 
Marine ecosystems............................................................................................................................................. 14 
Ecosystem assessment and accounting ............................................................................................................. 16 
ZERO POLLUTION ................................................................................................................................................ 18 
Clean air ............................................................................................................................................................. 18 
Industrial emissions ............................................................................................................................................ 19 
Major industrial accidents prevention – SEVESO ............................................................................................... 21 
Noise .................................................................................................................................................................. 23 
Water quality and management ........................................................................................................................ 23 
Chemicals ........................................................................................................................................................... 27 
CLIMATE ACTION ................................................................................................................................................ 29 
Key national climate policies and strategies ...................................................................................................... 29 
Effort sharing ..................................................................................................................................................... 29 
Key sectoral developments ................................................................................................................................. 30 
Use of revenues from the auctioning of EU ETS allowances .............................................................................. 31 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS .............................................................................. 32 

5. 

FINANCING ........................................................................................................................................................ 32 
Environmental investment needs in the European Union .................................................................................. 32 
EU environmental funding 2014-2020 ............................................................................................................... 33 
EU environmental funding 2021-2027 ............................................................................................................... 35 
National environmental protection expenditure ................................................................................................ 37 
Green budget tools ............................................................................................................................................. 38 
Overall financing compared to the needs .......................................................................................................... 40 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 42 
Information, public participation and access to justice...................................................................................... 42 
Compliance assurance ........................................................................................................................................ 43 
Effectiveness of environmental administrations ................................................................................................ 45 
Reforms through the Commission’s technical support instrument .................................................................... 45 
TAIEX EIR peer to peer projects .......................................................................................................................... 45 

Environmental Implementation Review 2022 – Denmark 

 
 
 
 
Denmark  3 

Executive summary 

In  previous  Environmental 
Implementation  Reviews 
(EIRs), the main challenges identified for Denmark for the 
implementation  of  EU  environmental  policy  and  law 
were: 

 

 

the  need  to  reduce  pressures  on  nature  from 
intensive  agriculture,  including  the  use  of  pesticides 
and nutrients; 
the need to improve air quality, especially in densely 
populated areas. 

On waste management, Denmark is likely to meet the EU 
2020  target  of  recycling  50 %  of  municipal  waste. 
However,  it  has  the  highest  municipal  waste  production 
per  head  in the  EU27  and  its  circular  (secondary)  use  of 
material  is  well  below  the  EU  average.  Thus  Denmark 
needs  to  primarily  focus  on  reducing  waste  generation 
and  improving  its  resource  productivity.  Furthermore,  
action  is  needed  to  reduce  incineration  (with  energy 
recovery)  of  municipal  waste; 
level  of 
incineration is partly explained by the very low landfilling. 
The  ERDF  focuses  on  the  circular  economy  and  on 
promoting  of  competitiveness  and  innovation  in  small 
and medium sized enterprises. 

the  high 

Regarding  nature,  the  share  of  habitats  in  poor  or  bad 
status has increased in Denmark. Although all terrestrial 
sites have been designated, the quality of the current set 
of  conservation  objectives  and  measures  is  insufficient; 
they  are  being  updated  2022-2023.  The  situation  for 
forested  areas  protected  under  the  nature  directives  is 
severe as more than half of assessments show they are in 
a bad conservation status. Denmark has a generally good 
capability to assess its state  of the marine  environment, 
although  some  descriptors  are  still  missing.  No  recent 
information  is  available  on  ecosystem  assessment  and 
accounting.  There  are  also  concerns  about  sufficient 
financing  of  the  Natura  2000  network  (based  on  a 
finalised  prioritised  action  framework  (PAF),  which  has 
not  yet  been  formally  submitted  to  the  European 
Commission). 

For  air  quality,  Denmark  plans  to  reach  emission 
reduction  commitments  for  sulphur  and  nitrogen  oxides 
and  non-methane  volatile  organic  compounds  for  the 
period 2020-2029 and from 2030 onwards. However, the 
projections  do  not  demonstrate  compliance  with 
emission  reduction  commitments  for  ammonia  and 
particulate  matter  (PM2.5)  for  2020-2029  and  from  2030 
onwards.  Denmark did not exceed of EU air quality limit 
values in 2020, and  has substantially improved air quality 
since the 2019 EIR with dedicated extra efforts. 

is 

in 

stable  and 

surface  water 

According  to  the  last  report  on  implementation  of  the 
Nitrates  Directive,  groundwater  quality  has  slightly 
improved. The situation concerning the concentration of  
some 
nitrates 
improvements were recorded in reducing eutrophication. 
Nutrient inflows into the Baltic Sea around Denmark have 
significantly  decreased  for  nitrogen  in  the  Danish  Straits 
and Kattegat, and for phosphorus in Kattegat. Improving 
nitrogen and phosphorus cycles helps improve circularity 
of the economy. Nevertheless, the Commission is closely 
monitoring  the  situation.  The  Recovery  and  Resilience 
Programme (RRP) makes the environmental transition in 
agriculture a specific target. 

overall 

financing 

environmental 

On  environmental  financing,  Denmark  has  a  small  RRP 
(2021-2026) with just over EUR 1.5 billion and a cohesion 
(2021-2027)  allocation  of  EUR  500  million.  
policy 
Denmark’s 
for 
investments  is  estimated  to  be  annual    0.57%  of  GDP 
over  the  period  2014-2020,  almost  exclusively  from 
national  sources.  The  overall  environmental  investment 
needs in the coming years are estimated to be at least an 
annual  0.72%  of  Denmark’s  GDP,  suggesting  an 
environmental  investment  gap  of  at  least    0.15%,  by 
focusing on the country’s environmental implementation 
priorities.  

Environmental Implementation Review 2022 – Denmark 

 
 
 
Denmark  4 

Part I: Thematic areas 

1. Circular economy and waste management 

Figure 1: Circular material use rate (%), 2010-20202 

Measures towards a circular economy 

The new Circular Economy Action Plan adopted in March 
2020 is one of the main building blocks of the European 
Green Deal. The EU’s transition to a circular economy will 
reduce  pressure  on  natural  resources  and  will  create 
sustainable  growth  and  jobs.  It  is  also  a  prerequisite  to 
achieve  the  EU’s  2050  climate  neutrality  target  and  to 
halt  biodiversity 
loss.  The  Action  Plan  announces 
initiatives  along  the  entire  life  cycle  of  products,  aiming 
to reduce the EU's consumption footprint and to double 
the EU's circular material use rate by 2030. It targets how 
products  are  designed,  promotes  circular  economy 
processes,  encourages  sustainable  consumption,  and 
aims to ensure that waste is prevented and the resources 
used are kept in the EU economy for as long as possible. 

The  circular  material  use  rate  is  a  good  indicator  of  an 
economy’s circularity, as it includes all the materials that 
are  fed  back  into  the  economy.  Large  differences  in  the 
circularity rate exist across countries. To help achieve the 
EU circular economy action plan’s goal of doubling the EU 
circular  material  use  rate  by  2030,  ambitious  measures 
targeting  the  whole  product  life  cycle  are  needed  at 
range 
Member  State 
from 
sustainable  product  design 
increase  durability, 
reparability,  upgradability  and  recyclability  of  products, 
to  other  measures  such  as  remanufacturing1,  increasing 
the circularity in production processes, recycling, as well 
as  boosting  eco-innovation  and  the  uptake  of  green 
public procurement. 

level.  Such  measures 

to 

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  minimise 
negative 
impacts  on  the  environment  and  reduce 
dependency on volatile raw  material  markets. As  shown 
in  Figure  2,  with  EUR  2.05  generated  per  kg  of  material 
consumed  in  2020,  resource  productivity  in  Denmark  is 
close  to  the  EU  average  of  EUR  2.09  per  kg.  More 
specifically,  Denmark  needs  to  reduce 
its  Domestic 
Material Consumption and Raw Material Consumption. 

Denmark’s  circular  (secondary)  material  use  rate  was 
8.2%  in  2016  and  7.7%  in  2020,  well  below  the  EU 
average of 12.8%. The trend in Figure 1 shows a light fall 
in the use of secondary material in the past few years . 

1 A standardized industrial process that takes place within industrial or 
factory  settings,  in  which  cores  are  restored  to  original  as-new 
condition and performance or better. 

2 Eurostat, Circular Economy Monitoring Framework.  

Environmental Implementation Review 2022 – Denmark 

 
 
                                                                 
 
 
 
                                                                 
 
Denmark  5 

Also worthy of note is the 2020 strategy for investments 
in  green  research,  technology,  and  innovation,  which 
contains  a  green  mission  (one  of  four)  on  circular 
economy focusing on reuse and reduction of plastic and 
textile  waste7  Although  Denmark’s 
recovery  and 
resilience plan (RRP) does not contain reforms relating to 
circular  economy,  there  is  an  investment  dedicated  to 
research  on  circular  economy  focusing  on  reuse  and 
reduction of plastic and textile waste (EUR 23.5 million). 
The  European  Regional  Development  Fund  (ERDF)  for 
2021-27  also  includes  actions  to  boost  the  circular 
economy. 

Eco-innovation 

can  only  be 

A  successful  transition  to  a  circular  economy  requires 
social and technological innovation as the full potential of 
reached  when 
circular  economy 
implemented  across  all  value  chains.  Therefore,  eco-
Innovation is an important enabling factor for the circular 
economy.  Product  design  approaches  and  new  business 
models can help produce systemic circularity innovations, 
creating new business opportunities. 

In 2021, Denmark ranked 4th on the 2021 Eco-Innovation 
Scoreboard, with a total score of 177, resulting in an eco-
innovation  leader  performance.  On  two  out  of  five 
components  (eco 
innovation  activities  and  resource 
efficiency  outcomes)  of  the  2021  Eco-Innovation  Index, 
Denmark  performed  below  the  EU  average.  On  eco-
innovation  outputs  and 
innovation 
socioeconomic  outcomes  it  performed  above  the  EU 
average, ranking 1st in eco-innovation outputs. See Figure 
3. 

inputs,  eco 

Figure 2: Resource productivity 2010-20203 

Circular economy strategies 

The  Commission  encourages  Member  States  to  adopt 
and 
implement  national/regional  circular  economy 
strategies  covering  the  whole  life  cycle  of  products,  as 
they  are  one  of  the  most  effective  ways  to  progress 
towards a more circular economy. Since the launch of the 
European  Circular  Economy  Stakeholder  Platform 
in 
20174,  national,  regional  or  local  authorities  have  used 
the platform to share their strategies and roadmaps.  

The  Danish  government  has  in  2021  launched  an  action 
plan  for  circular  economy5..  This  plan  describes  the 
current  conditions  and  the  direction  to  follow  for  the 
prevention  and  management  of  waste  in  Denmark  until 
20326.  The  plan  puts  extra  focus  on  how  to  make  the 
value  chains  for  biomass,  construction  and  plastics 
become  more  circular.  The  Action  Plan  for  Circular 
Economy  contains  a  total  of  129  initiatives,  many  of 
which are also included in Climate plan for a green waste 
sector  and  circular  economy  (2020),  Strategy  for  Green 
Public  Procurement  (2020),  National  Strategy  for  a 
Sustainable  Built  Environment 
for 
circular  economy  (2018)  and  Action  Plan  on  Plastics 
(2018). 

(2021),  Strategy 

3 Eurostat, Resource productivity 
4 Circular Economy Stakeholder Platform 
5 Danish Action Plan for Circular Economy July 2021  
6 thus it represents Denmark’s waste prevention programme. 

7  Danish  Ministry  of  Higher  Education  and  Science,  2020,  Green 
solutions of the future. 

Environmental Implementation Review 2022 – Denmark 

 
 
 
                                                                 
 
 
                                                                 
Figure 3 – Eco-innovation performance 2010-20198  

Green public procurement 

Denmark  6 

Public  procurement  accounts  for  a  large  proportion  of 
European 
authorities’ 
consumption,  with  public 
purchasing  power  representing  around  14%  of  EU  GDP. 
This can help drive the demand for sustainable products 
that  meet  repairability  and  recyclability  standards. 
Denmark adopted a green public procurement strategy in 
October  2020  (Green  Procurement  for  a  Green  Future), 
which put the public sector at the forefront of the green 
transition.  Around  EUR  25  billion  is  spent  per  year  in 
Denmark  on  public  procurement  of  goods  and  services, 
which  is  around  10%  of  GDP.  The  strategy  includes  a 
target that all public procurement on areas where official 
ecolabelling  schemes  exist  must  be  eco-labeled  or 
comply  with  corresponding  requirements  by  2030. 
Denmark  has  been  one  of  the  first  countries  to 
comprehensively assess the climate footprint from public 
procurement.  In  2019,  procurement  on  behalf  of  the 
government, municipal, and regional authorities resulted 
in  a  climate  footprint  totalling  approximately  12  million 
tons,  of  which  around  4  million  tons  were  emitted  in 
Denmark.  Based  on  the  assessment  made,  Denmark 
plans to set an emission reduction target in 202211. 

Denmark received a study visit using the EIR peer to peer 
tool on transferring knowledge and practice on setting up 
effective  repair  and  reuse  systems  24-25  September 
201812 to learn from Belgium’s experience. 

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

2022 priority actions 

  adopt  measures to increase the circular  material use 
rate,  and  lower  Domestic  Material  and  Raw  Material 
Consumption, learning from best EU practices. 

Waste management 

Turning waste into a resource is supported by:  
(i)  fully 
legislation,  which 
implementing  EU  waste 
includes  the  waste  hierarchy,  the  need  to  ensure 
landfill  diversion 
separate  collection  of  waste,  the 
targets, etc.;  
(ii) reducing waste generation and waste generation per 
capita in absolute terms;  
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
and  phasing  out  landfilling  of  recyclable  or  recoverable 
waste. 

11  Danish  Ministry  of  Finance,  Green  Procurement  for  a  Green  Future, 
2020, p.4. 
12 EIR peer to peer 

EU Ecolabel and the eco management and audit scheme 
(EMAS) 

The number of EU Ecolabel products and EMAS-licensed9 
organisations in a given country provides some indication 
of  the  extent  to  which  the  private  sector  and  national 
bodies are actively engaged in the transition to a circular 
shows  how  committed  public 
economy. 
authorities  are  to  supporting  schemes  designed  to 
promote the circular economy.  

It  also 

As of September 2021, Denmark had 2 465 products out 
of 83 590, and 81 licences out of 2 057, registered in the 
EU  Ecolabel  scheme,  showing  a  high  take-up  of  these 
schemes10. As of October 2021, 14 organisations from 48 
sites  in  Denmark  are  registered  in  the  EMAS  scheme.  
Since the last  report  in 2019, there has been 1 299 new 
product and 25 licences registrations of the EU Ecolabel, 
but  there  has  been  a  decrease 
in  the  number  of 
organisations  registered  with  EMAS,  by  14  organisations 
since 2019. 

8  European  Commission  -  Directorate-General  for  Environment  (DG 
ENV), Eco-innovation Observatory, Eco-innovation index. 
9  EMAS  is  the  European  Commission’s  Eco-Management  and  Audit 
Scheme, a programme to encourage organisations to behave in a more 
environmentally sustainable way. 
10European Commission, Ecolabel Facts and Figures. 

Environmental Implementation Review 2022 – Denmark 

 
 
 
  
                                                                 
 
 
                                                                 
This  section  focuses  on  the  management  of  municipal 
waste13  for  which  EU  law  sets  mandatory  recycling 
targets. 

resource  efficiency  and 

Preventing products and materials from becoming waste 
for  as  long  as  possible  is  the  most  efficient  way  to 
improve 
the 
environmental 
impact  of  waste.  Waste  prevention 
including re-use are the most preferred options; they top 
the  waste  hierarchy.  The  volume  of  municipal  waste 
generated  is  a  good  indicator  of  the  effectiveness  of 
waste prevention measures. 

reduce 

to 

After  a  stable  trend,  municipal  waste  generation  in 
Denmark has started to increase again in recent years. It 
amounted to 845 kg/year/inhabitant in 2020, the highest 
in the EU (EU average 505 kg/year/inhabitant), as Figure 
4 shows. It indicates that Denmark’s economic growth is 
not yet decoupled from waste generation. This is an issue 
of  waste  prevention.  In  the  2019  EIR  Denmark  had  two 
priority  actions  on  waste:  to 
introduce  new  policy 
instruments  to  promote  waste  prevention  and  recycling 
and to shift away from incineration. 

Figure  4:  Municipal  waste  by  treatment  in  Denmark, 
2011-20201914 

Denmark  7 

By  2019,  there  were  23  dedicated  and  multi-fired 
incineration  plants  in  Denmark,  of  which  17  plants  are 
municipally owned. It is expected that moving to private 
ownership will lead to an adjustment of the current over-
capacity  over  time.  This  may  lead  to  some  investment 
losses,  although  most  incineration  plants  are  more  than 
20 years old. No new plants are envisaged. In June 2020, 
Denmark decided that it must reduce  capacity for waste 
incineration  to  correspond  to  the  amount  of  residual 
waste from Denmark in 2030,  which entails an expected 
reduction in capacity by approximately 30% from 2020 to 
2030, and that the treatment  of residual waste  must  be 
sent out for tender in order to optimise waste treatment 
both  environmentally  and  economically15.  Thus,  it  is 
assessed  that  there  is  a  need  to  close  several  municipal 
incineration plants  – corresponding to the expected need 
for  domestically  generated 
for 
residual waste in 2030. As part of this political agreement 
DKK  200  million  are  reserved  for  stranded  assets  in 
incineration plants16. 

incineration  capacity 

Figure  5  and  national  projections17  shows  that  Denmark 
is  moving  towards  the  EU’s  2025  municipal  waste 
recycling  target  of  55%,  as  53.9%  in  2020  was  recycled 
(EU  average  (47.8%)).    The  EU  action  plan  for  circular 
economy includes a number of targeted policy initiatives 
to ensure compliance with the 2025 targets.  

The level of recycling in Denmark is not directly linked to 
the  level  of  investments  in  recycling  plants  in  Denmark. 
As  a  small  open  economy  most  of  Denmark’s  recyclable 
waste is exported to neighbouring Sweden and Germany 
for  material  recycling.  Waste  exported  to  be  recycled 
abroad  still  counts  towards  towards  Denmark’s  overall 
recycling rate so exporting waste to be recycled does not 
inherently limit improving a country’s recycling rate. 

Figure 5: Recycling rate of municipal waste, 2011-202018 

Figure  4  also  shows  municipal  waste  by  type  of 
treatment,  in  kilos  produced  per  person.  Much  of  the 
waste  in  Denmark  is  incinerated  with  energy  recovery 
(382 kg per person in 2020).  

13 municipal waste consists of (a) mixed waste and separately collected 
waste  from  households,  including  paper  and  cardboard,  glass,  metals, 
plastics,  bio-waste,  wood,  textiles,  packaging,  waste  electrical  and 
electronic  equipment,  waste  batteries  and  accumulators,  and  bulky 
waste, 
including  mattresses  and  furniture;  (b)  mixed  waste  and 
separately  collected  waste  from  other  sources,  where  such  waste  is 
similar in nature and composition to waste from households. (Directive 
2008/98/EC, Article. 3 2b). 
14 Eurostat, Municipal waste by waste operation, april 2022. 

15 Climate plan for a green waste sector and circular economy 
16 Ramboll, Evaluation report for assessing the waste  
management plan of Denmark. Final draft 22.12.2021 
17 Danish Environmental Protection Agency, Baseline projection  
18 Eurostat, Recycling rate of municipal rate, April 2022. 

Environmental Implementation Review 2022 – Denmark 

 
 
 
                                                                 
 
                                                                 
Denmark  8 

implemented  door  to  door  collection  within  walking 
distance  from  houses  (depending  on  the  logistics  of  the 
area) for nine fractions of household waste. 

However,  Denmark  must  take  more  action  to  ensure 
compliance  with  the  recycling  targets  for  the  post-2020 
period.  Therefore,  only  limited  progress  was  made  on 
both  priority  actions  since  2019,  and  in  the  light  of  the 
Early  Warning  Report  2022  they  are  repeated.  National 
plans,  programmes  and  strategies  also  need  to  be 
implemented.  

2022 priority actions 

  Bring  in  new  policy  instruments,  including  economic 
instruments.  These  instruments  should:  (i)  promote 
waste prevention; (ii) make preparing for waste reuse 
and recycling more economically attractive. 

  Shift  reusable  and  recyclable  waste  away  from 

incineration with energy recovery. 

listed 

Denmark  was  not 
in  the  Commission's  Early 
Warning report'19  at risk of missing the EU 2020 target of 
50 %  collected  for  recycling  of  municipal  waste.  The 
Commission  is  currently  finalising  its  analysis  of  the 
progress  on  the  recommendations  from  the  2018  Early 
Warning  Reports  and  analysis  of  progress  towards 
achieving  the  2025  waste  recycling  targets.  This  report 
will be presented at the end of 2022 and will assess the 
progress made to date. 

Implementation of the 2018 waste legislative package 

Denmark  has  notified  the  Commission  that 
it  has 
transposed  the  2018  waste  package.  A  conformity 
assessment is now ongoing. 

Waste  management  plans  and  waste  prevention 
programmes  (referred  to  in  the  section  on  circular 
economy)  are  instrumental  for  a  sound  implementation 
of  the  EU  waste  legislation.  They  set  out  key  provisions 
and investments to ensure compliance with existing and 
new 
legal  requirements  (e.g.  on  waste  prevention, 
separate  collection  for  a  number  of  specific  waste 
streams, recycling and landfill targets). Revised plans and 
programmes were due on 5 July 2020.  

Denmark’s  revised  waste  management  plan  &  waste 
prevention  programme  from  July  2021  is  acceptable20. 
The plan aims to reduce waste generation and shift away 
from  incineration  with  energy  recovery  as  there 
is 
overcapacity  and    towards  more  recycling.  Denmark  has 

19  European  Commission,  Report  on  the  implementation  of  waste 
legislation, including the early warning report for Member States at risk 
of missing the 2020 preparation for re-use/recycling target on municipal 
wasteCOM(2018)656. 
20  Danish  Ministry  of  Environment,  Handlingsplan-for-cirkulaer-
oekonomi 

Environmental Implementation Review 2022 – Denmark 

 
 
 
                                                                 
 
 
 
Denmark  9 

2. Biodiversity and natural capital 

The 2030 EU biodiversity strategy adopted in May 2020 
aims to put the EU’s biodiversity on a path to recovery 
and  sets  out  new  targets  and  governance  mechanisms 
to achieve healthy and resilient ecosystems.  
In particular, the strategy sets out ambitious targets to: 
(i) protect a minimum of 30% of the EU’s land area and 
30% of its sea area and integrate ecological corridors, as 
part of a true trans-European nature network;  
(ii) strictly protect at least a third of the EU’s protected 
areas,  including  all  remaining  EU  primary  and  old-
growth forests;  
(iii)  effectively  manage  all  protected  areas,  defining 
clear  conservation  objectives  and  measures,  and 
monitoring them appropriately.  
The strategy also sets out an EU nature restoration plan 
–  a  series  of  concrete  commitments  and  actions  to 
restore  degraded  ecosystems  across  the  EU  by  2030, 
and  manage  them  sustainably,  addressing  the  key 
drivers of biodiversity loss. 

The Habitats and the Birds Directives are key legislative 
tools  to  achieve  the  EU  biodiversity  strategy  targets. 
They  are  the  cornerstone  of  EU  legislation  governing 
wildlife conservation21.  

Denmark’s national biodiversity strategy is entitled ‘The 
Danish Nature Policy — Our Shared Nature’22. Adopted 
in  2014,  it  contains  a  long-term  vision  for  2050  and 
serves  as  Denmark’s  revised  national  biodiversity 
strategy  and  action  plan.  In  2020  there  was  a  political 
agreement on nature and biodiversity23 and in 2021 on 
green cities24. 

Nature protection and restoration  

Natura  200025,  the  largest  coordinated  network  of 
protected  areas  in  the  world,  is  the  key  instrument  to 
achieve  the  Birds  and  Habitats  Directives'  objectives  to 
ensure  the  long  term  protection,  conservation  and 
survival  of  Europe's  most  valuable  and  threatened 

21  These  should  be  reinforced  by  the  Nature  Restoration  Law, 
according to the  EU’s new biodiversity strategy. 
22 Danish Nature Policy – our share nature 
23 Political agreement on nature and biodiversity. 
24 Political agreement on green cities. 
25  Natura  2000  comprises  Sites  of  Community  Importance  (SCIs) 
designated  pursuant  to  the  Habitats  Directive  as  well  as  Special 
Protection  Areas  (SPAs)  classified  pursuant  to  the  Birds  Directive; 
figures of coverage do not add up due to the fact that some SCIs and 
SPAs  overlap.  Special  Areas  of  Conservation  (SACs)  means  a  SCI 
designated by the Member States. 

species and habitats and the ecosystems they underpin. 
The setting up of a coherent Natura 2000 network, the 
designation  of  Sites  of  Community  Importance  (SCI)  as 
Special  Areas  of  Conservation  (SAC)  and  the  setting  of 
conservation  objectives  and  measures  for  the  Natura 
2000  sites  are  key  milestones  towards  meeting  the 
objectives of the Directives. 

Setting up a coherent network of Natura 2000 sites 

Denmark  hosts  60  habitat  types26  and  79  species27 
covered  by  the  Habitats  Directive.  The  country  also 
hosts  populations  of  54  bird  taxa  listed  in  Annex  I  the 
Birds Directive28. 

By  2021,  8.3%  of  Denmark’s  territory  was  covered  by 
Natura  2000  (against  the  EU  average  of  18.5%),  see 
Figure  7.  Special  Protection  Areas  (SPAs)  classified 
under  the  Birds  Directive  covered  6%  (against  the  EU 
average of 12.8%) and SCIs under the Habitats Directive 
covered 7.4 % (EU average 14.2%) of Danish territory. 

The  latest  assessment  of  the  SPA  part  of  the  Natura 
2000 network shows that  Demark’s  designation of   the 
network  of  marine  SPAs  was  insufficient  to  cover 
(IBAs).  The  Danish 
several 
government  on  12  November  2021,  with  an  Order  No 
2091, proceeded with the designation of 6 new SPAs29, 
and  promised  6  December  2021  to  look  further  at 
appointing additional marine areas as SPAs. 

important  bird  areas 

The Danish government initiated in 2018 a procedure to 
adjust the boundaries of the sites within its Natura 2000 
network.  This  procedure 
still  ongoing.  The 
Commission will be able to finalise its assessment after 
receiving full justifications for each proposed change. 

is 

Considering  both  Natura  2000  and  other  nationally 
designated  protected  areas,  Denmark  legally  protects 
15.1%  of  its  territory  (against  the  EU  27  average  of 
26.4%)  and  18,7%  of  marine  areas  (against  the  EU  27 
average of 10.7%)30. Figure 6 shows the situation at EU 

26 EEA, Article 17 dashboard, Annex I total, 2019. 
27  EEA, Article  17  dashboard,  Annex  II  &  Annex  IV  excluding  those  in 
Annex  II  &  Annex  V  excluding  those  in  Annex  II,  2019.  This  counting 
only takes into account species and habitats for which assessment of 
conservation status was requested. 
28  EEA,  Article  12  dashboard,  Annex  I,  2020.  This counting  only  takes 
into account birds taxa for which information was requested. 
29 Danish Ministry of Environment, 2021 
30  EEA, Protected Areas,  terrestrial  protected area percentage  (2021) 
and marine protected area percentage (2019), March 2022. 

Environmental Implementation Review 2022 – Denmark 

 
 
                                                                 
 
                                                                 
level  for  land  and  marine  sites  to    meet  the  EU’s 
biodiversity strategy 2030 target of 30%. 

Figure 6: Marine & terrestrial protected area coverage, 
202131  

Figure  7:  Natura  2000  terrestrial  protected  area 
coverage, 202132  

Denmark  10 

of  these  sites.  However,  the  quality  of  the  current  
conservation objectives and measures is insufficient and 
will be updated in 2022/23. Moreover, the management 
plans  are  not  sufficiently  linked  with  other  applicable 
legislation  to  tackle  agriculture  emissions  which  exert 
high  pressure  on  species  and  habitats.;  these  aspects 
will  also  be  a  part  of  the  coming  plans,  which  were  in 
public consultation in spring 2022. 

Progress in maintaining or restoring favourable 
conservation status of species and habitats 

The  results  of  Habitats  Directive  Article  17  and  Birds 
Directive  Article  12  reports  on  progress  towards 
maintaining  or  restoring  the  favourable  conservation 
status  of  species  and  habitats  are  key  to  measure  the 
performance of Member States. 

According  to  the  report  submitted  by  Denmark  on  the 
conservation  status  of  habitats  and  species  covered  by 
Article 17 of the Habitats Directive for the period 2013-
2018,  the  share  of  assessments  for  habitats  in  good 
conservation  status  in  2018  is  only  5%  which  is  the 
second  lowest  in  the  EU  and  the  same  as  the  number 
reported  under  the  previous  reporting  period  (2007-
2012),  see  Figure  8.  As  to  protected  species,  the  share 
of  assessments  in  good  conservation  status  in  2018  is 
20%  which  is  less  than  the  32%  reported  under  the 
previous reporting period (2007-2012), see Figure 9. 

The  bird  conservation  results  with  54%  show  that  the 
population  of breeding  species was either increasing in 
the  short  term  or  stable  (for  wintering  species  this 
figure was 27%). 

The  share  of  habitats  in  bad  conservation  status  has 
remained  at  77%  and  the  share  of  assessments  for 
species in bad conservation status has increased to 34%, 
as shown in Figure 833.. The main pressures come from 
agriculture,  mixed  sources  of  pollution,  development, 
construction  and  use  of  residential,  commercial, 
industrial  and  recreational  infrustructure  and  alien  and 
problematic species. 

Designating Special Areas of Conservation (SACs) and 
setting conservation objectives and measures 

All SCIs have been designated as SACs and conservation 
objectives and  measures have been drawn up for each 

31  EU  Biodiversity  Strategy  Dashboard,  indicators  A1.1.1  and  A1.2.1, 
February 2022. 
32 EEA, February 2022.Natura 2000 Barometer, February 2022. 

33 EEA, State of Nature in the EU 2021. 

Environmental Implementation Review 2022 – Denmark 

 
 
 
 
                                                                 
                                                                 
Figure  8:  Assessments  on  conservation  status  for 
habitats  for  2007-2012  and  2013-2018  reporting 
periods34  

Denmark  11 

species  where  there  has  been  no  progress;  thus  it  is 
repeated. The second was to put in place clearly defined 
conservation  measures 
for  sites,  and  to  provide 
adequate resources; on the first aspect  there is limited 
progress  since  the  management  plans  for  the  new 
planning  period  to  put 
in  place  clearly  defined 
conservation  objectives  and  measures  were  in  public 
consultation  in  spring  2022;  on  the  second  aspect, 
considering that Denmark has not submitted a complete 
priotised  action  framework  (see  section  5),  a  new 
priority action is included. 

2022 priority actions 

Figure  9:  Assessments  on  conservation  status  for 
species for 2007-2012 and 2013-2018 reporting periods 
35 

 

 

 

the  update  of 

increase  efforts  to  ensure  that  the  Natura  2000 
network  is  managed  in  a  way  that  achieves  the 
favourable  conservation 
status  of  protected 
habitats  and  species,  especially  by  reducing  main 
pressures such as from agriculture. 
finalize 
the  Natura  2000 
management  plans  to  be  adopted  for  the  next 
planning  cycle  to  ensure  that  their  conservation 
objectives  and  measures  are  clearly  defined, 
linked  with  other 
sufficiently  detailed  and 
applicable 
to  achieve 
favourable conservation status. 
complete and submit a finalised PAF. 

legislation  and  plans 

Bringing nature back to agricultural land and restoring 
soil ecosystems 

Agricultural land 

The biodiversity strategy works alongside the new farm 
to fork strategy and the new common agricultural policy 
(CAP)  to  support  and  achieve  the  transition  to  fully 
sustainable agriculture.  
The  biodiversity  and  farm  to  fork  strategies  have  set 
four important targets for 2030:  
- a 50% reduction in the overall use of – and risk from – 
chemical pesticides; 
-  a  50%  reduction  in  the  use  of  more  hazardous 
pesticides; 
-  a  50%  reduction  in  losses  of  nutrients  from  fertilisers 
while  ensuring  there  is  no  deterioration  of  soil  fertility 
(which  will  result  in  a  20%  reduction  in  the  use  of 
fertilisers);  
- bring back at least 10% of agricultural area under high-
diversity  landscape  features  and  increase  areas  under 
organic farming to at least 25%. 

Denmark has used LIFE for nature projects for example 
the Better BirdLife36 and Open Woods37 projects. 

Denmark had two priority actions in 2019. The first was 
to  achieve  favourable  conservation  for  habitats  and 

34  EEA,  Conservation  status  and  trends  of  habitats  and  species, 
December  2021.  Please  note  when  comparing  the  figures  shown  for 
2007-2012  and 2013-2018  these  may  also  be  affected by  changes of 
methods or due to better data availability. 
35  EEA,  Conservation  status  and  trends  of  habitats  and  species, 
December  2021.  Please  note when  comparing  the  figures  shown  for 
2007-2012  and 2013-2018  these  may  also  be  affected by  changes of 
methods or due to better data availability. 
36 LIFE Better BirdLife 
37 LIFE Open Woods 

Environmental Implementation Review 2022 – Denmark 

 
 
 
 
 
                                                                 
Denmark  12 

taken per year in the period 2012-2018 can be seen as a 
measure  of  one  important  pressure  on  nature  and 
biodiversity - land use change - which constitutes at the 
same  time  an  environmental  pressure  on  people  living 
in urbanised areas.   

Despite  falling  during  the  last  decade  (land  take  was 
over  1000km2/year  between  2000-2006),  land  take  in 
EU28  still  amounted  to  539km2/year  between  2012-
201843.  The  net  land  take  concept  combines  land  take 
with the share of land returned to non-artificial land use 
(re-cultivation).  While  some  land  was  re-cultivated  in 
the EU28 in the period 2000-2018, 11 times more land 
was taken.   

Denmark ranks above the EU average on land take with 
net 
land  take  of  152.8m2/km2  2012-2018  (EU27 
average: 83.8 m2/km2). 44.  

its  reporting  on 

In  2018,  Denmark  updated 
land 
degradation  in line  with   the next Performance Review 
and 
reporting 
platform45. It includes  actions intended to combat land 
degradation . 

Implementation  System 

(PRAIS3) 

However,  Denmark  has  not  yet  committed  to  set  land 
degradation neutrality targets under the United Nations 
Convention to Combat Desertification (UNCCD) 46. 

The  RRP  for  Denmark  provides  EUR  89  million  for  a 
reform  to  take  4  700ha  of  carbon  rich  soil  out  of 
production  and  EUR  38  million  for  an  investment  to 
rehabilitate four sites. 

Denmark  has  an  estimated  11.45%  of  area  under 
organic farming, slightly above the EU average of 9,07% 
(2020)38, see Figure 10.  

Figure  10:  Share  of  total  utilised  agricultural  area 
occupied by organic farming per Member State39 

The  agricultural  sector  in  Denmark  has  a  level  of  high 
productivity.  However, 
intensive  farming  generates 
negative impacts on the environment and climate, such 
as nutrient leaching, GHG emissions, loss of habitats and 
biodiversity40. The farmland bird index  fell from 79.3 in 
2011 to 72 in 2019 (2000 = 100)41. 

Soil ecosystems   

soil 

new 

strategy, 

Soil  is  a  finite  and  extremely  fragile  resource.  It  is 
increasingly degrading in the EU. 
on 
adopted 
EU 
The 
17 November 2021,  stresses  the 
importance  of  soil 
protection,  of  sustainable  soil  management  and  of 
restoring  degraded  soils  to  achieve  the  Green  Deal 
objectives  as  well  as  land-degradation  neutrality  by 
2030.  
This entails:  
(i) preventing further soil degradation;  
(ii)  making  sustainable  soil  management  the  new 
normal;  
(iii) taking action for ecosystem restoration. 

One example of soil degradation is the area of soil that 
is  sealed  or  artificialised42  (Figure  11).  The  net  land 

38 Eurostat, organic farming 
39 Eurostat, Area under organic farming, February 2022. 
40 Commission Reccomendations for Denmark’s CAP Plan, 2021 
41 Eurostat Farmland Bird Index. 
42 Artificial  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). 
43 EEA Land take and recultivation in Europe  
44  EEA  Land  take  and recultivation;  fig  6;  Net  land take  =  land take  + 
recultivation. 
45 UNCCD, Prais3 
46 UNCCD, The LDN Target Setting Programme 

Environmental Implementation Review 2022 – Denmark 

 
 
 
                                                                 
 
                                                                                                      
 
Figure  11:  Land  take  and  re-cultivation 
(m2/km2), 2012-201847 

in  EU27 

Denmark  13 

situation of forest habitats protected under the Habitats 
Directive  is  particularly  worrying  in  Denmark  as  more 
than half of the assessed protected forests are in a bad 
status (Figure 12)51. 

Figure  12:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  in  EU  Member  States, 
2013-2018 (% assessments)52 

Forests and timber 

The EU Forest Strategy for 2030 adopted in July 2021 is 
a part of the Fit for 55 Package. The Strategy promotes 
the many services that forests provide. Its’ key objective 
is  to  ensure  healthy,  diverse  and  resilient  EU  forests, 
that 
strengthened 
significantly 
biodiversity and climate ambition.  
Forests  are 
their 
important  carbon 
conservation  efforts  are  vital  for  the  EU’s  vision  of 
achieving climate neutrality by 2050.  

sinks  and 

contribute 

to 

Of  the  27%  of  EU  forest  area  protected  under  the 
Habitats Directive, less than 15% of areas assessed were 
found  to  be  in  a  favourable  conservation  status48.  The 
share  of  forest  area  in  the  EU  in  a  bad  conservation 
status increased from 27% in 2015 to 31%. 

In  Denmark,  forests  cover  12.19%  of  land49  with  21 
000ha  in  Denmark  covered  by  primary  forests50.  The 

In  accordance  with  the EU  Timber  Regulation  (EUTR)53, 
which  prohibits    placing  illegally  harvested  timber  on 
the  EU  market,  EU  Member  States  competent 
authorities  must  conduct  regular  checks  on  operators 
and  traders,  and  apply  penalties  for  any  breaches.  By 
amending    Article  20  of  the  EUTR,  biennial  reporting 
became annual and covers the calendar year as of 2019. 

In  the  period  March  2017  -  February  201954,  Denmark 
carried out 49 checks on operators importing timber. It 
is estimated that Denmark had 24 000 operators placing 
domestic  timber  and  3 889 operators placing imported 
timber  onto  the  internal  market  over  the  reporting 
period. 

The  new  Deforestation  Regulation38  will  repeal  and 
replace  the  EU  Timber  Regulation,  as  it  will  essentially 
integrate  and  improve  the  existing  system  to  control 
timber legality. 

Denmark  hosted  an  EIR  peer  to  peer  study  visit  on  
implementation  of  the  EUTR,  29  October2018.  It  also 
participated  in  a  Workshop  of  the  EUTR  Nordic  Baltic 
Competent Authorities 17-19 June2019. 

47 EEA, Land Take in Europe. 
48 EEA, State of Nature in the EU 
49  EEA,  Forest  information  system  for  Europe;  Denmark  uses  FAO 
National Forest Inventory data which gives a higher figure of 14.7%. 
50 JRC, Mapping and assessment of primary and old-growth forests in 
Europe,  p.  13;  Denmark  uses  another  source,  Sabatini  et  al,  2018, 
which gives a much lower figure of 1690 ha. 

51 EU Forest Strategy 2030 Staff Working Document.  
52 EEA, Conservation status and trend in conservation status by habitat 
group - forests, January 2022. 
53Regulation  (EC)  No  2173/2005  of  20  December  2005  on  the 
establishment of a FLEGT licensing scheme for imports of timber into 
the European Community. 
54 Commission report 2020 on EU Timber Regulation  

Environmental Implementation Review 2022 – Denmark 

 
 
 
 
                                                                 
 
 
                                                                 
Denmark  14 

been  observed  in  the  environment  in  Denmark.  The 
spread can be checked in Figure 13. 

Denmark  had  a  priority  action  in  2019  to  remedy  the  
lack  of  data,  and  seek  ways  to  improve  its  surveillance 
system. In the 2019 Article 24 report, it is indicated that 
in  Denmark,  there  is  a  registration  website  for  IAS  for 
citizens to register observations, which are then verified 
by  the  Danish  Environmental  Protection  Agency.  These 
data  are  especially  important  for  rapid  eradication 
actions.  Additionally,  Denmark  has  a  national 
programme (NOVANA) for surveillance of IAS, and when 
new species are added to the EU list, they are included 
in  the  programme.  Moreover,  IAS  are  included  in 
several  surveillance  projects,  e.g.,  altas  projects,  and 
projects  using  new  technologies,  such  as  eDNA  and 
satellite data. 

Figure  13:  Number  of  IAS  of  EU  concern,  based  on 
available  georeferenced 
information  for  Denmark, 
2021 

Marine ecosystems 

The  EU  Biodiversity  Strategy 
for  2030  aims  to 
substantially  reduce  the  negative  impacts  on  sensitive 
species  and  habitats  in  marine  ecosystems  and  to 
achieve good environmental status as well as eliminate 
or 
incidental  catches  of  protected, 
endangered, threatened and sensitive species to a level 

reduce 

the 

Invasive alien species (IAS) 

in 

and 

land 

changes 

IAS  are  a  key  cause  of  biodiversity  loss  in  the  EU 
(alongside 
use, 
sea 
overexploitation, climate change and pollution).  
Besides  inflicting  major  damage  on  nature  and  the 
economy,  many  IAS  also  facilitate  the  outbreak  and 
spread of infectious diseases, posing a threat to humans 
and wildlife.  
The  implementation  of  the  EU  Invasive  Alien  Species 
Regulation  and  other  relevant 
legislation  must  be 
stepped up.  
The  biodiversity  strategy  for  2030  aims  to  manage 
recognised  invasive  alien  species  and  decrease  the 
number of ‘red list’ species they threaten by 50%. 

The core of Regulation (EU) 1143/2014 on invasive alien 
species. (the IAS Regulation55) is the list of Invasive Alien 
Species  of  Union  concern.  There  are  currently  66 
invasive alien species (IAS) of EU concern , of which: 30 
are  animal  species  and  36  are  plant  species;  41  are 
primarily  land  species,  23  are  primarily  freshwater 
species, 1 is a brackish-water species and 1 is a  marine 
species.  
A 2021 report56 on the review of the application of the 
IAS  Regulation  based  on  reports  that  Member  States 
submitted  for  the  period  2015-2018,  showed  the 
implementation of the IAS Regulation is already starting 
its  objectives  such  as  a  coherent 
to  deliver  on 
framework  for  addressing  IAS  at  EU  level  and  has 
increased  awareness  of  the  problem  of  IAS,  including 
among the general public. At the same time, the above 
for 
report 
for 
improvement.  Given 
deadlines 
implementing  the  various  obligations  of  the 
IAS 
Regulation applied gradually between July 2016 and July 
2019,  it  is  premature  to  draw  conclusions  on  several 
aspects of the implementation of the IAS Regulation. 

identified  some  challenges  and  areas 

that 

the 

Another  2021  report57  on  the  baseline  distribution 
shows that of the 66 species on the Union list, 18 have 

55  Regulation  (EU)  No  1143/2014  of  the  European  Parliament  and  of 
the Council of 22 October 2014 on the prevention and management of 
the introduction and spread of invasive alien species 
56  Report  from  the  Commission  to  the  European  Parliament  and  the 
Council  on  the  review  of  the  application  of  Regulation  (EU)  No 
1143/2014  of  the  European  Parliament  and  of  the  Council  of  22 
October 2014 on the prevention and management of the introduction 
and spread of invasive alien species, COM(2021) 628 final, 13.10.2021 
57  Cardoso  A.C.,  Tsiamis  K.,  Deriu  I.,  D'  Amico  F.,  Gervasini  E.,  EU 
Regulation  1143/2014:  assessment  of  invasive  alien species of  Union 
concern  distribution,  Member  States  reports  vs  JRC  baselines,  EUR 
ISBN  978-92-76-37420-6,  doi:10.2760/11150, 
30689  EN,  2021, 
JRC123170. 

Environmental Implementation Review 2022 – Denmark 

 
 
                                                                 
 
 
 
Denmark  15 

Figure  14:  Level  of  adequacy  of  GES  determination  by 
Denmark (ANS and BAL regions) with criteria set under 
the  Commission  GES  Decision  -  Article  9  (2018 
reporting exercise)62 

that allows species recovery and conservation58. 

The  Marine  Strategy  Framework  Directive  (MSFD)59 
requires Member States to achieve good environmental 
status  (GES)  of  their  marine  waters.  To  that  end, 
Member States must develop marine strategies for their 
marine  waters,  and  cooperate  with  Member  States 
sharing  the  same  marine  regarion  or  subregion.  These 
marine  strategies  comprise  different  steps  to  be 
developed and implemented over six-year cycles. 

Among  other  obligations,  the  MSFD  requires  Member 
States  by  15  October  2018  to  define  a  set  of  GES 
characteristics  for  each  descriptor  (Article  9),  and  to 
provide  an  initial  assessment  of  their  marine  waters 
(article  8).  The  Commission  then  assesses  whether  this 
constitutes  an  appropriate  framework  to  meet  the 
requirements of the Directive. 

Denmark’s 

Commission 

The 
2018 
assessed 
determinations of GES for each of the 11 descriptors in 
the  MSFD60  and  determined  their  adequacy  in  relation 
to the Commission GES Decision61. A good or very good 
score indicates that the national GES determinations are 
well aligned with the requirements of the GES Decision, 
and  quantitative  national 
providing  qualitative 
environmental  objectives  to  be  achieved  for  their 
marine waters (Figure 14). 

Denmark has two marine sub-regions: 

ANS-NE  Atlantic,  the  Greater  North  Sea.  In  this  sub-
region, 6 out of 11 determinations of GES were assessed 
as good or very good63. Denmark’s assessment of GES is 
coherent with the MSFD for 6 out of 11 descriptors. 

BAL,  the  Baltic  Sea.  In  this  marine  sub-region,  4  out  of 
11 determinations of GES were assessed as good or very 
good.  Denmark’s  assessment  of  GES  is  coherent  with 
the MSFD for 4 out of 11 descriptors. 

The  MSFD  also  requires  that  Member  States  make  an 
assessment of the current environmental status of their 
marine  waters  in  relation  to  the  GES  determination.  A 
good  or  very  good  score  indicates  that  the  Member 
State  has  good  capabilities  to  assess  their  marine 
environment  in  accordance  with  the  requirements  set 
out in the Commission GES Decision (Figure 15). 

58  The  EU  Common  Fisheries  Policy  (CFP)  aims  to  contribute  to  the 
achievement  of  the  objectives  of  the  environmental  legislation  for 
marine ecosystems. 
59 Marine Strategy Framework Directive 2008/56/EC 
60 Annex I to Directive 2008/56/EC. 
61  Commission  Decision  (EU)  2017/848  laying  down  criteria  and 
methodological  standards  on  the  good  environmental  status  of 
marine  waters  and  specifications  and  standardised  methods  for 
monitoring and assessment, and repealing Decision 2010/477/EU. 

62  Assessment  carried  out  by  the  European  Commission  of  the  data 
reported by the Member States, January 2022. Please note that only 
two sub-sections of descriptor D1 are displayed (D1-M Mammals and 
D1-B Birds). For the analysis, these two sub-sections were considered 
as a whole after averaging them.  
63Only one part of D1 (Mammals) and D2-D11 are displayed. 

Environmental Implementation Review 2022 – Denmark 

 
 
                                                                 
 
                                                                 
Figure 15: Level of adequacy of national assessment of 
Denmark’s marine environment (ANS and BAL regions) 
with criteria set under the Commission GES Decision - 
Article 8 (2018 reporting exercise)64 

Denmark  16 

Furthermore, in March 2022, the European Commission 
published a Communication  with recommendations for 
Member States. The Commission assessment  highlights 
that  Member  States  need  to  step  up  their  efforts  to 
determine  the  good  environmental  status  and  the  use 
of  the  criteria  and  methodological  standards  according 
to 
the  Commission  GES  Decision.  The  above 
considerations  form  the  basis  for  the  2022  priority 
actions. 

2022 priority actions 

 

  ensure  regional  cooperation  with  Member  States 
sharing the same marine (sub)region to address  the 
main environmental  pressures; 
implement  the  recommendations  made  by  the 
the  staff  working  document66 
Commission 
Communication67 
accompanying 
on 
the 
recommendations per Member States and region on 
the 2018 updated reports for Articles 8, 9 and 10 of 
the MSFD. 

in 

In  the  marine  sub-region  ANS-NE  Atlantic,  the  Greater 
North Sea, 6 descriptors out of 11 were scored as good 
or  very  good.  Denmark’s  assessment  of  its  marine 
environment  is  coherent  with  the  requirements  set 
under  the  Commission  GES  Decision  for  6  out  of  11 
descriptors. 

Ecosystem assessment and accounting  

The  EU  biodiversity  strategy  for  2030  calls  on  Member 
States  to  better  integrate  biodiversity  considerations 
into  public  and  business  decision  making  at  all  levels 
and to develop natural capital accounting. The EU needs 
a  better  performing  biodiversity-observation  network 
and  more  consistent  reporting  on  the  condition  of 
ecosystems.  

In  the  marine  sub-region  BAL,  the  Baltic  Sea,  7 
descriptors out of 11 were scored as good or very good. 
Denmark’s  assessment  of  its  marine  environment  is 
coherent  with 
the 
Commission GES Decision for 7 out of 11 descriptors. 

requirements  set  under 

the 

In  the  2019  EIR,  Denmark  had  a  priority  action  to 
achieve  timely  reporting  under  the  MFSD.  It  has  made 
limited  progress  on  this  with  several  descriptors 
missing. 

As  highlighted  in  the  Commission’s  report  on  the 
implementation  of  the  MSFD65,  although  regional 
cooperation  has  improved  since  the  adoption  of  the 
MSFD,  more  cooperation 
is  needed  to  meet  the 
requirements  under  the  Directive  of  full  regional 
coherence of the marine strategies.  

report  was  published 

As  mentioned  in  the  2019  EIR,  Denmark  has  been 
involved  with  MAES68  since  2014  in  collaboration  with 
in  201769  
universities.  A 
illustrating the synergies and trade-offs for six different 
scenarios  between 
services  and 
biodiversity. A case study also showed that it is possible 
to  combine  existing  spatial  data  layers  and  models  to 
facilite  analyses  of  the  effects  of  land  use  changes 
across  many  ecosystem  services  and  biodiversity 
indicators.  A  follow  up  project  on  two  modelling 
components has been carried out70. 

six  ecosystem 

No  progress  has  been  recorded  since  January  2016 
is  based  on  27 
(Figure  16).  This  assessment 
implementation  questions,  updated  every  six  months. 
Progress  on  ecosystem  accounting  implementation  is 
assessed at national level based on 13 questions. 

64  Assessment  carried  out  by  the  European  Commission  of  the  data 
reported by the Member States, January 2022. Please note that only 
two sub-sections of descriptor D1 are displayed (D1-M Mammals and 
D1-B Birds). For the analysis, these two sub-sections were considered 
as a whole after averaging them.  
65 COM(2020)259 

66 SWD(2022)1392. 
67  COM(2022)550. 
68 Mapping and Assessment of Ecosystems and their Services. 
69 Aarhus University report 
70 Termansen M et al. 

Environmental Implementation Review 2022 – Denmark 

 
 
                                                                 
                                                                 
Figure 16: ESMERALDA MAES Barometer (January 2016 
- March 2021)71 

Denmark  17 

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

2022 priority actions 

 

Continue  supporting  the  mapping  and  assessment 
of  ecosystems  and  their  services,  and  ecosystem 
accounting  development, 
through  appropriate 
indicators 
integrating  ecosystem  extent, 
for 
condition  and  services  (including  some  monetary 
values) into national accounts; continue supporting 
the  development  of  national  business  and 
biodiversity  platforms, 
including  natural  capital 
accounting  systems  to  monitor  and  value  the 
impact of business on biodiversity. 

71 European Commission, Joint Research Centre, Publication Office, EU 
Ecosystem  assessment:  summary  for  policymakers,  page  80,  May 
2021. 

Environmental Implementation Review 2022 – Denmark 

 
 
 
                                                                 
Denmark  18 

3. Zero pollution 

Clean air 

its 

EU  clean-air  policies  and  legislation  need  to  significantly 
improve air quality in the EU, moving the EU closer to the 
quality recommended by the WHO and curbing emissions 
of key air pollutants.  
Air  pollution  and 
impacts  on  ecosystems  and 
biodiversity  should  be  further  reduced  with  the  long-
term  aim  of  not  exceeding  critical  loads  and  levels.  This 
requires  strengthening  efforts  to  reach  full  compliance 
with EU clean-air legislation and defining strategic targets 
and actions for 2030 and beyond.  
The 2030 zero-pollution action-plan targets are to reduce 
the health impacts of air pollution by 55% and to reduce 
the  EU  ecosystems  threatened  by  air  pollution  by  25%, 
compared to 2005.  

2020  to  2029  and  from  2030  onwards.  Latest  inventory 
data  submitted  by  Denmark,  prior  to  review  by  the 
Commission, indicate that Denmark is in compliance with 
the  emission  reduction  commitments  for  NOx,  NMVOC, 
SO2 and PM2.5, and in non-compliance with the emission 
reduction commitment for NH3 in 2020.  

Denmark  has  submitted  a  National  Air  Pollution  Control 
Programme on 1 April 2019 and an update on 11 August 
2021. 

Figure  17:  Emission  trends  of  main  pollutants/GDP  in 
Denmark, 2005-201979 

The  EU  has  developed  a  comprehensive  suite  of  air 
quality  legislative  measures,  which  set  health-based  air 
reduction 
and 
quality 
commitments73  per  Member  State  for  a  number  of  air 
pollutants.  

standards72 

emission 

Air quality in Denmark is generally good with exceptions. 
The  latest  available  annual  estimates  by  the  European 
Environment  Agency  (for  2019)74  indicate  about  2  900 
premature  deaths  (or  30  700  years  of  life  lost  (YLL)) 
attributable  to  fine  particulate  matter  concentrations75 
and 150 (1600 YLL) to ozone concentrations7677.  

The  emissions  of  key  air  pollutants  have 
fallen  
significantly  in  Denmark  over  the  last  years,  while  GDP 
growth continued (see Figure 17). According to the latest 
projections  as  submitted  under  Article  10(2)  of  the 
National  Emission  Reduction  Commitments  Directive 
(NECD)78,  Denmark  expects  to  reach 
its  emission 
reduction commitments for SOx, NOx and NMVOC for the 
period  2020  to  2029  and  from  2030  onwards.  The 
projections  however  do  not  demonstrate  reaching 
emission  reduction  commitments  for  NH3  and  PM2.5  for 

Figure  18  shows  the  emissions  of  PM2.5  and  NOx  by 
economic sector. 

Figure  18:  PM2.5  and  NOx  emissions  by  sector  in 
Denmark (2019)80 

72 European Commission, 2016. Air Quality Standards 
73European Commission, Reduction of National Emissions 
74  EEA,  Air  Quality  in  Europe  –2021  Report.  Please  see  details  in  this 
report as regards the underpinning methodology, p.106 
75  Particulate  matter  (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 human sources, including combustion. 
76 Low-level ozone is produced by photochemical action on pollution 
77  Please  note  that  these  figures  refer  to  the  impacts  of  individual 
pollutants, and to avoid double-counting cannot be added up to derive 
a sum.  
78  Directive 2016/2284/EU. 

79 EEA. 
80 EEA. 

Environmental Implementation Review 2022 – Denmark 

 
 
                                                                 
 
 
                                                                 
Denmark  19 

Industrial Emissions Directive82 (IED). The Commission 
tabled a proposal in April 202283. The revision seeks to 
improve the Directive’s contribution to the zero-pollution 
objective, as well as its consistency with climate, energy 
and circular-economy policies. 

The overview of industrial activities regulated by  the IED 
is based on data reported to the EU Registry (2018)84. 

In  Denmark,  around  2  350  industrial  installations  are 
required under the IED to have a permit. This represents 
an  increase  of  about  70  installations  since  2015,  largely 
due  to  an  increase  in  the  intensive  rearing  of  poultry  or 
pigs  but  also  in  the  waste  management  sector.  The 
distribution of installations is shown in Figure 19. 

Industrial sectors in Denmark with the most installations 
in  2018  are  intensive  poultry  and  pig  rearing  (68%), 
followed  by  the  waste  management  sector,  including 
landfills  (15%),  the  food,  drink  and  milk  sector  (5%)  and 
the energy sector (4%). 

82  Directive  2010/75/EU  covers  industrial  activities  carried  out  above 
certain thresholds. It covers the energy industry, metal production, the 
mineral and chemical industry, waste management, and a wide range of 
industrial  and  agricultural  sectors  (e.g.  intensive  rearing  of  pigs  and 
poultry, pulp and paper production, painting and cleaning). 
83  European  Commission,  proposal  for  a  revision  of  the  Industrial 
Emissions Directive, 4 April 2022. The revision of the IED is performed in 
parallel to the revision of Regulation (EC) No 166/2006 on the European 
Pollutant Release and Transfer Register (E-PRTR). 
84 EEA. 

In    2020,  Denmark  did  not  register  any  cases  exceeding 
the  limit  values  set  under  the  Ambient  Air  Quality 
Directive.81. 

According  to  latest  air  pollutant  emission  projections 
additional  measures  would  be  needed  to  achieve    the 
NECD emission reduction commitments. 

In  the  2019  EIR,  Denmark  had  two  priority  actions.  The 
first  was  to  take  specific  action  under  the  national  air 
pollution control programme (NAPCP) to reduce the main 
emission  sources,  in  particular  to  reduce  PM2.5  and 
ammonia. The second was to reduce ammonia ceilings to 
comply  with  national  emission  ceilings,  by  shifting  to  
low-emission  agricultural  measures.  Denmark  has 
achieved limited progress on both fronts. 

2022 priority actions  

 

take  action  under  the  NAPCP  to  reduce  emissions 
from the main sources mentioned above. 

  ensure  full  compliance  with  the  EU  air  quality 
standards  and  maintain  downward  emissions  trends 
of  air  pollutants,  to  reduce  adverse  air  pollution 
impacts  on  health  and  economy  with  a  view  to 
reaching WHO guideline values in the future.  

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to:  
(i) protect air, water and soil;  
(ii) prevent and manage waste;  
(iii) improve energy and resource efficiency;  
(iv) clean up contaminated sites.  
To achieve this, the EU takes an integrated approach to 
the prevention and control of routine and accidental 
industrial emissions. The cornerstone of the policy is the 

81 EEA, Eionet Central Data Repository 

Environmental Implementation Review 2022 – Denmark 

 
 
                                                                 
 
                                                                 
Figure  19:  Number  of  IED  industrial  installations  per 
sector in Denmark, 201885 

Figure  20: Emissions to air from IED sectors and rest of 
national total air emissions in Denmark, 201886 

Denmark  20 

The  environmental  burdens  for  industrial  emissions  to 
water  mainly  result  from  the  waste  management  for 
total  nitrogen,  phosphorous,  from  landfills  for  polycyclic 
aromatic  hydrocarbons  (PAHs),  from  the  energy  sector 
for  total  organic  carbon  (TOC)  and  from  the  pulp  and 
paper  sector  for    heavy  metals.  Figure  21  provides  the 
breakdown by substance  based on E-PRTR data.  

The  industrial  sectors 
identified  as  contributing  the 
largest  burden  to  the  environment  for  emissions  to  air 
were the energy sector for sulphur oxides (SOx), nitrogen 
oxides (NOx) as well as for cadmium (Cd), chromium (Cr) 
and mercury (Hg); the waste management sector for lead 
(Pb),  zinc  (Zn),  and  dioxins;  the  mineral  industry  for 
arsenic (As); and intensive rearing of poultry and pigs for 
ammonia  (NH3)  and  PM2.5.  The  breakdown  is  given  in 
Figure 20. 

85 EEA, EU Registry, European Industrial Emissions Portal (data retrieved 
on 3 November 2021). 

86  EEA,  LRTAP,  Air  pollutant  emissions  data  viewer  (Gothenburg 
Protocol, LRTAP Convention) 1990-2019 (data retrieved on 3 November 
2021). 

Environmental Implementation Review 2022 – Denmark 

 
 
 
                                                                 
 
 
 
                                                                 
 
Figure 21: Relative releases to water from industry in 
Denmark, 201887 

Figure  22: Number of inspections in IED installations in 
Denmark in 201888 

Denmark  21 

the 

taken 

to  enforcing 

The  EU  approach 
IED 
requirements creates strong rights for the public to have 
access to information and to participate in the permitting 
process. This empowers individuals and NGOs, to ensure 
that  permits  are  appropriately  granted  and  their 
conditions followed. As part of environmental inspection, 
IED 
competent  authorities  carry  out  site  visits  to 
installations  to  take  samples  and  to  collect  the  requisite 
information.  According  to  Article  23(4)  of  the  IED,  site 
visits are carried out between once every year and once 
every three years, depending on the environmental risks 
posed by the installations. In 2018, Denmark  carried out 
1 597 site visits, the majority to installations for intensive 
poultry  or  pig  rearing    (66%),  followed  by  the  waste 
management sector, including landfills and the food drink 
milk sector (8%), as shown in Figure 22. 

The  development  of  Best  Available  Techniques  (BAT) 
Reference  Documents  (BREFs)  and  BAT  Conclusions 
ensures  good  collaboration  with  stakeholders  and 
enables better implementation of IED89. Since the last EIR 
for  waste 
report,  BAT  Conclusions  were  adopted 
incineration,  for  the  food,  drink  and  milk  industries  and 
for  surface  treatment  using  organic  solvents  including 
wood and wood products preservation with chemicals. 

The  Commission  relies  on  the  efforts  of  national 
competent  authorities  to  implement  the  legally  binding 
BAT  conclusions  and  associated  BAT  emission  levels  in 
environmental  permits,  resulting  in  considerable  and 
continuous reduction of pollution.  

On 16 November 2021, Denmark hosted the EIR peer to 
peer  workshop  on  ammonia  reducing  technology  and 
measures. 

In 2019, Denmark  had  priority actions to review permits 
to comply with new adopted BAT conclusions and to step 
up  control  and  enforcement  to  ensure  compliance  with 
BAT conclusions. These actions have been followed up by 
the Commission through the reporting by Denmark to the 
EU  Registry.  The  Commission  is  currently  verifying  with 
Denmark  the  reported 
information  on  the  permits 
granted for each installation in the scope of the IED. 

Major industrial accidents prevention – 
SEVESO 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 
(i)  control  major  accident  hazards  involving  dangerous 
substances, especially chemicals;  
(ii)  limit  the  consequences  of  such  accidents  for  human 
health and the environment;  

87  EEA,  EU  Registry,  European  Industrial  Emissions  Portal.  The  heavy 
metals are presented both as a weighted sum of eco toxicity and human 
toxicity  factors  to  illustrate  both  the  ecological  and  human  impact 
(based on USEtox) (data retrieved on 3 November 2021). 

88 EEA, EU Registry, European Industrial Emissions Portal (data retrieved 
on 3 November 2021). 
89 European Commission BAT reference documents 

Environmental Implementation Review 2022 – Denmark 

 
 
 
 
 
                                                                 
  
 
 
                                                                 
Denmark  22 

Figure 24: Situation regarding EEP in Denmark, 201894 

The  information  to  the  public  referred  to  in  annex  V  to 
the Seveso-III Directive – especially about how the public 
concerned will be warned in case of a major accident; the 
appropriate behaviour in the event of a major accident ; 
and  the  date  of  the  last  site  visit  –  are  permanently 
available for 100% of Seveso establishments in Denmark. 
This  is  an  important  provision  of  the  Seveso-III  Directive 
as this public knowledge could reduce the consequences 
of a major industrial accident. 

Figure 25 gives the share of UTE on which information on 
safety  measures  and  requisite  behaviours  were  actively 
made available to the public in recent years.  

Figure 25: Share of UTE for which information on safety 
measures and requisite behaviours were actively made 
available  to  the  public  in  Denmark,  2011,  2014  and 
201895 

(iii)  continuously  improve  prevention,  preparedness  and 
response to major accidents.  
The  cornerstone  of  the  policy  is  Directive  2012/18/EU 
(the Seveso-III Directive)90.  

The overview below of industrial plants regulated by the 
Seveso-III Directive, hereafter ‘Seveso establishments’, is 
based on data  reported to the eSPIRS database (2018)91 
and  the  Denmark  report  on  implementation  of  the 
Seveso-III Directive for the period 2015-201892. 

In  Denmark,  of  the  122  Seveso  establishments,  61  are 
categorised as  lower-tier establishments (LTE) and 61 as 
upper-tier establishments (UTE)  – based on the quantity 
of hazardous substances likely to be present. The UTE are 
subject  to  more  stringent  requirements.  The  number  of 
Seveso establishments is given in Figure 23. 

Figure  23:  Number  of  Seveso  establishments 
Denmark, 2011, 2014 and 201893 

in 

According to Denmark, an external emergency plan (EEP) 
is required for 61 UTE. In 2018, 61 UTE had an EEP and 55 
of  these  EEP  had  been  tested  over  the  last  three  years. 
The summary is shown in Figure 24. The establishment of 
EEPs 
is  essential  to  allow  proper  preparation  and 
effective  implementation  of  the  necessary  actions  to 
protect  the  environment  and  the  population  should  a 
major industrial accident nevertheless happen. 

2022 priority actions 

  Strengthen  control  and  enforcement  to  ensure 
compliance  with  Seveso-III  Directive  provisions, 
especially on information to the public and EEP. 

90  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances. 
91 European Commission, Seveso Plants Information Retrieval System 
92 As provided for by Article 21(2) of the Seveso-III Directive 
93 European Commission, Assessment and summary of Member States’ 
Implementing  Decision  2014/896/EU 
implementation  reports  for 
(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 

94 As above. 
95 As above. 

Environmental Implementation Review 2022 – Denmark 

 
 
 
                                                                 
 
 
 
 
 
                                                                 
Noise 

Water Framework Directive 

Denmark  23 

The  Environmental  Noise  Directive96  provides  for  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  exposure  to  environmental  noise, 
although  it  does  not  set  noise  limits  as  such.  The  main 
instruments  it  uses  in  this  respect  are  strategic  noise 
mapping  and  planning.    A  relevant  2030  zero  pollution 
action  plan  target  is  a  reduction  by  30%  of  the  share  of 
people 
transport  noise 
compared to 2017.  

chronically  disturbed  by 

Excessive noise from aircraft, railways and roads is one of 
the  main  causes  of  environmental  health‐related  issues 
in  the  EU.  It  produces  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress97. 

limited  set  of  data98, 
In  Denmark,  based  on  a 
environmental  noise  is  estimated  to  cause  at  least 
around 100 premature deaths and 400 cases of ischaemic 
heart disease annually99. Moreover, some 55 000 people 
suffer  from  disturbed  sleep.  In  Denmark,  the  number  of 
people exposed to noise increased by 15% between 2012 
and  2017,  based  on  reported  data.  Noise  mapping  of 
agglomerations,  roads  and  railways  is  complete,  and 
based on the latest full set of analysed information. 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal  and  fresh  waters 
(including  surface  and  ground  waters)  be  significantly 
reduced.  Achieving,  maintaining  or  enhancing  a  good 
status  of  water  bodies  as  defined  by  the  Water 
Framework Directive  will  ensure that EU citizens benefit 
from good quality and safe drinking and bathing water. It 
will  further  ensure  that  the  nutrient  cycle  (nitrogen  and 
phosphorus)  is  managed  in  a  more  sustainable  and 
resource-efficient way. 

96 Directive 2002/49/EC 
97 WHO 2018, Environmental Noise Guidelines for the European Region. 
98  For  further  information:  European  Environment  Agency,  Noise  Fact 
Sheets 2021. 
99  These  figures  are  an  estimation  by  the  European  Environmental 
Agency  based  on  :  (i)  the  data  reported  by  Member  States  on  noise 
exposure  covered  by  Directive  2002/49/EC;  (ii)  ETC/ATNI,  2021,  Noise 
indicators under the Environmental Noise Directive 2021: Methodology 
for  estimating  missing  data,  ETC/ATNI  Report  No  2021/06,  European 
Topic Centre on Air Pollution, Transport, Noise and Industrial Pollution; 
(iii)  the  methodology  for  heaalculations,  ETC/ACM,  2018,  Implications 
of  environmental  noise  on  health  and  wellbeing  in  Europe,  Eionet 
Report  ETC/ACM  No  2018/10,  European  Topic  Centre  on  Air  Pollution 
and Climate Change Mitigation. 

The  Water  Framework  Directive100  is  the  cornerstone  of 
the EU’s water policy in the 21st century101. This Directive 
along  with  other  water-related  directives102  set  the 
framework 
integrated  water 
sustainable  and 
management.  The    aim  is  to  achieve  a  high  level  of 
protection  of  water  resources,  to  prevent  of  further 
deterioration and to restore water to good status. 

for 

By  March  2022,  all  Member  States  have  to  report  the 
third  generation  of  river  basin  management  plans 
(RBMPs)  under  the  Water  Framework  Directive.  The 
Commission will assess the reported status and progress, 
and  will  check  how  the  findings 
in  the 
the  second  RBMPs103  have  been 
assessment  of 
addressed.  Denmark  has  not  yet  reported  the  third 
RBMPs. 

identified 

It 

includes,  an 

substances.  The  assessment 

The  Commission  published  in  December  2021  the  sixth 
Implementation  Report104. 
interim 
assessment  on  progress  of  the  implementation  of  the 
programmes of measures and on monitoring of the new 
priority 
for 
Denmark105  showed  that  the  planned  and  implemented 
measures 
(RBDs) 
contributed significantly to reaching the objectives of the 
Water  Framework  Directive  in  2021.  However,  the  pace 
had slowed in particular for planned measures related to 
wetlands, hydromorphological changes on rivers and lake 
restorations. 

four  river  basin  districts 

in  all 

report 

In  Denmark,  70  research  projects  took  place  in  the  2nd 
management  cycle  to  better  identify  pressure  factors, 
potential  areas  for  action  and  their  significance  for 
achieving the environmental objectives106. 

100 Water Framework Directive (2000/60/EC). 
101 EU Water Policy. 
102  This 
includes  the  Groundwater  Directive  (2006/118/EC),  the 
Environmental  Quality  Standards  Directive  (2008/105/EC),  the  Floods 
Directive  (2007/60/EC),  the  Bathing  Water  Directive  (2006/7/EC),  the 
Urban  Waste  Water  Treatment  Directive  (91/271/EEC),  the  new 
Drinking  Water  Directive  (2020/2184/EC),  the  Nitrates  Directive 
(91/676/EEC),  the  Marine  Strategy  Framework  Directive  (2008/56/EC), 
the Industrial Emissions Directive (2010/75/EU) and the new Regulation 
on minimum requirements for water reuse (2020/741). 
103  Detailed  information  can  be  found  in  the  5th  Report  from  the 
Commission on the implementation of the Water Framework Directive 
and the Floods Directive, as well as in the 2019 EIR. 
104  See  the  6th  Implementation  Report  of  the  Water  Framework 
Directive and Floods Directive. 
105  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Member  States’  progress  in  Programmes  of  Measures 
during  the  second  planning  cycle  of  the  Water  Framework  Directive. 
Member State: Denmark, 2022. 
106  European  Commission,  Assessment  of  Member  States’  progress  in 
Programmes  of  Measures  during  the  second  planning  cycle  of  the 
Water Framework Directive, pp.3-4. European Commission. 

Environmental Implementation Review 2022 – Denmark 

 
                                                                 
                                                                 
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Figure  27.  Percentage  of  surface  water  bodies  not 
achieving good chemical status110 

Based  on  the  second  RBMPs  reporting  and  data 
published  in  2020107,  in Denmark  28.2% of  all  surface 
water  bodies108achieved    good  ecological  status  (with 
unknown  status 23.8%) and  only  0.8%  were  in    good 
For 
chemical 
groundwaters,  25.1%  did  not  achieve  good  chemical 
status (30.6% were in unknown status) and 0.7% were in 
a poor status. 

unknown).  

98.5% 

status 

(with 

Figure  26  illustrates  the proportion  of  surface  water 
bodies in Denmark and 
countries 
European 
other 
that failed to achieve good ecological status. 

Figure 26.  Proportion  of  surface  water  bodies  (rivers, 
lakes, transitional and coastal waters) in less than good 
ecological status per River Basin District109 

the 

IED 

Under 
framework,  Denmark  achieved  a 
significant  decrease the last  decade (20.1%) in industrial 
releases  of  heavy  metals  such  as  Cd,  Hg,  Ni,  Pb  and  an 
increase  (21.4%) 
in  total  organic  carbon  (TOC)  to 
water111. 

The  total  volume  of  water  abstracted  annually 
in 
Denmark from surface and groundwater sources in 2018 
was  868.77  hm3112.  By  sector,  the  percentage  of  water 
abstraction was 56.86% for agriculture, 40.56% for public 
water  supply,  0.07%  for  electricity  cooling,  1.53%  for 
manufacturing  and  0.97%  for  mining  and  quarrying,  as 
illustrated in Figure 28. It should be noted that 2018 was 
a particularly dry year,  so the amount  of water used  for 
agriculture  was  higher  than  normal.  Denmark  uses  a 
register  to  monitor  water  abstractions.  All  water 
abstractions require a permit, except for a broad owner's 
abstraction of surface water for cattle, under the Danish 
Water Supply Act. 

Figure  27  presents  the  percentage  of  surface  water 
bodies  in  Denmark  and  other  European  countries  failing 
to  achieve  good  chemical  status.  For  Denmark,  the 
percentage is 0.7%, including water bodies failing due to 
substances behaving as ubiquitous PBTs (persistent,  bio-
accumulative,  or  toxic). Excluding uPBTs, the percentage 
of  surface  water  bodies  that  did  not    achieve  good 
chemical status is unknown. 

107 WISE Freshwater (europa.eu) 
108 river, lake, transitional, coastal, territorial 
109  EEA, 2021.  

110 EEA, December 2019.  
111 EEA, 2021 
112 EEA, 2022. 

Environmental Implementation Review 2022 – Denmark 

 
 
                                                                 
 
                                                                 
Figure 28: Water abstraction per sector in Denmark113 

Denmark  25 

assist  NRW 

performance  monitoring 

and 
to 
reporting     Another  good  practice  in  Denmark  is  the 
Water  Valley  initiative  for  water  technology  that  will 
enable  water  consumption  to  become  more  resource 
efficient, cost effective and quality assured117. 

Floods Directive 

As  mentioned,  the  Commission  published  in  December 
2021  the  sixth  Implementation  Report.  It  includes  the 
review  and  update  of  the  Preliminary  Flood  Risk 
Assessments  during  the  second  cycle  (2016-2021).  The 
in  Denmark,  the 
assessment  report  showed  that 
in  the  Preliminary  Flood  Risk 
information  provided 
Assessment  document 
the 
combination  with 
in 
methodology report was informative and clear. Denmark 
also  applied  clear  methodology  to  calculate  APSFRs118 
using  a  spatial  process  to  rank  areas  of  flood  risk, 
factoring  in  climate  change.  However,  pluvial  floods 
should  be  also  considered  –  at  least  in  areas  with  high 
vulnerabilities. 

Denmark has made an attempt to overcome data scarcity 
for  past  fluvial  flood  events  by  conducting  a  survey 
amongst municipalities. 

Denmark  has  not  yet  adopted  and  reported  the  second 
generation  of  flood  risk  management  plans  (FRMPs) 
under  the  Floods  Directive.  The  European  Commission 
will  assess  progress  since  the  adoption  of  the  first  flood 
risk management plans and publish a report. 

Drinking Water Directive 

As  regards  the  Drinking  Water  Directive119,  no  new 
assessment  of  the  quality  of  Drinking  Water  is  available 
since  the    EIR  2019.  The  quality  of  drinking  water  in 
Denmark has not been indicated as an area of concern120. 

The  recast  Directive  121entered  into  force  on  12  January 
2021,  Member  States  have  until  12  January  2023  to 
transpose it into their national legal system. Denmark will 
have to comply with these reviewed quality standards. 

117 Water Valley Denmark 
118 Areas of Potential Significant Flood Risk 

120The  latest  report  for  2017-2019  by  the  Danish  Environmental 
Protection  Agency  was  based  on  analysis  of  water  from  supplies  of 
water surpassing 1,000 m3 a day on average or serving more than 5,000 
people.  The  controls  showed  that  majority  of  biological  and  chemical 
parameters were close to or 100% compliance. For the microbiological 
parameters deviations were mainly observed for coliform bacteria and 
colony  count  22  ˚C,  in  1-4  %  of  the  per-formed  analyses.  For  the 
chemical  parameters  deviations  were  mainly  observed  for  colour, 
turbidity, NVOC, ammonium, iron, manganese and nitrite, where 1-8 % 
of the performed analyzes deviated from the standard values. 

In Denmark, the  water  exploitation  index  plus  (WEI+)114 
was 1.49% in 2017, far less than the 20% that is generally 
considered  as  an  indication  of  water  scarcity115  (Figure 
29); Denmark is  ranked 18th  (from  high  to  low  score)  in 
the EU level in terms of WEI+ . 

Figure  29:  Water  exploitation  index  plus  (WEI+)  inside 
EU, 2017116 

Denmark  has  taken  several  measures  (smart  meters, 
intelligent  pumps, 
intelligent  valves,  deployed  noise 
loggers  and  much  more)  to  reduce  the  level  of  non-
revenue  water  (NRW),  including  creating  an  economic 
incentive  for  water  utilities  to  keep  their  NRW  level 
below  10%.  Denmark  has  also  taken  action  to  create 
awareness of the importance of saving water. As a result, 
Denmark  has managed  to reduce  its water consumption 
by  over  40%  since  1980.  Doing  so  means  that  Denmark 
has  achieved  one  of  the  world's  lowest  levels  of  NRW 
with  a  consistent  national  average  of  just  6  to  8% 
compared to some parts of the world where NRW is over 
50%.  Water  loss  has  been  kept  low  through  systematic 
leakage detection and by implementing modern ICT tools 

113  European  Environment  Agency, Water  abstraction  by  source  and 
economic sector in Europe, 2022. 
114  EEA,  Water  exploitation  Index  Plus,  2022.  The  Water  Exploitation 
Index plus (WEI+) is a measure of total fresh water use as a percentage 
of  the  renewable  fresh  water  resources  (groundwater  and  surface 
water)  at  a  given  time  and  place.  It  quantifies  how  much  water  is 
abstracted  and  how  much  water 
is  returned  after  use  to  the 
environment. 
115 Eurostat 
116 EEA, Water exploitation Index Plus, 2022. 

Environmental Implementation Review 2022 – Denmark 

 
 
 
                                                                 
                                                                 
 
 
Bathing water 

Regarding  the  Bathing  Water  Directive,  Figure  30  shows 
that  in 2020,  of the  1 026 Danish bathing waters,  90.7% 
were  of  excellent  quality122.  The  evolution  is  shown  in 
Figure 31. 

Figure  30:  Bathing  water  quality  in  Europe  in  the  2020 
season123 

Denmark  26 

2019125, warns that nitrates are still polluting water in the 
EU  and  causing  harm.  Excessive  nitrates  in  water  are 
harmful  both  to  human  health  and  to  ecosystems, 
causing  oxygen  depletion  and  eutrophication.  Where 
national authorities and farmers have cleaned up waters, 
it has had a positive impact on drinking water supply and 
biodiversity, and on sectors such as fisheries and tourism 
that  depend  on 
them.  Nevertheless,  excessive 
fertilisation remains a problem in many parts of the EU. 

Denmark  has  received  a  derogation  under  the  Nitrates 
Directive  for  the  application  of  more  than  170  kg/ha  of 
nitrogen from manure until 31 July 2024126. 

Figure 31: Bathing water quality 2017-2020124 

in 

reducing 

recorded 

improvements 

for  phosphorus 

According to the last report on the implementation of the 
Nitrates Directive127, between periods 2008-11 and 2016-
19,  groundwater  quality  has  slightly 
improved  as 
compared  to  the  previous  reporting  period,  with  the 
percentage of stations reaching or exceeding 40 or 50mg 
nitrate per  litre that  falling from  6.9% to  6.7% and from 
19.3%  to  14.3%,  respectively.  The  situation  concerning 
nitrates  concentrations  in  surface  water  is  stable  with 
of 
some 
eutrophication.  However,  nutrient  inputs  to  the  Baltic 
Sea  around  Denmark  however  have 
significantly 
decreased for nitrogen in the Danish Straits and Kattegat, 
In  2020,  the 
and 
government reached a new agreement on nitrogen129. In 
2021,  this  was  followed  up  by  a  deal  on  the  green 
transition  of  Danish  agriculture130. 
the 
improve  the 
nitrogen  and  phosphorus  cycles  helps 
circularity of the economy. Nevertheless, the Commission 
is  aware  of  the  challenges  that  the  nutrient  surplus  in 
Denmark  poses  on  the  local  environment  and  for  the 
Baltic Sea. It will continue its structured dialogue with the 
Danish  authorities  to  ensure  that  appropriate  measures 
are taken to implement EU legislation131. However latest 
data for 2010-2020 shows increases in pollutant releases 
to water of 35.5% for nitrates, 30.8% for phosphorus and 
21.4 for TOC132. 

in  Kattegat128. 

Improving 

Nitrates Directive 

The latest Commission Report on the Implementation of 
the  Nitrates  Directive,  referring  to  the  period  2016-

122  EEA,  2021.  State  of  bathing  waters  in  2020  –  Denmark  country 
report. 
123 EEA, Bathing Water Quality in 2020, 2022. 
124 EEA, European Bathing Water Quality in 2017, 2018, 2019, 2020. 

Urban wastewater treatment 

Regarding the Urban Wastewater Treatment Directive, in 
Denmark, the compliance rate is  99% much  higher than 
the  EU  average  of  76%  in  2018133.  Further  action  is 

125 European Commission, Implementation Report 2016-2019. 
126 European Commission, Derogation 17.07.2020. 
127  European  Commission,  Annex  15  of  the  Staff  Working  Document 
accompanying  the  report  on  the  implementation  of  the  Nitrates 
Directive for the period 2016-2019 
128 Commission Recommendations for Denmark’s CAP Plan, 2021, p.15 
129 Danish government, Agreement on nitrogen efforts in 2020 
130 Deal on green transition of Danish agriculture 
131 European Parliament petition: 0862/2021 
132 EEA, Water pollutant releases changes from 2010 to 2020 for the EU 
Member States, 29.03.2022.  
133 WISE  

Environmental Implementation Review 2022 – Denmark 

 
 
 
                                                                 
                                                                 
needed to provide biological treatment to additional 0.02 
million  p.e  of  urban  wastewater  (0.2%)  and  biological 
treatment  with  nitrogen  and  phosphorus  removal  to 
additional  0.07  million  p.e.  of  urban  wastewater  (0.7%) 
(see Figure 32). 

Figure  32: Proportion of urban waste water that  meets 
all  requirements  of  the  UWWTD  (collection,  biological 
treatment,  biological  treatment  with  nitrogen  and/or 
phosphorus  removal)  in  compliant  urban  areas  of  the 
UWWTD (‘compliance rate’), 2018134 

Denmark  27 

legislation136 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.  

information  on  the 
The  Commission  has  collected 
enforcement of REACH and CLP since 2007. In December 
2020,  the  Commission  assessed  the  Member  States 
reports  on  implementation  and  enforcement  of  these 
Regulations137, in line with REACH Article 117(1) and CLP 
Article  46(2).  According  to  the  latest  available  data, 
national enforcement structures have not changed much. 
However,  it  is  apparent  from  this  report  that  there  are 
still  many  disparities  in  implementing  REACH-CLP  and 
notably in the area of the law enforcement. The recorded 
compliance levels seem to be quite stable over time, but 
they have worsened slightly possibly due to enforcement 
detecting 
authorities 
noncompliant  products/companies  and  more  non-
compliant products being put on the EU market.  

being  more 

effective 

in 

In  the  2019  EIR  Denmark  had  four  priority  actions.  The 
first  was to take  steps to improve  monitoring of surface 
waters and the second was to complete the development 
of  assessment  methods  for  biological  quality  elements. 
The  Commission  cannot  evaluated  this  until  Denmark 
submits the third RBMP. The third priority action was to 
adopt legislation on nutrient pollution from agriculture to 
address  environmental  pressures  and  water  quality 
issues;  Denmark  has  done  so.  The  fourth  2019  priority 
action  was  to  integrate  flood  risk  management  cycles 
amongst various levels of administration. 

2022 priority actions 

  Maintain progress to reduce agricultural pollution. 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects  on  human  health  and  the  environment.  In 
October  2020,  the  Commission published  its  chemicals 
'Towards  a  Toxic-Free 
strategy  for  sustainability 
Environment'135  which  led  to  some  systemic  changes  in 
EU  chemicals  legislation.  The  strategy is  part  of  the  EU's 
zero-pollution  ambition  –  a  key  commitment  of  the 
European Green Deal. 

- 

134 European Commission, WISE Freshwater, 2021. 

135 COM(2020) 667 final. 

In August 2021, the Commission published a measurable 
assessment  of  the  enforcement138  of  the  two  main  EU 
regulations on chemicals using a set of indicators tracking  
different aspects of enforcement. 

In  Denmark,  responsibility  for  checking  compliance  with 
REACH  lies  with  the  Danish  Environmental  Protection 
Agency139:  

As  a  rule,  all  infringements  of  REACH  are  classed  as 
serious  or  very  serious  environmental  administrative 
offences.  If  the  infringement  is  sufficiently  serious,  the 
competent  authority  may  decide  to 
impose  further 
penalties  in  addition  to  a  fine.  Where  necessary,  it  may 
also  order  the  provisional  seizure  of  assets  and 
documents.  

In Denmark 4.5 person years are allocated to REACH and 
CLP  enforcement140.   The  enforcement  strategy  is  based 
on  risk-based  prioritisation  to  focus  on  areas  with  the 
highest  risk  of  a  breach,  and  areas  where  breaches  can 
lead  to  serious  risk  to  health  and  the  environment. 
Denmark  was  below  the  EU  average  in  the  %  of  non-
compliance cases in 2019141 (see Figure 33). 

136 REACH: OJ L 396, 30.12.2006, p.1. -  CLP: OJ L 252, 31.12.2006, p.1 s. 
137 European Commission, Final Report, on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu) 
138  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators 
139 European Commission, Final Report, on the operation of REACH and 
CLP, p. 68 

140 European Commission, Final Report, on the operation of REACH and 
CLP, p. 74. 

141 European Commission, Final Report, on the operation of REACH and 
CLP, p. 78 

Environmental Implementation Review 2022 – Denmark 

 
 
 
                                                                 
 
                                                                 
 
 
Figure 33: Percentage % of non-compliance cases out of 
the  total  number  of  REACH  and  CLP  controls  during 
2019  per  Member  State  and  compared  to  the  EU 
average142 

Denmark  28 

In  2021,    Denmark  reached    a  political  agreement  on  a 
strategy  on  pesticides143.  This  was  followed  up  in  early 
2022, with an agreement on biocides in agriculture144 and 
on a chemicals strategy145. 

2022 priority actions 

  upgrade 

the 

implementation  and  enforcement 
administrative capacity toachieve a zero tolerance for 
non-compliances. 

142 European Commission, Final Report, on the operation of REACH and 
CLP , pp.87-88, 2022. 
143 Political agreement on a pesticide strategy 2022-26 
144  Political  agreements on  concerted  Danish  efforts on  biocides 2022-
25 
145 Agreement on initiatives on chemicals 

Environmental Implementation Review 2022 – Denmark 

 
  
 
 
                                                                 
4.  Climate action 

Denmark  29 

to 

(NDC) 

law  also 

In  line  with  the  Paris  Agreement  and  as  part  of  the 
European Green Deal, the European Climate Law sets the 
EU  target  of  reaching  climate  neutrality  by  2050  and 
reducing  greenhouse  gas  (GHG)  emissions  by  55%  by 
2030  compared  to  1990.  The 
limits  the 
contribution  that  carbon  removals  can  make  towards 
in  2030  to  ensure  a  sufficient 
emission  reductions 
mitigation effort.  
The  EU  and  its  Member  States  submitted  updated 
Nationally  Determined  Contribution 
the 
UNFCCC in December 2020.  
The  EU  is  working  across  all  sectors  and  policies  to  cut 
GHG  emissions  and  make  the  transition  to  a  climate-
neutral  and  sustainable  economy,  as  well  as  addressing 
the unavoidable consequences of climate change.  
EU  climate  legislation  incentivises  emissions  reductions 
from power generation, industry, transport, the maritime 
sector and fluorinated gases (F-gases) used in products.  
For  road  transport,  EU  legislation  requires  the  GHG 
intensity  of  vehicle  fuels  to  be  cut  by  6%  by  2020 
compared  to  2010146  and  sets  binding  GHG  emission 
standards for different vehicle categories147.  
Under the F-gas Regulation, the EU’s F-gas emissions will 
be cut by two thirds by 2030 compared with 2014 levels. 
From  2021,  emissions  and  removals  of  GHGs  from 
LULUCF have been included in the EU emission-reduction 
efforts.  
The  EU  adaptation  policy  is  an  integral  part  of  the 
European  Green  Deal.  From  2021,  Member  States  are 
required 
their  national  adaptation 
policies148,  as  the  EU  Climate  Law  recognises  adaptation 
as a key component of the long-term global response to 
climate change. Member States will be required to adopt 
national  strategies,  and  the  EU  will  regularly  assess 
progress  as  part  of  its  overall  governance  on  climate 
action. The updated EU adaptation strategy, published in 
February  2021,  sets  out  how  the  EU  can  adapt  to  the 
unavoidable  impacts  of  climate  change  and  become 
climate resilient by 2050. 

report  on 

to 

Key national climate policies and strategies 

In  December  2019,  Denmark  adopted  its  integrated 
national  energy  and  climate  plan  (NECP)  for  the  2021-
2030  period  covering  decarbonisation,  deployment  of 
renewable  energy  and  energy  efficiency.  The  plan  will 
contribute  to  Denmark’s  domestic  objective  to  reduce 

greenhouse  gas  emissions  by  70%  by  2030  (relative  to 
1990)  and  achieve  carbon  neutrality  by  2050  at  the 
latest.  

In  its  RRP  Denmark  allocates  59%  of  available  resources 
to  climate  objectives  and  outlines  crucial  reforms  and 
investments including in relation to sustainable transport 
and  clean  and  efficient  production  and  on  energy 
efficiency in public buildings and households. A green tax 
reform is also being implemented (more details in section 
5). 

Denmark’s 
first  national  adaptation  strategy  was 
adopted in March 2008. It is based on the principle that 
all parts of society contribute to climate adaptation.  

Between 1990 and 2020, economy wide greenhouse gas 
emissions in Denmark fell by 41%. Danish greenhouse gas 
emissions  per  person  are  close  to  the  EU  average  (see 
Figure 34). 

Figure  34:  Total  greenhouse  gas  emissions 
international aviation) in Denmark, 1990-2020  

(incl. 

Effort sharing 

For emissions not covered by the EU ETS, Member States 
have  binding  national  targets  under  the  Effort  Sharing 
legislation149. Denmark’s target is to reduce emissions not 
covered  by  the  EU  emissions  trading  system  (such  as 
buildings,  road  transport,  agriculture,  small  industry  and 
waste)  by  20%  by  2020  and by  39%  by  2030,  relative  to 
the  2005  levels.  Denmark  has  met  its  2020  target  (see 
Figure 35). 

146  The Fuel  Quality  Directive (Directive 98/70/EC)  sets  strict  quality 
requirements  for  fuels  used  in  road  transport  in  the  EU  to  protect 
human health and the environment, and to make road travel across the 
EU safer. 
147 Directive 98/70/EC. 
148 Article 29 of Regulation (EU) 2018/1999. 

149 Regulation (EU) 2018/842. This is for sectors currently not covered 
by the existing EU emissions trading sector (typically emissions from the 
buildings,  road  transport,  small  industry,  waste,  agriculture  and  non-
CO2  emissions  from  other  sectors).  The  proposed  national  target  will 
continue to cover this scope. 

Environmental Implementation Review 2022 – Denmark 

 
                                                                 
 
                                                                 
According  to  its  NECP,  Denmark  intends  to  achieve 
reductions in line with its current Effort Sharing target for 
2030. 

Figure  35:  Emissions  and  targets  under  the  Effort 
Sharing Decision/ Effort Sharing Regulation  in Denmark 
2020 and 2030 as percentage change from 2005 

Denmark  30 

renewable fuels.  The greenhouse gas reduction target  is 
set  to  further  increase  in  2025,  2028  and  2030,  and  by 
2025  the  Danish  government  will  include  indirect  land 
use criteria (ILUC), to further reduce the global impact of 
the use of biofuels.  The Danish government presented a 
specific  transport  plan  to  tackle  key  road  congestion 
problems and has taken action to roll out the  European 
Rail  Traffic  Management  System  signalling  on  Danish 
railroads, which is  a prerequisite for more frequent train 
schedules  and  for  further  electrification  of  the  rail 
network.  The  plan  also  foresees  investments  in  public 
transport  and  cycling.  The  Danish  government  also  aims 
to phase out the sale of new traditional diesel and petrol 
cars  as  of  2030  and  to  increase  the  sale  of  electric 
vehicles. 

Figure  37:  Greenhouse  gas  emissions  by  sector  in 
Denmark150 
1990-2020, 
projections 2021-2030151 

emissions 

historical 

– 

Figure  36:  Emissions,  annual  emission  allocations 
(AEAs) and accumulated surplus/ deficit of AEAs under 
the Effort Sharing Decision in Denmark 2013-2020  

Key sectoral developments 

In 2019, road transport in Denmark accounted for 26% of 
greenhouse gas emissions. Little progress has been made 
in  reducing  emissions  from  fuels  and  cars;  compared  to 
2005 emissions, it only decreased by 2%. The greenhouse 
gases  (GHG) 
in  Denmark 
intensity  of  vehicle  fuels 
decreased by 2.7% from 2010 to 2019. The country needs 
to act swiftly to meet the current reduction target of 6% 
by 2020.  

In 2020 Denmark increased its blending mandates for the 
road  transport  sector,  and  by  2022  legislation  has  been 
altered to a greenhouse reduction target, which also aims 
to  reduce  the  global  emissions  of  the  used  bio  and 

On  buildings, it is crucial to increase  energy efficiency in 
order  to  reach  climate  goals.  In  agriculture,  further 
measures are needed to reduce emissions, both CO2 and 
non-CO2  emissions.  Figure  37  shows  emission  trends  by 
sector. 

In  the  land  use,  land  use  change  and  forestry  (LULUCF) 
sector,  Denmark  projects  moderate  net  emissions  by 
2030.  The  quantities  reported  under  the  Kyoto  Protocol 
for the LULUCF sector in Denmark show net emissions of, 
on average, 1.8 Mt CO2-eq for the period 2013 to 2019. 
In  this  regard,  Denmark  represents  -0.5%  of  the  annual 
average  sink  of  -344.9  Mt  CO2-eq  of  the  EU-27. 
Accounting for the same period gives net average annual 

150  The  sectors  in  the  figure  correspond  to  the  following  IPCC  sectors: 
Energy supply: 1A1, 1B and 1C. Energy use in manufacturing industries: 
1A2.  Industrial  processes  and  product  use:  2.  Transport:  1A3.  Other 
energy  use:  1A4,  1A5  and  6.  Agriculture:  3.  Waste:  5.  International 
aviation: 1.D.1.a. 
151 EEA, Total GHG trends and projections. 

Environmental Implementation Review 2022 – Denmark 

 
 
 
 
 
                                                                 
Denmark  31 

credits  of  -5.4Mt  CO2-eq,  which  corresponds  to  4.7%  of 
the EU-27 accounted sink  of  -115.0 Mt  CO2-eq. There is 
an  overall  increasing  pattern  of  reported  net  emissions. 
Accounted  net  credits  show  no  clear  trend.  Denmark  is 
one  of  three  EU  Member  States  with  average  net 
emissions  and  one  of  six  EU  Member  States  that  show 
net emissions for at least one year (see Figure 38).  

Figure  38:  Reported  and  accounted  emissions  and 
removals from LULUCF in Denmark152 

Use of revenues from the auctioning of EU ETS 
allowances 

Total  revenues  from  auctioning  of  emission  allowances 
under  the  EU  ETS  over  the  years  2012-2021  exceeded 
EUR  1.1  billion.  100  %  of  auctioning  revenue  was  spent 
on  climate  and  energy  purposes.  In  Denmark,  revenues 
are  not  earmarked,  for  example  projects  have  reported 
up to 100% of revenue each year.  

2022 priority actions  

 

further invest in the electricity grid network 
increasing  share  of 
to  ensure  that  the 
renewable  energy  can  be  used  efficiently, 
for  example,  on  system  flexibility,  smart 
grids and storage. 

152  The  differences  between  reported  and  accounted  emissions  from 
LULUCF under the Kyoto Protocol are described in the ‘explanatory note 
on  LULUCF  –  accounted  and  reported  quantities  under  the  Kyoto 
Protocol’. 

Environmental Implementation Review 2022 – Denmark 

 
 
 
 
                                                                 
Denmark  32 

Part II: Enabling framework: implementation tools 

5. Financing

Environmental investment needs in the 
European Union 

Financing  environmental  measures  is  essential  for  their 
success.  Although  most  financing  comes  from  national 
sources, various EU funds contribute significantly, helping 
to close the financing gaps.  
Post-2020,  environmental  implementation  will  also  be 
supported by the EU’s  COVID-19 Recovery  Fund (via  the 
RRF) and the ‘do no significant harm’ principle which runs 
across the EU budget. The renewed commitments made 
at  COP26  (Glasgow,  October-November  2021)  and  the 
Biodiversity  Convention  (April-May  2022)153  will  also  be 
reflected in the EU budget. 

Overall environmental investment gaps (EU27) 

The EU’s green transition investment needs cover a range 
of  interlinked  areas.  The  additional  investment  needs  in 
addition  to  the  baseline  figures  (i.e.  the  gap  between 
what is needed and what is forecast to be invested if no 
is  taken)  for  climate,  energy  and 
additional  action 
transport  were  estimated  at  EUR  390  billion  per  year 
(EU27)154,  with  a  further  EUR  130  billion  needed  to 
achieve  the  EU's  core  environmental  objectives155. 
Climate adaptation costs can also be significant, reaching 
a total of EUR 35-62 billion (narrower scope) or EUR 158-
year156. 
518  billion 
Those 
implementation 
investment   needs 
objectives 
for  climate 
adaptation the  costs of which are expected to be spread 
over a longer time horizon). 

scope)  per 
the 
(except 

reflect 
to 
for  2020  to  2030 

(wider 

in  circular  economy  and  waste 

total  gap  if  combined  with  water  management.  The 
is 
investment  gap 
estimated  to  be  between  EUR    13-28  billion  per  year, 
depending  on  levels  of  circularity  implemented.  The 
annual  biodiversity  financing  gap  is  estimated  at  around 
EUR 20 billion. 

1: 

Table 
environmental 
objective, 2021-2030 per year158 

Estimated  breakdown  of 

EU’s 
investment  gaps,  by  environmental 

the 

Estimated investment gap (EU-27, 
per year)  

Environmental 
objective 

Pollution  prevention 
& control 

Water  management 
& industries 

Circular  economy  & 
waste 

 EUR billion 

 42.8 

 26.6 

 13.0 

Biodiversity 
ecosystems159 

& 

 21.5 

R & D & I and other  

Total 

 6.2 

 110.1 

 % 

 39% 

 24% 

 12% 

 20% 

 6% 

 100% 

Environmental investment needs in Denmark 

A  preliminary  update  of  the  EU’s  core  environmental 
investment  gap  is  provided  in  Table  1157.  Almost  40%  of 
the  environmental  investment  needs  relate  to  dealing 
with  pollution,  accounting  for  nearly  two-thirds  of  the 

Climate  is  a  political  priority  in  Denmark.  In  2020,  the 
Danish  parliament  passed  a  climate 
law  with  a 
commitment  to  reducing  greenhouse  gas  emissions  by 
70%  (compared  to  1990  levels)  by  2030.  The  Danish 
Minister of Finance has positioned the green transition as 

153 The Convention on Biological Diversity 
154 SWD(2021)621 
155 SWD(2020) 98 final/2 
156 SWD(2018)292. 
157  With  decreases  due  to  Brexit  and  some  reconciliation  among  the 
objectives.  Source:  DG  Environment,  ‘Study  supporting  EU  green 
investment  needs  analysis’  (ongoing,  2021-2023)  and DG  Environment 
internal analysis ‘Environmental investment needs and financing in the 
EU’s green transition’ July 2020.   

158 European Commission, DG Environment, ‘Study supporting EU green 
investment  needs  analysis’  (ongoing,  2021-2023)  and DG  Environment 
internal analysis ‘Environmental Investment needs and financing in the 
EU’s green transition’,  July 2020. 
159  To  meet  the  needs  of  the  2030  biodiversity  strategy  (Natura  2000, 
green infrastructure), at least EUR 20 billion a year should be unlocked 
for nature (COM/2020/380 final). To fully cover the strategy (including 
restoration) EUR 30-35 billion may be needed, indicating a gap of EUR 
10-20 billion a year compared to the current baseline expenditure. 

Environmental Implementation Review 2022 – Denmark 

 
 
 
 
 
                                                                 
 
 
 
                                                                 
a  core  policy  priority.  The  following  environmental 
investment needs have been identified by sector. 

Pollution prevention & control 

The  EU’s  First  Clean  Air  Outlook160  under  the  clean  air 
programme estimated that the total air pollution control 
costs for Denmark to reach the NECD Emission Reduction 
Requirements  161  by  2030  amount  to  EUR  1  113  million 
per year, including EUR 807 million for capital investment 
(assuming 
its  2030  climate  and  energy 
targets)162. 

it  meets 

The Second EU’s Clean Air Outlook163 suggests that, if all 
relevant  legislation adopted  up to 2018  (including all air 
pollution and the 2030 climate and energy targets set in 
2018)  delivered  their  full  benefits  and  if  Member  States 
also  implemented  the  measures  announced  in  their 
NAPCPs,  the  EU  would  largely  achieve  the  reductions  of 
air pollutant emissions that correspond to the obligations 
under  the  NECD  for  2030,  except  for  ammonia  (NH3) 
emissions in 15 Member States, including Denmark.  

Water management 

for 

some 

resources, 

in  demand 

irrigation  will 

According  to  the  OECD164,  in  Denmark  surface  water  is 
scarce.  As  a  result,  groundwater  is  the  main  source  of 
drinking  water.  Although  Denmark  has  abundant 
groundwater 
regions  experience 
pressure on groundwater.  Urbanisation and a  significant 
increase 
increase 
competition for water resources, including groundwater. 
Intrusion  of  saltwater  from  sea  level  rise  may  affect  the 
quality  of  groundwater.  Despite  high 
levels  of 
expenditure  on  water  supply  and  sanitation,  there 
remains  a  small  compliance  gap  with  wastewater 
treatment. EU funding has provided a significant share of 
past  public  funding  over  the  past  decade.  It  is  also 
estimated that Denmark will need to invest an additional 
cumulative EUR 1 938 million by 2030 for drinking water 
and 
levels, 
corresponding  to  a  need  of  around  EUR  190  million 
investment (capital expenditure) per year, most of which 
(over  90%)  for    wastewater)165.  Moreover,  the  recent 

sanitation 

spending 

current 

over 

160 International Institute for Applied Systems Analysis (IIASA), Progress 
towards  the  achievement  of  the  EU's  air  quality  and  emissions 
objectives, 2018.  
161  Covering  the  reductions  of  and  the  emission  ceilings  for  5 
atmospheric  pollutants,  SOx,  NOx,  PM2.5,  NH3  and  VOC  by  2030, 
compared  to  2005.  Source:  Progress  towards  the  achievement  of  the 
EU’s  air  quality  and  emissions  objectives,  IIASA  2018.  (page  29). 
Requirements are based on  Directive (EU) 2016/2284.  
162 Directive (EU) 2003/35/EC repealing Directive (EU) 2011/81/EC 
163 COM(2021) 3 Final and Report Annex.   
164  OECD,  Financing  Water  Supply,  Sanitation  and  Flood  Protection: 
Challenges and Options, 2020. 
165  OECD,  Financing  a  Water  Secure  Future,  2022.  Country  Fact  Sheet 
Denmark, Country Fact Sheet Denmark, Page 4 

Denmark  33 

sixth Water Framework Directive and Floods  Directive166 
Implementation  Report  and  the  financial  -  economic 
study167  accompanying  it,  are  also  a  relevant  source  of 
information in this domain. 

Waste & the circular economy  

According to a Commission study168 to meet the recycling 
targets  for  municipal  waste  and  packaging  waste, 
Denmark  still  needs  to   invest  an  additional  EUR  290 
million   (around  EUR  41.5  million  per  year)  between 
2021-2027 in collection, recycling reprocessors, biowaste 
treatment,  waste  sorting  facilities  and  waste  registry 
facility 
this,  biowaste 
digitalisation.  Of 
replacement costs are EUR 26 million for 2021-27 (or 3.7 
million per year).  

treatment 

This does not include investment necessary for other key 
waste streams (plastics, textiles, furniture) or to unlock a 
higher uptake of circularity and waste prevention across 
the economy. 

Biodiversity and ecosystems 

The  prioritised  action  framework  (PAF)  adopted  by  the 
Member  States  under  Article  8  of  the  Habitats  Directive 
present  the  conservation  priorities  for  the  Natura  2000 
network  and  its  supporting  green  infrastructure,  their 
costs and planned funding sources for the current budget 
(2021-2027).  Denmark  has  not  yet  submitted  a  finalised 
PAF, which was expected by the end of 2021169.  

To  note  that  PAF  costs  exclude  the  additional  costs  to 
implement the biodiversity strategy to 2030, for instance 
on increased protection and restoration. 

EU environmental funding 2014-2020 

The multiannual financial framework (MFF) for the years 
(in 
2014-2020  allocated  almost  EUR  960  billion 
commitments,  2011  prices)170 
the  EU.  The 
commitment to achieving the green transition included a 

for 

166  Water  Framework  Directive  and  Floods  Directive  Implementation 
Reports – DG Environment – European Commission. 

167  European  Commission,  Directorate-General 
for  Environment, 
Economic  data  related  to  the  implementation  of  the  WFD  and  the  FD 
and the financing of measures, Final report, 2021. 

168  European  Commission,  Study  on  investment  needs  in  the  waste 
sector and on the financing of municipal waste management in Member 
States,  2019,  p.61.  This  is  an  EU-wide  study;    a  caveat  to  attach  to 
reasoning  in the  paragraph is  that  the  level  of  recycling  in Denmark  is 
not  directly  linked  to  the  level  of  investments  in  recycling  plants  in 
Denmark.  As  a  small  open  economy  most  of  Denmark’s  recyclable 
waste is exported for material recycling. 

169  The  N2K  Group,  Strengthening  investments  in  Natura  2000  and 
instruments  report  to  the 
improving  synergies  with  EU  funding 
European Commission, 2021. 
170 Council Regulation (EU, Euratom) No 1311/2013. 

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Denmark  34 

Figure  39:  ESI  Funds  allocated  to  Denmark,  including 
environmental investments, 2014-2020173 

20%  climate  spending  target  and  funding  opportunities 
for  the  environment,  in  particular,  under  the  European 
Structural  and  Investment  (ESI)  Funds171.  The  2014-2020 
budget  was  subsequently  topped  up  with  over  EUR  50 
billion  (current  prices)  from  REACT-EU  programme  for 
cohesion policy action against coronavirus (COVID-19)172.  

in 

invest 

Denmark received EUR 1 955.6 million from the ESI funds 
job  creation  and  a 
over  2014-2020  to 
sustainable  and  healthy  economy  and  environment. 
Planned  direct  environmental  investment  amounted  to 
EUR  180.1  million  with  a  further  EUR  32.9  million 
identified  as  indirect  environmental  investment  value, 
totalling  EUR  213  million  (Table  2).  Figure  39  gives  an 
overview  of  (planned)  individual  ESI  funds  earmarked 
specially  for  Denmark  (EU  amounts,  without  national 
amounts) 
the 
for 
environmental 
  REACT-EU 
investments  are  focused  on  green  technologies  and 
addressing climate change (carbon capture). 

the  2014-2020  period 
it  comprises. 

investments 

and 

171  The  European  Structural  and  Investment  (ESI)  funds  include  the 
European  Regional  Development  Fund  (ERDF),  the  Cohesion  Fund (CF) 
which does not apply to Denmark, the European Social Fund (ESF) with 
the  Youth  Employment  Initiative  (YEI),  the  European  Agricultural  Fund 
for  Rural  Development  (EAFRD)  and  the  European  Maritime  and 
Fisheries Fund (EMFF).   
172 Regulation (EU) 2020/2221. 

Table  2: Direct  and indirect environmental investments 
under the ESI Funds in Denmark, 2014-2020174 

Instrument 

Under Cohesion policy (ERDF) 
Direct environmental investments 
Indirect environmental investments 
energy efficiency 
business development, R&I 

Under EAFRD/rural development 
Direct environmental investments 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 

Allocations  
for the environment  
(EUR million) 

23.1 
0.0 
23.1 
18.5 
4.6 

52.8 
43.1 
43.1 
9.8 
4.2 
5.6 

173  European  Commission,  DG  Environment  -  DG  Environment  analysis 
based  on  ESI  Funds  Open  Data  Portal  (cohesiondata.ec.europa.eu), 
Integration of environmental concerns in Cohesion Policy Funds (COWI, 
2017),  Regulation  (EU)  No  1303/2013,Regulation  (EU)  2021/1060  and 
Implementing  Regulation  (EU)  No  215/2014.  Cut-off  date  for  data: 
December 2021. Environmental investments here are captured via the 
combined use of intervention fields  and coefficients under  Regulation 
(EU) No 1303/2013 and Regulation (EU) 2021/1060  allowing for a more 
precise 
identification  and  valuation  of  relevant  environmental 
investments. N.B. Indirect environmental investments are valued using 
the  Annex  I  environmental  coefficients  of    Regulation  (EU)  2021/1060 
(as opposed to the full value).    
174  European  Commission,  DG  Environment  -  Data analysis.  The  values 
of  environmental 
the  specific 
in 
environmental  areas  may  differ 
from  the  tracking  values  at 
cohesiondata.ec.europa.eu, e.g. for clean air or biodiversity due to two 
factors:  the  set  of  environmental  coefficients  used  and  the  range  of 
funds assessed. DG Environment’s analysis here  covered the full range 
of ESI Funds. See also previous footnote. 

identified  here 

investments 

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Denmark  35 

EU environmental funding 2021-2027 

The 2020 European Green Deal investment plan calls  for 
upon  EUR  1  trillion  in  green  investments  (public  and 
private) by 2030. The EU’s multiannual budget for  2021-
2027  and  the  NextGenerationEU  (NGEU)  Fund  will 
mobilise EUR 2.018 trillion  (in current  prices) to  support 
the COVID-19 recovery and the EU's long-term priorities, 
including  environmental  protection181.  Following  the  EU 
Green  Deal’s182 
the 
Interinstitutional  Agreement  on  the  2021-2027  MFF183, 
30% of the EU budget will support climate  action efforts 
and 7.5% (as of 2024) and 10% (as of 2026)  will support 
biodiversity.  These 
increased 
programming  of  financial  resources  for  biodiversity, 
specifically under the 2021-2027 Cohesion policy and the 
2023-2027 common agricultural policy.  

‘do  no  harm’  pledge  and 

latter  targets  require 

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 
EU  Taxonomy)184,  strengthens  non-financial  reporting 
requirements and facilitates green bond issuance (by the 
EU  green  bond  standard185).  Reinforced  by  the  renewed 
sustainable  finance  strategy  (2020)186  it  will  increase 
investment  flows  to  climate  and  environmental  action. 
To  help  finance  climate  adaptation  measures,  the  new 
strategy  on  adaptation  to  climate  change187  can  help 
close  the  insurance  protection  gap  from  climate-related 
events that are uninsured188. The EIB will align 50% of its 
lending with climate and environment by 2025189 with an 
EUR  250  billion  contribution  to  the  Green  Deal 
investment plan by 2027. 

Table  3: Key 2021-2027 EU funds allocated to Denmark 
(current prices) 

Instrument 

Country funding allocation 
(million EUR) 

Under EMFF 
Direct environmental investments 
environment  protection  &  resource 
efficiency 
Indirect environmental investments 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

137.0 
137.0 
137.0 

0.0 

213.0 
180.1 
32.9 

Funding for the environment from the ESI funds has also 
been  supplemented  by  other  EU  funding  programmes 
available  to  all  Member  States,  such  as,  the  LIFE 
programme,  Horizon  2020  or  loans  from  the  European 
Investment Bank (EIB), that add up to an estimated total 
of  EU  environmental  financing  of  EUR  316  million  for 
Denmark in 2014-2020  

is  entirely  dedicated 

The  LIFE  programme175 
to 
environmental  and  climate  objectives. 
finances 
demonstration and best practices to prepare the roll-out 
ofgreen  solutions.  Between  2014-2020  period,  Denmark 
received EU  funding for  11 LIFE projects  (for nature and 
environment)  with  EUR  49  million  from  the  LIFE 
programme (out of 1 028 EU27 LIFE projects with a total 
EU contribution of EUR 1.74 billion). 

It 

In  2014-2020,  the  Horizon  2020  programme  allocated 
some EUR 53.6 million to Denmark for the environment, 
in particular, for climate action, the circular economy and 
natural  resources,  with  a  total  environmental  share  of 
from  Denmark’s  Horizon  2020  allocation176. 
3.1% 
Denmark  did  not  use  funding  under  the  European  Fund 
for  Strategic  Investments,for  projects  with  a  dedicated 
environmental objective177. The environment-related EIB 
loans  to  Denmark  amounted  to  0.5  million  (supporting 
waste  and  water),  out  of  an  overall  EUR  4.7  billion  EIB 
lent to Denmark in the period178179. The country ranks  17 
in size in terms of total EIB lending. 

In 2020, the EIB provided EUR 24.2 billion to fight climate 
change, 37% of its total financing and EUR 1.8 billion (3% 
of financing) for the environment180.  

175 European Commission, LIFE Programme. 
176  EASME 
177 Approved and signed EFSI financing - EIB, 2015-2020 
178 EIB loans in EU countries in 2014-2020. 
179 EIB, Activity Report, 2021. 
180  The  EIB  Group  jointly  works  with  the  European  Commission  in 
implementing  several  programmes 
finance  environmental 
implementation: InvestEU,  the  successor  of  EFSI,  Pillar  II  and III  of  the 
Just  Transition  Mechanism.  The  EIB  Group  is    a  key  implementing 
partner for InvestEU with responsibility for managing 75% of the overall 
budget capacity of the mandate. 

that 

long-term  EU  budget  & 

181  European  Commission,  2021-2027 
NextGenerationEU. 
182 COM/2019/640 final. 
183 Interinstitutional Agreement, OJ L 433I. 
184 European Commission, EU taxonomy for sustainable activities 
185 EU Green Bond Standard - 2021/0191 (COD). 
186 COM (2021) 390 Final - European Commission, Strategy for Financing 
the Transition to a Sustainable Economy. 
187 COM(2021) 82 final. 
188  The  strategy  would  support  improved  insurance  gap  coverage 
including through the natural catastrophe markets as reflected with the 
EIOPA  (the  Association  for  European  Insurance  and  Occupational 
Pension Authorities) dashboard on insurance protection gap for natural 
catastrophes. See: The pilot dashboard on insurance protection gap for 
natural catastrophes). 
189 EIB Climate Bank Roadmap 2021-2025, November 2020. 

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Cohesion policy 

Total: 518.6190 

Figure 40: Climate expenditure in RRPs, 2021-2026200 

Denmark  36 

ERDF 

ESF+ 

ETC (ERDF) 

Just Transition Fund 

EAFRD/rural 
development  

under  CAP 
plans 2023-2027193 

strategic 

European  Maritime, 
and 
Fisheries 
Aquaculture 
Fund 
(EMFAF) 

Recovery 
and 
Resilience Facility (RRF)  

2021 – 2026196  

247.2191 

119.6 

153 

88.9 192 

379.7194 

201.0195 

1 551.4197 (grants) 

As  part  of  the  EU’s  Recovery  Package,  Denmark 
requested EUR 1.511 billion from the RRF, all in the form 
of  grants.  A  59.5%  share  of  RRF  funding  for  Denmark 
relates  to  measures  that  do  contribute  to  the  country’s 
climate and environmental objectives. This puts Denmark 
among  the  top  Member  States  (EU  average:  45.3%). 
Denmark also stands above the 37% climate expenditure 
target,  the  minimum 
level  required  under  the  RRF 
Regulation  (see  Figure  40)198.  The  main  green  priorities 
under  the  RRP  for  Denmark  are  to  achieve  a  green 
transition  in  agriculture,  energy  efficiency  and  green 
heating,  green  tax  reform,  sustainable  transport  and  to 
fund green research and development. 

Overall, the plan ensures that direct actions can be taken 
at local level to contribute to the green transition, while 
protecting  or 
in 
compliance  with  the  Do  No  Significant  Harm  (DNSH) 
principle 199. 

the  environment,  and 

restoring 

The  partnership  agreement  2021-27 
for  Denmark 
allocates ERDF funding to invest in promoting the circular 
economy  and  EMFAP  to  restore  water  bodies  to  good 
ecological  status,  both  under  priority  objective  2  (low 
carbon).  Denmark  satisfies  the  enabling  condition  for  a 
waste management plan allowing to fund investments in 
the  circular  economy.  However,  the  enabling  condition 
for  a  prioritised  action  framework  for  investments  in 
nature  and  biodiversity  is  not  fulfilled  as  a  final  version 
yet to be submitted. 

Under  the  NextGenerationEU Fund, the Commission  will 
issue up to EUR 250 billion of EU green bonds (one third  
of the NGEU) until 2026 that  meet   the general spirit of 
the  DNSH  principle.  But  this  will  not  be  subject  to  the 
current delegated acts on the EU Taxonomy and will not 
fully align with the proposed EU green bond standard. 

In  addition  to  EU  funds  earmarked  specifically  for 
Denmark in the 2021-2027 period, there are also funding 
programmes  available  at  EU  level  and  are  open  to  all 
Member  States.  These  include,  among  others,  the  LIFE 
programme201 (EUR 5.4 billion), Horizon Europe (EUR 95.5 
billion)202,  the  Connecting  Europe  Facility203  (EUR  33.7 
billion)204  and  the  funds  due  to  be  mobilised  under  

190  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
191N.B.  it  is  expected    to  transfer  EUR  106  million  from  ETC  to  ERDF 
giving a total of EUR 247.2 million. 
192  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
193 European Commission, CAP strategic plans. 
194 Regulation (EU) 2021/2115, Annex XI.  
195 Regulation (EU) 2021/1139, Annex V. 
196  The  actual  reforms  and  investments  under  the  RRF  must    be 
implemented by 31 December 2026.   
197 Council Implementinng Decision, FIN 515. 
198 Regulation (EU) 2021/241. 
199 COM(2021) 1054 final. 

200 European Commission. The contributions to climate objectives have 
been calculated using Annex VI of the RRF Regulation (EU) 2021/241. 
201 European Commission, LIFE Programme. 
202  European  Commission,  Multiannual  financial  framework  2021-2027 
(in commitments) - Current prices. 
203  The  CEF  (Transport)  includes also  EUR  11.3  billion transferred from 
the  Cohesion  Fund.  30%  of  the  transferred  amount  will  be  made 
available,  on a competitive  basis,  to  all  Member  States eligible  for  the 
Cohesion  Fund.  The  remaining  70%  will  be  allocated  in  line  with    the 
national allocations  until 31 December 2023. Any unspent amount, by 
that  date,  under  national  allocations    will  be  pooled  to  support  all 
Cohesion Fund’s Member States. 
204 Regulation (EU) 2021/1153. 

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InvestEU205.  They  will  also  support  the  green  transition, 
including 
innovation  projects  on 
environmental  protection  (Horizon  Europe)206,    clean 
transport  and  energy  (the  Connecting  Europe  Facility)207 
or sustainable infrastructure (InvestEU)208. 

and 

National environmental protection 
expenditure 

Total national spending on environmental protection (all 
current and capital expenditure)209 in the EU27 was EUR 
272.6  billion  in  2020,  representing  2%  of  the  common 
GDP  and    quite  stable  over  time.  Although  in  absolute 
figures  expenditure  is  concentrated  in  a  few  countries  , 
as a share of GDP, most countries spend  between 1-2%; 
Denmark spends around 2%. 

Of  the  above  total,  the  EU27’s  capital  expenditure 
(Capex)  on  environmental  protection  (i.e.  investment)  
amounted to EUR 56.3 billion in 2018, falling to EUR 54.5 
billion  in  2020,  representing  around  0.4%  of  GDP.  Most 
Member  States 
in 
environmental  protection.  Denmark  invested  0.4%  of 
GDP in 2018. During 2014-2020, this totalled  around EUR 
376 billion of environmental investment in the EU27, and  
EUR 9.1 billion for Denmark (see Figure 41). 

invested  0.2-0.5%  of  their  GDP 

205  The  InvestEU  Fund  is  expected  to  mobilise  over  EUR  372  billion  in 
investment through an EU budget guarantee of EUR 26.2 billion to back 
the investment of financial partners such as the EIB Group and others. 
206 European Commission, Horizon Europe. 
207 European Commission, Connecting Europe Facility. 
208 European Union, InvestEU. 
209  At  economy 
intermediate 
consumption and  capital  expenditure  of  households,  corporations  and 
governments related to environmental protection goods and services. It 
excludes EU funds, while may include some international expenditure in 
addition  to  domestic  expenditure.  Data  source:  Environmental 
Protection  Expenditure  Accounts  (EPEA),  Eurostat.  EPEA  accounts  are 
based  on  the  CEPA  2000  classification,  excluding  climate,  energy  and 
circular economy 

including  final  consumption, 

level, 

Denmark  37 

Figure 41: Direct and indirect environmental protection 
investments  in  the  EU-27  (EUR  million  and  %  of  GDP), 
2018210 

By institutional sector, 7.7% of Denmark’s environmental 
protection  investments  (capital  expenditure)  came  from 
the  general  government,  86%  from  specialist  producers 
(of environmental services, mainly waste and wastewater 
companies and 6.4% from the business sector’s (ancillary 
producers, i.e. whose environmental activities are usually 
ancillary to the core ones) expenditure. At EU level, 37% 
comes from governments, 33% from specialist producers 
and 30% from industry (business). 

210 Eurostat, Environmental Protection Expenditure Account, 2021. 

Environmental Implementation Review 2022 – Denmark 

 
                                                                 
 
 
                                                                 
 
Figure  42:  EU-27  Member  States'  environmental 
protection  investments  (Capex)  by  institutional  sectors 
(Total economy = 100%), 2018211 

restoration, based on the Climate Bonds Taxonomy being 
broadly similar to the EU Taxonomy214 (see Figure 43). 

Figure 43: Annual EU green bond issuance in 2020 (EUR 
billion)215 

Denmark  38 

of 

share 

environmental 

A  breakdown  of  investment  by  environmental  topic  is 
only partially available, at the level of institutional sectors 
(rather than at economy level), due to different reporting 
patterns212.  At  Denmark’s  general  government  level,  a 
significant 
protection 
investments  (around  60%)  went  on  environmental 
research  and  development  and  21%  on  biodiversity  in 
2018 
that  are  not 
comprehensive  or  fully  validated).  In  terms    of  the 
country’s  specialist  producers,  76%  of  investment  were 
received by wastewater and 24% by waste management 
bodies.  In  the  business  sector,  41%  of  investment  went 
on air protection, 20% on wastewater and 9% on waste, 
the most significant areas of investment (see Figure 42). 

(based  on  available  data 

Green budget tools 

Green taxation and tax reform  

revenue 

absolute 

terms,  Denmark’s 

from 
In 
environmentally  related  taxes  remains  around  the    EU 
average  in  2020,  as  shown  in  Figure  44.  Within  this, 
energy  and  transport  taxation  represent  the  highest 
share  with  52.2%  and  42.5% 
in  2020,  while 
pollution/resource tax accounted for 5.3%. In terms of % 
of  GDP,  environmental  taxes  accounted  for  3.17%  in 
2020, the third highest in the EU (EU average is 2.24 %). 

The  total  annual  European  green  bond  issuance  in  2020 
was USD 156 billion (EUR 137 billion213), rising from USD 
117 billion (EUR 105 billion) in 2019, including some non-
EU  European  countries.  By  EU27  Member  States  only 
2020  annual  green  bond  issuance  was  EUR  124  billion, 
including EUR 1.95 billion issued by Denmark. 83% of the 
green bonds issued by European countries served energy, 
buildings or transport objectives between 2014-2020, 8% 
supported  water  and  waste,  and  an  additional  6%  for 
land  use  –  with  links  to  ecosystem  conservation  & 

211 Eurostat, Environmental Protection Expenditure Accounts (env_epe). 
212  Data  reporting  differs  for  the  three  institutional  sectors,  leading  to 
aggregation  difficulties.  Specialist  companies  provide  comprehensive 
data  across  all  environmental  areas  (CEPA  1-9),  while  this  is  less  the 
case  for  general  government  and  industry  that  often  report  (the  non-
obligatory)  data  in  merged  categories  only  (making  it    difficult  to 
provide a breakdown) or not at all. 
213 At Eurostat’s annual average EUR/USD exchange rates. 

Interactive  Data  Platform  at  www.climatebonds.net.  Further 

214 
information on Climate Bonds Taxonomy. 
215 Climate Bonds Initiative, 2022. 

Environmental Implementation Review 2022 – Denmark 

 
 
                                                                 
 
 
 
                                                                 
 
Figure 44: Environmental taxes in the EU-27, 2020216 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience, foster a fairer society and a just transition, by 
sending the right price signals and incentives to economic 
actors.  The  Green  Deal  creates  the  context  for  broad-
based tax reforms, for the removal of fossil fuel subsidies, 
shifting the tax burden from labour to pollution, and for 
factoring  in  social  considerations217.  The  application  of 
the  ‘polluter  pays  principle’  218  stipulating  that  polluters 
should bear the cost of measures to prevent, control and 
remedy  pollution  is  facilitated  by  the  EU  Commission’s 
TSI flagship on greening taxes. 

In  Denmark  there  are  many  examples  of  green  tax 
reform219,  notably  on  phosphorus  and  pesticides. 
Denmark could consider bringing in a system of tradable 
livestock rights to reduce ammonia. 

Environmentally-harmful subsidies 

Addressing  and 
removing  environmentally  harmful 
subsidies is a further step towards wider fiscal reforms220.  

Fossil  fuel  subsidies  are  costly  for  public  budgets  and 
undermin  the achievement of the Green Deal objectives. 
In  many  cases  they  also  go  against  incentives  for  green 
investments  and  distort  the  playing  field.  Fossil  fuel 
subsidies fluctuate around EUR 55 billion in the EU since 

Denmark  39 

2015. They rose by 4% between 2015 and 2019, however 
some countries, such as Latvia, Lithuania Sweden, Greece 
or  Ireland,  managed  to  decrease  them.  In  the  EU, 
subsidies  for  petroleum  products,  in  sectors  such  as 
transport  and  agriculture,  continued  to  rise  over  this 
period, whereas subsidies on coal and lignite  fell, largely 
owing  to  the  falling  role  of  solid  fuels  in  electricity 
generation. As a share of GDP, fossil fuel subsidies ranged 
from 1.2% in Hungary to less than 0.1% in Luxembourg in 
2019  (0.4%  on  EU  average).  Total  fossil  fuel  subsidies 
amounted  to  EUR  1.4  billion  in  Denmark  in  2019  – 
representing 0.4% of GDP (around the EU-average). 

In  2020,  the  total  amount  of  fossil  fuel  subsidies  fell  to 
EUR  52  billion  (due  to  falling  consumption  trends  amid 
the COVID-19-related restrictions). Unless action is taken 
by  the  Member  States  ,  these  subsidies  are  likely  to 
rebound as economic activity picks up from 2020221. 

Further details of the situation in Denmark  are shown in 
Figure 45. 

Figure  45:  Trends  in  natural  gas,  petroleum  products 
and coal subsidies in Denmark222 

% GDP 

Natural 
gas 

Petroleum 
products 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

No 
data 

No 
data 

No 
data 

No 
data 

0,01 

0,03 

0,04 

0,07 

0,30 

0,29 

0,29 

0,27 

0,34 

0,34 

0,34 

0,34 

Coal 

0,05 

0,05 

No 
data 

No 
data 

No 
data 

No  

No  

data 

data 

No 
data 

216 Eurostat, Environmental taxes accounts (env_eta). 
217  European  Commission,  The  European  Green  Deal,  COM  (2019/640 
final), p.17 
218  Article  191(2)  of  the  Treaty  on  the  Functioning  of  the  European 
Union:  “Union  policy  on  the  environment  (…)  shall  be  based  on  the 
precautionary  principle  and  on  the  principles  that  preventive  action 
should  be  taken,  that  environmental  damage  should  as  a  priority  be 
rectified at source and that the polluter should pay”. 
219 European Commission, 2021, Ensuring that Polluters Pay - Denmark 
220  European  Commission,  Study  on  assessing  th  environmental  fiscal 
reform potential for the EU 28, 2016. 

Current green budgeting practices 

Green  budgeting  encompasses  multiple  climate  and 
environmental  tagging  and  tracking  practices  in  budgets 
with some Member States already using green budgeting 

221 State of the Energy Union reports, COM(2021) 950 and Annex 
222 OECD, Fossil Fuel Subsidy Tracker.. 

Environmental Implementation Review 2022 – Denmark 

 
 
 
                                                                 
 
                                                                 
elements.223  Green  budgeting  helps  identify  and  track 
green  expenditure  and  green  revenues  to 
increase 
transparency  on  the  environmental 
implications  of 
improve  policy  coherence  and 
budgetary  policies, 
(including  climate  and 
supporting  green  policies 
environmental objectives).224 

The  EU  has  also  developed  climate  proofing  and 
to  assess  project 
sustainability  proofing  guidance 
eligibility  and  compliance  with  environmental  legislation 
and  criteria.225  The  European  Commission  drew  up    a 
green budgeting reference framework226 and launched a 
technical  support  flagship  (TSI)  on  green  budgeting  in 
2021  to  assist  Member  States  in  drafting  or  developing 
national  green  budgeting  frameworks  to  improve  policy 
coherence  and  for  the  green  transition.  Denmark 
participated 
the  European  Commission’s  green 
budgeting project with a training 24 February 2022227. 

in 

(a 

development 

a 
under 

policies, 
impacts 

new  macroeconomic  model, 
Denmark 
has 
GreenREFORM, 
dynamic 
computable general model). The aim with the model is to 
enable  the  fiscal  and  economic  planning  to  support  the 
green  transition.  The  model  is  being  developed  by  the 
independent governmental institution the DREAM group, 
and  the  project  is  primarily  financed  by  the  Danish 
Ministry of Finance, which also contributes to the model 
development  and  intends  to  implement  and  use  the 
model when it is ready. The model is designed to assess 
the  future  economic  and  fiscal  impacts  of  climate  and 
and 
environmental 
environmental 
policies. 
GreenREFORM describes the energy use and emission of 
pollutants  in  the  energy  and  air  emissions  accounts 
produced  by  Statistics  Denmark 
from  all  Danish 
businesses, households, and the public sector. The model 
also  describes 
from 
environmental  taxes,  subsidies,  and  other  regulations. 
The  model  produces  annual  projections  up  to  2100, 
which  aids  medium-to-long-term  fiscal  and  economic 
analysis.  The  projections  enable  an  assessment  of  the 
effect  of  future  economic  developments  on  the  climate 
and  environment  and  whether  these  developments  are 
consistent  with  climate  and  environmental  targets.  This 
functionality will enable Denmark to position climate and 

effect  on  emissions 

the 
economic 

and 
of 

climate 

the 

Denmark  40 

environmental  policy  centrally  when  preparing 
medium-term fiscal framework228. 

its 

Overall financing compared to the needs 

The  overall  environmental  financing  for  investments  is 
estimated  to  reach    0.6-0.7%  of  GDP  in  the  2014-2020 
period in the European Union, taking into account major 
EU  funds  and  national  financing.  This  ranged  from  0.3% 
(Ireland)  to  1.91%  (Bulgaria),  linked  to  the  level  of 
environmental  challenges  in  the  Member  States.  In  the 
2021-2027  period, 
the  overall  EU  environmental 
investment  needs  are  estimated  to    range  between  0.9-
1.5%  of  the  projected  GDP  (2021-2027),  suggesting  a 
potential environmental financing gap of 0.6-0.8% of GDP 
at  EU  level,  previous  financing  levels  maintained  (see 
Figure 46)229. 

Figure 46: Total environmental financing baseline (2014-
2020) and estimated needs (2020 - 2030) in the EU27 (% 
of GDP)230  

Denmark’s  environmental  financing  for  investments  is 
estimated  to  have  been  0.57%  of  GDP  in  2014-2020, 
almost  exclusively  from  national  sources.  From  2021-
investment  needs  of  the 
2027,  the  environmental 

223 European Commission, Green Budgeting Practices in the EU: A First 
Review, 2021. The term tagging is explained on p.7. 
224  European  Commission,  European  Commission  Green  Budgeting 
Reference  Framework.  European  Commission,  Green  Budgeting  in  the 
EU Key insights from the 2021 Commission survey. 
225 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 
226  European  Commission,  Green  Budgeting  Reference  Framework, 
based  on  the  review  of  the  OECD  Paris  Collaborative  on  Green 
Budgeting initiative, 2017. 
227 Green budgeting TSI participation 

228 OECD, European Commission, IMF, 2021  Green Budgeting: Towards 
Common Principles, p.12 
229 Source: DG Environment data analysis. EU financing sources covered: 
ESI  Funds  (ERDF,  CF,  ESF,  YEI,  EAFRD,  EMFF),  Horizon  2020,  LIFE,  EFSI 
(EU amount), EIB loans. National financing: total national environmental 
protection  capital  expenditure  (investments)  -  source:  Eurostat  EPEA 
dataset.  Cut-off  date  for  data:  end  2021.  N.B.  The  total  financing  may 
be  higher,  in particular  through further  indirect  investments,  requiring 
further analysis in the future.   
230 Eurostat; ESI Funds Open Data, 2021. 

Environmental Implementation Review 2022 – Denmark 

 
                                                                 
 
 
 
                                                                 
Denmark  41 

country are estimated to be at least 0.72% of GDP (with 
partial  information  available  at  country  level,  excluding 
e.g. nature protection costs in the lack of a finalised PAF, 
‘higher  circularity  needs’  for 
water  protection  and 
example  related  to  2022  Commission  proposal  on 
sustainable product policy and eco-design231), suggesting 
an  environmental  financing  gap  of  at  least  0.15%  of  the 
GDP, likely to be higher when also accounting for needs 
currently estimated at EU level only (e.g. water protetion, 
circularity, biodiversity strategy etc.) to be addressed  by 
for  environmental 
mobilising  additional 
implementation priorities.  

financing 

2022 priority actions 

No  priority  actions  were  proposed  for  Denmark  in  the 
2019  and  none  are  proposed  for  2022.  It  can  be 
highlighted that, based on the data available, the share of 
private environmental financing in Denmark is high (over 
80%)  that  can  provide  useful  examples  for  other  
Member  States  on  using  more  effectively 
the 
involvement of private financing.  

231 European Commission, Sustainable product policy and design 

Environmental Implementation Review 2022 – Denmark 

 
 
                                                                 
Denmark  42 

6. Environmental governance 

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention:  
(i) access to information;  
(ii) public participation in decision making; 
(iii) access to justice in environmental matters.  
It is of crucial importance to public authorities, the public 
and businesses that environmental information is shared 
efficiently  and  effectively232.  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 environment233. It includes the right to bring 
legal challenges (‘legal standing’)234.  

Environmental information 

the 

This section focuses on Denmark’s implementation of the 
INSPIRE  Directive235.  The  aim  of 
INSPIRE 
(Infrastructure  for  Spatial  Information  in  Europe)236  is  to  
establish a  European spatial data  infrastructure  to share 
information  between  public 
environmental  spatial 
authorities  across  Europe,  assist  in  policy-making  across 
boundaries  and 
this 
information.  Geographic  information  is  needed  for  good 
governance  at  all  levels  and  should  be  readily  and 
transparently  available.  Denmark’s  implementation  of 
the INSPIRE Directive could be better. Slow progress has 
been  made  on  data  identification  and  documentation, 
and  implementation  levels  are  good.  However,  more 
efforts are needed to make data  more widely accessible 
(see Table 4). 

facilitate  public  access 

to 

Table  4:  Country  dashboard  on  the  implementation  of 
the INSPIRE Directive, 2016-2020237 

232  The  Aarhus  Convention,  the  Access  to  Environmental  Information 
Directive  (Directive  2003/4/EC)  and  the  INSPIRE  Directive  (Directive 
2007/2/EC)  together  create  a  legal  foundation  for  the  sharing  of 
environmental  information  between  public  authorities  and  with  the 
public. This EIR focuses on the INSPIRE Directive's implementation.  
233 These guarantees are explained in the Commission Notice on access 
to  justice  in  environmental  matters,  OJL  275,  18.8.2017  and  a  related 
Citizen's Guide. 
234  This  EIR  focuses  on  the  means  implemented  by  Member  States  to 
guarantee  rights  of  access  to  justice,  legal  standing  and  to  overcome 
other major barriers to bringing cases on nature and air pollution. 
235 INSPIRE  
236 INSPIRE  
237 INSPIRE knowledge base Denmark, 2021. 

2016 

2020 

Legend 

Effective  coordination  and  data 
sharing 

Ensure effective 
coordination  

sharing 

Data 
without 
obstacle  

■ 

■ 

■ 

■ 

INSPIRE performance indicators 

i. Conformity of 
metadata  

ii.  Conformity 
of  spatial  data 
sets238 

iii.  Accessibility 
of  spatial  data 
through 
sets 
view 
and 
download 
services 

iv.  Conformity 
of 
network 
services 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

■ Implementation 
of this provision is 
well advanced or 
(nearly) completed. 
Outstanding issues 
are minor and can be 
addressed easily. 
Percentage: >89% 

■ Implementation of 
this provision has 
started and made 
some or substantial 
progress but is still 
not close to be 
complete. 
Percentage: 31–89% 

■  Implementation 
of this provision is 
falling significantly 
behind. Serious 
efforts are necessary 
to close 
implementation gap. 
Percentage: <31% 

Denmark  had  a  priority  action  in  2019  on  the  need  to 
improve  access  to  spatial  data  and  services  and  make 
stronger  links  to  the  country  INSPIRE  portals,  where 
some progress can be seen. Therefore no priority action 
is proposed in 2022. 

Public participation  

for 

responsible 

implementing 
Planning  authorities 
Environmental 
Impact  Assessment  (EIA)  may  be  at 
national,  municipality,  or  local  level,  depending  on  the 
nature of the project. The planning authority in question 
must  publish  the  hearing  on  its  own  website,  and  the 
process  may  be  conducted  using  the  national  portal 
“Høringsportalen”239. The long-term ambition is to make 
Høringsportalen  a  single  point  of  entry  for  all  public 

238  In  2016,  the  deadlines  for  implementation  of  the  spatial  data 
interoperability were still in the future: 23.11.2017 for Annex I data and 
21.10.2020  for  Annex  II  and  III  data.  This  conformity  indicator  will  in 
many cases never reach 100% as most  countries provide as-is-data sets 
in addition to the INSPIRE harmonised data sets 
239 Høringsportalen 

Environmental Implementation Review 2022 – Denmark 

 
                                                                 
 
  
 
                                                                 
irrespective  of  the  competent 
hearings  in  Denmark 
authority  (government,  national  authorities,  municipal 
councils  etc.).  Currently  the  use  of  the  portal  is  only 
mandatory  for  state  authorities  in  all  EIA  and  Strategic 
Environment  Assessment  (SEA)  procedures,  and  only  for 
limited cases for municipalities and local authorities. The 
wide  range  of  administrations  responsible  for  EIA  and 
SEA  procedures  results  in  a  lack  of  available  data  at 
national  level  on  public  participation.  Extending  the  use 
of  the  national  portal  would  clearly  facilitate  data 
collation and publication on participation rates. 

As regards the EIA Directive, Denmark is currently subject 
infringement  procedure240.  The  shortcomings 
to  an 
include  unclear  national  rules  for  adopting  projects  by 
legislative  acts,  incorrect  application  of  the  provisions 
governing consultation of the public and  authorities and 
incorrect  national  provisions  on  the  required  content  of 
development consent decisions.  

Access to justice  

Physical  and 
challenge environmental adminsitrative decisions. 

legal  persons, 

including  NGOs,  may 

The  Danish  Act  on  Environmental  Assessment  applies  a 
very broad scope  and definition for any type of plans or 
programmes,  including  informal  plans  or  programmes. 
The  administrative  appeals  boards  provide  information 
in 
on  how 
environmental  matters.  In  general,  a  digital  platform 
must  be  used 
for  administrative  appeals.  The 
Environmental  Protection  Agency  (EPA)  also  provides 
in  environmental 
information  on  access  to 
matters. 

to  submit  an  administrative  appeal 

justice 

legally  binding  normative 

In  general,  there  are  no  options  for  administrative 
appeals regarding executive regulations and/or generally 
instruments.  If, 
applicable 
however, such executive regulations are to be considered 
a plan or a programme falling under the scope of the SEA 
requirements  under 
the  Act  on  Environmental 
Assessment,  the  rules  on  administrative  appeals  in  the 
Environmental  Assessment  Act  will  apply  as  regards  the 
environmental assessment. 

There are no specific rules however on judicial review of 
executive regulations. The general rule on judicial review 
in  Section  63  of  the  Danish  Constitution  also  includes 
access to review executive regulations and their legality. 
Thus,  executive  regulations  can  only  be  challenged  in 
courts  e.g.  as  regards  their  legal  basis  in  the  relevant 
legislation and their compliance with EU law. 

240 
2021_infringements_package__key_decisions 

European 

Commission, 

October 

Denmark  43 

It can be concluded that Denmark has a system of regular 
supervision  of  regulatory  legally  binding  acts  but  it  is 
hardly  accessible  for  members  of  the  public  and  NGOs, 
who  can  only  call  alert  bodies  or  officials  entitled  to 
initiate an extraordinary supervision procedure. 

2022 priority actions 

in 

datasets 

environmental 

  make  spatial  data  more  widely  accessible  and 
the 
prioritise 
implementation  of  the  INSPIRE  Directive,  especially 
those  identified  as  high-value  spatial  datasets  for 
implementing environmental legislation;  
improve  access  to  courts  by  the  public  concerned 
when  challenging  administrative  or 
regulatory 
decisions  and  omissions,  in  particular  under  water, 
nature and air quality; 

 

  consider 

collating  and  publishing  data 

from 
Høringsportalen  (national  hearings  portal)  on  public 
participation. 

Compliance assurance  

to  ensure 

Environmental compliance assurance covers all the work 
that 
undertaken  by  public  authorities 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect water, air and nature, and manage waste241.  
It includes support measures provided by the authorities 
such as: 
(i) compliance promotion 242;  
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring 243;  
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement244.  
Citizen  science  and  complaints  enable  authorities  to 
liability245 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage.  

Compliance promotion and monitoring 

information 

Comprehensive 
is  available  online  on 
technical and regulatory aspects of the Nature Directives 
and  the  Nitrates  Directive.  In  addition,  the  EPA  has 
published guidance to help livestock farmers understand 

241  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.  
242 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation.  
243 This EIR focuses on inspections of major industrial installations.  
244  This  EIR  focuses  on  the  availability  of  enforcement  data  and  co-
ordination between authorities to tackle environmental crime. 
245  The  Environmental  Liability  Directive,  2004/35,  creates  the 
framework. 

Environmental Implementation Review 2022 – Denmark 

 
                                                                 
 
                                                                 
and comply with the environmental requirements of the 
Nitrates  Directive246.  Farmers  can  find  guidance  on 
matters  such  as  permit 
requirements  and  other 
regulatory requirements, and administrative procedures, 
government 
in 
information  on  nature  protection  specifically  aimed  at 
farmers  is  limited,  the  EPA  website  on  Natura  2000 
includes  a  section  addressed  to  landowners  of  Natura 
2000 sites with a section about nature in agriculture247. 

format.  Although 

searchable 

a 

inspections, 

including 
Information  on 

Responsibility  for  permitting  under  the  IED,  and  for 
monitoring  compliance,  is  shared  between  the  EPA,  and 
municipalities,  which  are  responsible  for  some  specific 
categories of industry. The EPA sets out formal guidelines 
those  carried  out  by 
for 
municipalities. 
including 
reports, and on other permitting activities is submitted to 
the  EPA  via  its  Digital  Environmental  Administration 
(DMA)248.  Reports  are  not  published,  but  may  be 
requested  by  members  of  the  public  under  freedom  of 
information 
legislation.  Denmark  does  not  publish  
environmental statistics or annual activity reports linked 
to these environmental inspections. 

inspections, 

Complaint handling and citizen science 

information,  on 

The  EPA  has  guidance  on  submitting  complaints,  and 
its  website249.  The  various 
contact 
departments  are  listed  with  links  to  their  functions, 
contact  information  and  opening  hours.  Information  is 
also  provided  on  the  confidentiality  and  anonymity  of 
complaints  in  order  for  citizens  to  feel  safe  in  their 
communication with the authorities. There is also specific 
‘whistleblower’  information  for  citizens  who  want  to 
contact an authority anonymously250. The information on 
the EPA website is,  however, brief and may not  be  easy 
for people to navigate. 

The  Environment  and  Food  Complaint  Board  has  more 
detailed  and  accessible  information  on  its  website251. 
Most significantly it contains a ‘Klageportalen’ (Complaint 
Portal)  that  provides  a  secure  access  to  submit 
gives 
complaints. 
comprehensive  guidance  on  the  use  of  the  Portal,  and 
explains what happens after submitting a complaint252. 

Board’s  website 

also 

The 

Statistics  on 
whistleblowing cases do not appear to be compiled. 

the  use  of  public  complaints  or 

246 Danish EPA Guidance on livestock farming  
247 Nature in Agriculture f 
248 Digital Environmental Administration  
249  Contact the Danish Environmental Protection Agency  
250 The Ministry of the Environment's handling of inquiries from citizens 
about possible offences  
251Environment and Food Complaints Board  
252 FAQ on “Klageportalen 

Denmark  44 

Enforcement 

Denmark  does  not  keep  a  publicly  available  database  of 
environmental prosecutions. The EPA formerly published 
an  annual  overview  of  environmental  criminal  cases  but 
it has not provided this information for years. 

Cooperation  and  coordination  among  the  Danish  bodies 
responsible  for  tackling  environmental  crime  appears  to 
function well, despite the lack of formal agreements. The 
police have developed informal cooperation with the EPA 
to better prepare cases that are to be referred to them. 
The  Director  of  Public  Prosecutions  Office  runs  courses 
on  handling  environmental  crime  cases,  which  it  also 
makes  available  also  to  staff  from  the  EPA,  police,  and 
courts service. 

Environmental Liability Directive (ELD) 

The  EPA  has  a  web  page  specifically  for  ELD  cases253; 
although  only  two  cases  has  been  published  so  far,  as 
only  ‘serious’  damages  are  considered  falling  within  the 
ELD.  Prevention  cases  do  not  seem  to  be  included.  In 
each  case,  a  full  description  of  the  investigation  carried 
out  and  final  decision  are  provided.  Neither  appear  to 
have  resulted  in  financial  costs  to  the  private  sector. 
There  does  not  appear 
to  be  an  overview  of 
environmental  damage  cases  under  other  legislation. 
Denmark  has  not  updated  its  legislation  on  financial 
security  since  the  2019  EIR,  although  some  Danish 
insurance  companies  do  offer  cover  for  ELD  liabilities. 
Furthermore, the Commission urged Denmark in 2019 to 
correctly incorporate rules on environmental liability into 
its  national  law,  to  ensure  sufficient  protection  for  the 
public.  This  case  is  now  closed,  but  Denmark  is  still 
subject  to  an  infringement  procedure  for  failure  to 
correctly  transpose  Article  12(1),  first  sub-paragraph  of 
the ELD with regard to the prevention and remedying of 
environmental  damage  as  interpreted  by  the  CJEU  in 
Case C-529/15. 

In 2019 Denmark  had four priority actions. The first  was 
to better inform the public about compliance promotion, 
monitoring  and  enforcement,  where  there  has  been 
limited  progress.  The  second  and  third  were  related  to 
the  ELD  on  extending  insurance  cover  and  improving 
financial security for liabilities and publishing information 
on environmental damage, where there has been limited 
progress.  The  fourth  was  on  publishing  information  on 
the outcome of enforcement action and the follow-up of 
detected  cross-compliance  on  breaches  on  nitrates  and 
nature; here too there has been limited progress. 

2022 priority actions 

253 Environmental damage (Environmental Liability Directive)  

Environmental Implementation Review 2022 – Denmark 

 
                                                                 
                                                                 
Denmark  45 

In the 2019 EIR Denmark had a priority action on further 
improving  its  overall  environmental  governance.  The 
evidence  presented  here  is  that  there  has  been  some 
progress, so no priority action is proposed for 2022. 

Reforms through the Commission’s technical 
support instrument 

The Commission supports environmental implementation 
and  the  green  transition,  not  only  through  the  EU 
financing  programmess,  but  also  granting  technical 
assistance such as the technical support instrument (TSI). 
The  Commission’s  2021  TSI  supported  a  project  related 
to  energy  transition  in  Denmark.  Then  under  the  TSI 
2022, Denmark is running  two projects of environmental 
relevance: i) the development of resilient, innovative and 
human  centred  digital  government  service,  which  is 
applied to the circular economy, and  ii) the Digitilisation 
of  the  East  Atlantic  Flyway  for  birds  in  the  Wadden  Sea 
(together with Germany and The Netherlands). 

TAIEX EIR peer to peer projects 

The TAIEX EIR peer to peer tool257 has been launched by 
learning 
the  Commission  to  facilitating  peer-to-peer 
between environmental authorities. During the reporting 
period,  Denmark  has  taken  part  in  three  TAIEX  EIR 
multicountry  workshop  on  EU  Timber  Regulation  Nordic 
Baltic  Competent  Authorities  (2019),  ammonia  reducing 
technology  and  measures  (2021)  and  zero  pollution 
(2022). 

 

 

 

improve  the  availability  of  practical  information 
for  farmers  on  compliance  with  the  Nature 
Directives; 
improve  the  publicly  available  information  on 
to 
the 
environmental 
including  through 
the publication of regular summary data; 
improve the information provided on ELD cases, 
including data on costs.  

inspections, 

complaints 

follow-up 

and 

to 

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 

Denmark ranks first out of 180 in the 2020 Environmental 
Index254.  At  present,  the  number  of 
Performance 
complaints and infringements in the environmental field 
can be considered below the EU average. 

Denmark  has  an  advanced  use  of  digital  or  innovative 
solutions  in  environmental  policy  as  mentioned  under 
Compliance  Assurance,  under  the  Technical  Support 
Instrument and also on  water policy (see section 3). 

Coordination and integration  

As  mentioned  in  the  2017  and  2019  EIR  Reports,  the 
transposition  of  the  revised  EIA  Directive255  provided  an 
opportunity  to  streamline  the  regulatory  framework  on 
environmental  assessments.  Denmark  transposed  the 
revised  Directive;  there  is  currently  an  infringement 
open, covering public consultation. 

in  order 

The  Commission  encourages  the  streamlining  of  the 
reduce 
environmental  assessments 
duplication  and  avoid  overlaps 
in  environmental 
assessments 
projects.  Moreover, 
streamlining  helps  reducing  unnecessary  administrative 
burden  and  accelerates  decision-making,  without 
compromising 
the  environmental 
assessment procedure256. 

the  quality  of 

applicable 

to 

to 

254 Environmental Performance Index  
255 Directive 2014/52/EU of the European Parliament and of the Council 
of 16 April 2014 amending Directive 2011/92/EU on the assessment of 
the effects of certain public and private projects on the environment 
256 The Commission issued a guidance document in 2016 on setting up 
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.  
257TAIEX  -  Environmental  Implementation  Review  -  PEER  TO  PEER  - 
Environment - European Commission. 

Environmental Implementation Review 2022 – Denmark