COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review 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 2025 Environmental Implementation Review for prosperity and security
Date: 2025-07-07
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, 7.7.2025  SWD(2025) 306 final  COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review        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 2025 Environmental Implementation Review for prosperity and security         {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 302 final} - {SWD(2025) 303 final} - {SWD(2025) 304 final} - {SWD(2025) 305 final} - {SWD(2025) 307 final} - {SWD(2025) 308 final} - {SWD(2025) 309 final} - {SWD(2025) 310 final} - {SWD(2025) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 319 final} - {SWD(2025) 320 final} - {SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}  
 
 
 
 
 
 
 
 
 
Denmark  2 

Contents 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT .............................................................................................. 4 
Transitioning to a circular economy...................................................................................................................... 4 
Waste management ............................................................................................................................................. 6 

2. BIODIVERSITY AND NATURAL CAPITAL ............................................................................................................... 12 
Global and EU biodiversity frameworks .............................................................................................................. 12 
Nature protection and restoration – Natura 2000.............................................................................................. 12 
Recovery of species ............................................................................................................................................. 14 
Recovery of ecosystems ...................................................................................................................................... 16 
Prevention and management of invasive alien species ...................................................................................... 21 
Ecosystem assessment and accounting .............................................................................................................. 22 

3. ZERO POLLUTION ................................................................................................................................................ 24 
Clean air .............................................................................................................................................................. 24 
Industrial emissions ............................................................................................................................................ 25 
Major industrial accidents prevention – Seveso ................................................................................................. 27 
Mercury Regulation ............................................................................................................................................ 29 
Noise ................................................................................................................................................................... 29 
Water quality and management......................................................................................................................... 30 
Chemicals ............................................................................................................................................................ 34 

4. CLIMATE ACTION................................................................................................................................................. 37 
The EU emissions trading system ........................................................................................................................ 37 
Effort sharing ...................................................................................................................................................... 38 
Land use, land-use change and forestry ............................................................................................................. 39 
Adaptation to climate change ............................................................................................................................ 39 

PART II: ENABLING FRAMEWORK – IMPLEMENTATION TOOLS ............................................................................ 40 

5. FINANCING .......................................................................................................................................................... 40 
Climate finance landmarks ................................................................................................................................. 40 
Environmental financing and investments .......................................................................................................... 41 
Public financial management ............................................................................................................................. 45 

6. ENVIRONMENTAL GOVERNANCE ........................................................................................................................ 48 
Information, public participation and access to justice ...................................................................................... 48 
Compliance assurance ........................................................................................................................................ 50 
EU-supported environmental capacity building .................................................................................................. 53 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
 
 
 
 
 
 
Denmark  3 

Executive summary 

In  May  2016,  the  European  Commission  launched  the 
Environmental  Implementation  Review  (EIR),  a  regular 
reporting 
tool  based  on  analysis,  dialogue  and 
collaboration  with  EU  Member  States  to  improve  the 
implementation  of  existing  EU  environmental  policy  and 
legislation (1). Following previous cycles in 2017, 2019 and 
2022,  this  report  assesses  the  progress  made  while 
the  main  outstanding  challenges  and 
describing 
opportunities 
legal 
implementation in Denmark. The purpose of this report is 
to  provide 
implementation 
performance  and  highlight  the  most  effective  ways  to 
address  the  implementation  gaps  that  impact  human 
health  and  the  environment  and  hamper  the  economic 
development  and  competitiveness  of  the  country.  The 
report relies on detailed sectoral implementation reports 
collected  or  issued  by  the  Commission  under  specific 
environmental legislation. 

information  on 

environmental 

regarding 

the 

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  taking  into 
consideration 
factors  such  as  the  gravity  of  the 
environmental implementation issue in light of the impact 
on the quality of life of the citizens, the distance to target 
and financial implications. 

On biodiversity, most habitats and species covered by the 
Habitats  Directive  are  in  an  unfavourable  conservation 
status  in  Denmark,  mainly  due  to  intensive  agricultural 
practices  and  mixed  sources  of  pollution  but  also  other 
pressures.  The 
favourable 
share  of  habitats 
conservation  status  is  the  second  lowest  in  the  EU.  The 
share  of  Natura  2000  marine  area  is  well  above  the  EU 
average  in  Denmark,  but  the  share  of  Natura  2000  land 
area out of the total national territory is the smallest in the 
EU.  

in 

legal  requirements 

On  water  quality,  the  overall  condition  of  groundwater 
is  good  and  urban  wastewater 
and  bathing  water 
treatment  complies  with  the 
in 
Denmark.  By  contrast,  surface  waters  are  in  a  fragile 
ecological  status.  Nutrients  from  intensive  agricultural 
practices cause eutrophication and oxygen depletion. The 
main  reason  is  phosphorus  for  lakes  and  nitrates  for 
coastal  waters.  The  chemical  status  of  most  surface 
waterbodies  is  unknown,  the  small  sample  of  classified 

(1) 

from 

the  Commission 

Communication 
the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Delivering  the 
benefits  of  EU  environmental  policies  through  a  regular 
environmental  implementation  review,  COM(2016) 316  final  of 

to 

surface waterbodies suggests a worsening chemical water 
status  caused  by  toxic  pollutants  such  as  mercury, 
anthracene, cadmium, lead and nonylphenols. The source 
and volume of this pollution is unclear. 

to 

improve 

the  situation 

Denmark  aims 
through 
converting about 15% of agricultural land into forests and 
nature and reducing nitrogen pollution by 13 780 tonnes 
annually as stated in the 2024 Green Denmark agreement. 
This  ambitious  plan  has  been  agreed  between  the  main 
political  parties  and  it  has  a  strong  support  from  the 
environmental, agricultural and other stakeholders. 

On air quality, the emissions of several air pollutants have 
decreased significantly in Denmark since 2005, while the 
growth  of  the  gross  domestic  product  has  continued. 
Denmark  has  met  its  emission  reduction  commitments 
and the air quality in Denmark is generally good. 

On  waste,  Denmark  is  among  the  EU  Member  States 
generating  the  biggest  quantity  of  municipal  waste  per 
capita  and  the  country  incinerates  the  most  municipal 
waste  per  person  in  the  EU.  Denmark  has  to  make 
significant efforts to prevent municipal waste generation 
and  shift  reusable  and  recyclable  municipal  waste  away 
from incineration. By contrast, only a small share of waste 
is  landfilled.  As  to  electronic  waste,  in  Denmark,  the 
collection  rate  for  electronic  waste  is  below  the  legally 
binding target.  

On circular economy, Denmark’s material footprint is well 
above the EU average and the circular  material  use  rate 
remains below the EU average. The three biggest sectors, 
representing  more  than  half  of  Denmark’s  material 
footprint,  are  construction,  manufacturing,  and  agrifood 
(2).  

On  environmental  governance,  Denmark  could  expand 
the  national  portal  to  all  public  consultations  in  the 
environmental  decision-making  procedures  to  facilitate 
data collation at national level on participation rates.   

The  investment  gap  to  meet  Denmark’s  environmental 
objectives  is  an  estimated  EUR  1.4  billion  per  year, 
representing around 0.39% of the national gross domestic 
product. 

(2) 

2016, 

https://eur-lex.europa.eu/legal-

27 May 
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN. 
The  Circularity  Gap  Report  –  Denmark,  August  2023, 
https://circulareconomy.europa.eu/platform/en/knowledg
e/circularity-gap-report-denmark. 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
 
  
Denmark  4 

Part I: Thematic areas 

1. Circular economy and waste management 

Transitioning to a circular economy 

Advancing the transition to a circular economy in the EU 
will reduce the environmental and climate impact of our 
industrial  systems  by  reducing  input  materials,  keeping 
products and materials in the loop for longer and reducing 
waste generation, thus decoupling economic growth from 
circular  economy  has 
resource 
considerable  potential  to  increase  competitiveness  and 
job creation and will also promote innovation and provide 
access to new markets. With the 2020 circular  economy 
action  plan  (CEAP) (3)  measures  going  through  the 
legislative  process,  EU  Member  States  will  now  have  to 
focus on a swift and effective implementation. 

consumption.  A 

The 2020 CEAP launched the  legislative process for a set 
of  initiatives  that  will  now  have  to  be  implemented  by 
national  governments  across  the  EU.  These  initiatives 
were all introduced following a holistic life-cycle approach, 
with  measures  addressing  the  different  stages  of  a 
product’s life cycle, from design through use to end of life. 

In the CEAP, the EU sets as its overarching objective the 
doubling of its circular material use rate (CMUR) by 2030. 

The CMUR is a  measure of one aspect of circularity: the 
share of the total amount of material used in the economy 
that is accounted for by recycled waste.  A higher CMUR 
value means that more secondary materials were used as 
a  substitute  for  raw  materials,  thus  reducing  the 
environmental impacts of extracting primary material. 

Denmark’s  CMUR  was  9.1 %  in  2023,  below  the  EU 
average of 11.8 %. The trend in Figure 1 shows an overall 
decline  since  2014,  with  a  slight  increase  in  2018. 
However,  since  2020  the  Danish  CMUR  has  increased 
slightly  and  in  2022–2023  it  returned  to  its  2014  level 
(Figure 1) (4). 

Furthermore,  Denmark  was  among  the  five  Member 
States  with  the  highest  material  footprints  in  2022  and 
2023 (28.2 and 25.9 t per capita, respectively) compared 
with  the  EU  average  of  14 t  per  capita (5).  The  three 
biggest sectors, representing more than half of Denmark’s 
material  footprint,  are  construction,  manufacturing  and 
agrifood (6). 

Denmark  has  been  among  the  three  highest-ranking 
Member  States  in  terms  of  consumption  footprint  per 
capita  since  2014. 
It  had  the  second  highest  EU 
consumption  footprint  in  2022  (1.23  per  inhabitant), 
compared with the EU average of 0.96 per inhabitant (7). 

Moreover, in 2023, the country relied on importing 39.8 % 
of  materials  to  meet  its  needs,  versus  an  EU  average  of 
22 % (8). 

Figure 1: CMUR (%), 2013–2023 

15

10

5

0

2013

2015

2017

2019

2021

2023

Denmark

EU-27

Source: Eurostat, ‘Circular material use rate’, env_ac_cur,  last updated 
13 November 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_cur. 

10 December 

2024, 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic product (GDP). Improving resource productivity 
can help to minimise negative impacts on the environment 
and reduce dependency on volatile raw material markets. 
As shown in Figure 2, with EUR 2.36 generated per kg of 

(3) 

(4) 

(5) 

of 

to 

final 

from 

2020, 

11 March 

the  Commission 

the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  A  new  circular 
economy action plan for a cleaner and more competitive Europe, 
COM(2020) 98 
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A98%3AFIN. 
Eurostat,  ‘Circular  material  use  rate’,  env_ac_cur,  last  updated 
13 November 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/product/view/env_a
c_cur.  The  figures  for  2023  are  Eurostat  estimates.  Denmark’s 
CMUR was 7.6 % in 2020, 8.6 % in 2021, 9.3 % in 2022 and 9.1 % 
in 2023. 
Eurostat,  ‘Material  footprints –  Main  indicators’,  env_ac_rme, 
2024, 
accessed 

10 December 

7 October 

2024, 

(6) 

(7) 

(8) 

https://ec.europa.eu/eurostat/databrowser/view/env_ac_rme/d
efault/table?lang=en. The figures for 2022 and 2023 are Eurostat 
estimates. 
Circle  Economy,  The  Circularity  Gap  Report –  Denmark,  2023, 
https://circulareconomy.europa.eu/platform/sites/default/files/
2023-09/64ecce479e36018c09c5411c_CGR%20Denmark%20-
%20Report.pdf. 
Eurostat, 
25 March 
accessed 
https://ec.europa.eu/eurostat/databrowser/view/cei_gsr010__c
ustom_13652614/default/table?lang=en. 
Eurostat,  ‘Material  import  dependency’,  cei_gsr030,  7 August 
2024, 
2025, 
https://ec.europa.eu/eurostat/databrowser/view/cei_gsr030/def
ault/table?lang=en. The figures for 2023 are Eurostat estimates. 

‘Consumption  footprint’,  cei_gsr10, 

last  updated 
2025, 

17 January 

17 January 

accessed 

2024, 

2025 Environmental Implementation Review – Denmark 

 
 
 
resource 
material  consumed 
productivity is slightly above the EU average of EUR 2.23 
per kg. 

in  2023,  Denmark’s 

Figure 2: Resource productivity (EUR/kg), 2013–2023 

2,5

2,0

1,5

1,0

0,5

0,0

2013

2015

2017

2019

2021

2023

Denmark

EU-27

NB: The unit of measurement used is EUR/kg chain-linked volume (2015). 
Chain-linked  volumes  focus  on  changes  on  quantities  and  prices  of 
commodities  in  previous  years,  taking  account  of  inflation,  and  are 
indexed to the nearest appropriate year, in this case 2015. 

Source:  Eurostat,  ‘Resource  productivity’,  env_ac_rp,  last  updated 
2024, 
7 August 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_rp. 

10 December 

accessed 

2024, 

Policies and measures 

In  parallel  with  European  initiatives  under  the  CEAP, 
Member States are encouraged to adopt and implement 
circular strategies at the national, regional and city levels. 
These should be tailored to each national and local reality, 
to  harness  the  proximity  economy’s (9)  potential,  while 
following  the  principles  of  a  holistic  whole-value-chain 
approach. 

Since the launch of the online European Circular Economy 
Stakeholder  Platform  in  2017 (10)  national,  regional  and 
local  authorities  have  used  the  platform  to  share  their 
strategies,  roadmaps  and  good  practices,  for  example 
alternative business models and innovative technologies. 

The  Danish  government  launched  an  action  plan  for 
circular  economy  in  2021 (11),  which  constitutes  the 
national  waste  prevention  programme  and  waste 
management  plan.  The  plan  puts  extra  focus  on  how  to 
make  the  value  chains  for  biomass,  construction  and 

(9) 

(10) 

website, 

Commission 

European Commission, ‘Proximity and social economy ecosystem’, 
European 
https://single-market-
economy.ec.europa.eu/sectors/proximity-and-social-
economy_en. 
Circular 
(https://circulareconomy.europa.eu/platform/en/strategies). 
(11)  Ministry  of  Environment,  Handlingsplan  for  cirkulær  økonomi, 
2021, 

Stakeholder 

Economy 

Platform 

Copenhagen, 
https://mim.dk/media/s0rpgnej/handlingsplan-for-cirkulaer-
oekonomi.pdf. 
State of play as of 10 April 2024. 
INFR(2022)2081 
(https://ec.europa.eu/commission/presscorner/detail/en/inf_22
_5402). 

(12) 
(13) 

Denmark  5 

plastics more circular. It contains 129 initiatives, many of 
which  are  also  included  in  the  climate  plan  for  a  green 
waste sector and circular economy (2020), the strategy for 
green public procurement (2020), the national strategy for 
a  sustainable  built  environment  (2021),  the  strategy  for 
circular  economy  (2018)  and  the  action  plan  on  plastics 
(2018). According to the latest annual progress report on 
the  national  action  plan  for  circular  economy,  79  out  of 
129 initiatives have been completed (12). 

An  infringement  procedure  is  ongoing  against  Denmark 
because  it  did  not  communicate  to  the  Commission  the 
national transposition measures necessary to ensure the 
full transposition of  the Single-use Plastics Directive into 
its national legal framework (13). 

Denmark  has  established  a  National  Bioeconomy  Panel, 
and various multistakeholder initiatives have been formed 
to accelerate the transition to a circular economy, such as 
the  green  industrial  symbiosis  programme,  the  Rethink 
Resources  innovation  centre  and  the  Genbyg  Skive  pilot 
project (which aims to reuse building materials to create 
business opportunities and reduce waste). 

In August 2022, a supplementary political agreement was 
made to follow-up to the climate plan for a green waste 
from  2020 (14).  This 
sector  and  circular  economy 
agreement strengthens waste supervision and the control 
of  management  of  commercial  waste  as  well  as  exports 
and imports. 

reform  programme (15) 
Denmark’s  2023  national 
emphasises  circular  economy 
including  a 
initiatives, 
planned new plastic action plan with the aim of reducing 
plastic  waste  in  the  environment,  extended  producer 
responsibility  (EPR)  for  packaging,  and  wastewater 
standards to limit perfluorooctane sulfonate (PHOS) / per- 
and  polyfluoroalkyl 
(PFAS)  pollution. 
Furthermore, these reforms  are  included in the national 
fiscal  and  structural  policy  plan (16).  Additionally,  the 
national reform programme supports sustainable mining 
of  raw  materials  like  sand  and  gravel,  reusing  building 
materials and implementing standardised waste collection 
across 10 household waste fractions. 

substances 

(14) 

https://economy-
finance.ec.europa.eu/document/download/6139aa30-006e-
4691-b8d5-
82767718612a_en?filename=Denmarks%20Fiscal%20and%20Str
uctural%20Plan%202024_0.pdf. 

(15)  Ministry of Finance, Denmark’s National Reform Programme 2023, 
2023, 

Copenhagen, 
https://en.fm.dk/publications/2023/maj/denmarks-national-
reform-programme-2023/. 

(16)  Ministry  of  Finance,  Denmark’s  Fiscal  and  Structural  Policy  Plan 
2024, 
version, 
2024, 
https://en.fm.dk/publications/2024/oktober/denmarks-fiscal-
and-structural-policy-plan-2024/. 

Copenhagen, 

revised 

2025 Environmental Implementation Review – Denmark 

 
 
 
Although Denmark’s national recovery and resilience plan 
(RRP) (17) does not contain reforms relating to the circular 
economy,  there  is  investment  devoted  to  research  on 
circular economy focusing on the reuse and reduction and 
recycling  of  plastic  and  textile  waste.  The  European 
Regional  Development  Fund 
Just 
Transition  Fund  (JTF)  funding  for  2021–2027  covers 
actions to boost the circular economy in Denmark. 

(ERDF)  and  the 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
authorities’ 
consumption,  with  public 
European 
purchasing  power  representing  around  14 %  of  EU  GDP. 
Public  procurement  using  green  or  circular  criteria  (life-
cycle  assessment,  PaaS  (product  as  a  service),  second 
hand)  can  help  drive  the  demand  for  more  sustainable 
products  that  i.a.  meet  reparability  and  recyclability 
standards. 

includes  an 

Denmark adopted a green public procurement strategy in 
October  2020  (green  procurement  for  a  green  future), 
which  puts  the  public  sector  at  the  forefront  of  the 
country’s green transition. Around EUR 25 billion is spent 
per year in Denmark on public procurement of goods and 
services,  which  is  around  10 %  of  its  GDP.  The  strategy 
includes  a  target  that  all  public  procurement  in  areas 
where official ecolabel schemes exist must be ecolabelled 
or comply with corresponding requirements by 2030. The 
introduces 
strategy 
mandatory  procurement  of  ecolabelled  products  or 
products  meeting  equivalent  requirements  for  state 
procurement  in  product  groups  where  the  government 
is  sufficient  competition  and  no 
determines  there 
significant price difference. Priority was given to ensuring 
that the following product groups are ecolabelled or meet 
similar  requirements:  paper  and  printed  materials, 
cleaning  products  and  agents,  soap  and  certain  hygiene 
products,  standard  batteries  and 
indoor  paint.  The 
intention  is  to  update  the  list  of  product  groups  with 
ecolabelled procurement requirements annually. 

initiative,  which 

Furthermore,  the  strategy  includes  an  initiative  which 
introduces mandatory use of total cost of ownership (TCO) 
as  an  economic  price  parameter  in  state  procurement, 
where  feasible  and  appropriate.  The  aim  is  to  shift  the 
incurred 
focus  from  acquisition  price  to  the  costs 
throughout  a  product’s 
this 
requirement is intended to apply to the 25 product groups 

life  cycle. 

Initially, 

(17) 

(18) 

https://commission.europa.eu/business-economy-
euro/economic-recovery/recovery-and-resilience-
facility/country-pages/denmarks-recovery-and-resilience-
plan_en. 
European Commission, ‘EU Ecolabel facts and figures’, European 
2024, 
Commission 

September 

accessed 

website, 

Denmark  6 

for  which  official  tools  to  assess  total  cost  of  ownership 
are available. 

The  EU  Ecolabel  and  the  eco-management  and  audit 
scheme 

The  number  of  EU  Ecolabel  product  groups  and  the 
number  of  eco-management  and  audit  scheme  (EMAS)-
licensed  organisations  in  each  country  provide  some 
indication  of  the  extent  to  which  the  private  sector  and 
national stakeholders in that country are actively engaged 
in the transition to a circular economy. The EU Ecolabel is 
awarded  to  products  with  best-in-class  environmental 
is  a  voluntary  environment 
performance.  EMAS 
management 
the 
scheme 
environmental impacts of organisations. 

reducing 

aimed 

at 

As of September 2024, Denmark had 6 021 products out 
of 98 977, and 130 licences out of 2 983 registered in the 
EU  Ecolabel  scheme (18).  As  of  October  2024,  two 
organisations  in  Denmark  were  registered  in  the  EMAS 
scheme (19). 

In  2022,  the  European  Commission  identified  a  priority 
action  for  Denmark  to  adopt  measures  to  increase  the 
CMUR  and  lower  material  consumption.  Denmark  has 
made some progress on this. While its CMUR has slightly 
increased  in  recent  years,  it  remains  below  the  EU 
average. The Danish consumption and material footprints 
are among the highest in the EU. 

2025 priority action 

•  Adopt measures to increase the circular  material use 

rate. 

Waste management 

Turning waste into a resource is supported by: 

(i)  addressing  the  full  life  cycle  of  products,  from 
conception to end of life, by setting requirements on 
the design of products to ensure that they are more 
sustainable; 

(ii)  fully 

implementing  EU  waste 

legislation,  which 
includes the waste hierarchy, the obligation to ensure 
separate collection of waste, landfill diversion targets, 
etc.; 

(iii)  reducing waste generation per capita and in absolute 

terms; 

(iv)  increasing  the  recycling  rates  of  waste  containing 
critical raw materials (CRMs), with a view to reducing 

(19) 

https://environment.ec.europa.eu/topics/circular-economy/eu-
ecolabel/businesses/ecolabel-facts-and-figures_en. 
European Commission, EMAS - Facts and Figures, November 2024 
https://green-business.ec.europa.eu/emas/about-
emas/statistics-and-graphs-0_en.  

2025 Environmental Implementation Review – Denmark 

 
 
dependencies and building resilient value chains, and 
stimulating  demand  for  recycled  content 
in  all 
products; 

(v)  limiting energy recovery to non-recyclable materials; 

and 

(vi)  phasing  out  landfilling  of  recyclable  or  recoverable 

waste. 

One  of  the  main  objectives  of  the  EU  Waste  Law  is  to 
decouple  economic  growth  from 
its  environmental 
impacts. 

The EU’s approach to waste management is based on the 
waste  hierarchy:  prevention,  preparing 
reuse, 
recycling,  recovery  and,  as  the  least  preferred  option, 
disposal  (which 
incineration 
includes 
without energy recovery). 

landfilling  and 

for 

All legislative proposals in the field of waste management 
put forward by the Commission since 2021 are intended 
to encourage Member States to promote better product 
design,  to  require  producers  to  cover  the  costs  of 
managing the waste resulting from their products and to 
ensure that waste is managed at the higher levels of the 
waste hierarchy. 

in  Denmark 
The  total  amount  of  waste  generated 
increased  until  2018  and  then  decreased.  At  the  same 
time, Denmark’s GDP increased, except in 2020. The latest 
data  suggest  a  potential  decoupling  between  waste 
generation  and  economic  growth,  but  it  is  too  early  to 
confirm a permanent trend (Figure 3). 

Figure 3: Generation of waste (total and excluding major 
mineral waste), population and GDP, 2010–2022 

accessed 

15 October 

nama_10_gdp, 

Sources: Eurostat, ‘GDP and main components (output, expenditure and 
income)’, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__cust
om_9301905/default/table;  Eurostat,  ‘Generation  of  waste  by  waste 
category,  hazardousness  and  NACE  Rev. 2  activity’,  env_wasgen,  last 
2024, 
updated 
https://ec.europa.eu/eurostat/databrowser/view/env_wasgen/default/
table?lang=en; Eurostat, ‘Population change – Demographic balance and 
crude  rates  at  national  level’,  demo_grind,  accessed  15 October  2024, 

30 September 

22 October 

accessed 

2024, 

Denmark  7 

https://ec.europa.eu/eurostat/databrowser/view/demo_gind/default/t
able?lang=en&category=demo.demo_ind. 

The  main  cause  of  the  decreased  waste  generation  is 
reduced  soils  and  mineral  waste  from  construction  and 
demolition.  After  mineral  waste,  recyclable  waste  and 
mixed ordinary waste are the largest waste fractions. 

By  2024,  Denmark  had  30  waste  incineration  plants,  of 
which 17 were owned by municipalities. It is expected that 
the mandatory tendering of residual waste will lead to no 
new plants and the closure of several municipal plants to 
reduce  capacity  to  the  level  of  domestically  generated 
residual waste by 2030 (20). 

Critical raw materials 

CRMs are addressed in the Danish action plan for circular 
economy (2020–2032) (21) and in separate legislation and 
statutory orders. The management of CRMs is facilitated 
by  the  EPR  schemes  for  waste  electrical  and  electronic 
equipment  (WEEE),  batteries  and  (end-of-life)  vehicles 
and executive orders setting out rules on the recycling of 
various waste streams in which CRMs are a component. 

The Danish Board of Business Development has launched 
a new initiative to support the circularity and security of 
supply of CRMs for small and medium-sized enterprises. 

Construction and demolition waste 

Construction  and  demolition  waste  (CDW)  accounts  for 
almost  40 %  of  all  waste  generated  in  the  EU.  A  recent 
study (22)  by  the  Joint  Research  Centre  shows  that 
recycling  and  preparation  for  reuse  are  preferred  over 
incineration  and 
landfilling  from  an  environmental 
perspective  for  most  of  the  different  streams  of  CDW. 
However,  the  economics  are  often  unfavourable  for 
recycling  and  preparation  for  reuse  compared  with 
incineration and landfilling. If available technology were to 
be applied, it is estimated that the increase in the recycling 
and  preparation  for  reuse  of  CDW  would  lead  to  an 
additional  33 Mt  of  greenhouse  gas  (GHG)  emission 
savings annually (more than, for example, the combined 
annual  GHG  emissions 
from  Estonia,  Latvia  and 
Luxembourg). 

In Denmark, the recycling and preparation for reuse and 
recycling  rate  of  mineral  CDW  is  37.7 %,  below  the  EU 
average  of  79.8 % 
in  2022.  Selective  demolition  of 
buildings exceeding 250 m2 is mandatory by July 2025 in 

(20) 

(21) 

The  expected  reduction  in  capacity  is  approximately  30 %  from 
2020 to 2030. Using a tender for the treatment of residual waste 
will be required. See the climate plan for a green waste sector and 
circular 
economy 
(https://www.regeringen.dk/media/9591/aftaletekst.pdf). 
https://producentansvar.dk/wp-
content/uploads/2021/09/handlingsplan-for-cirkulaer-oekonomi-
0607211338.pdf. 

(22) 

European Commission: Joint Research Centre, Cristobal Garcia, J., 
Caro, D. et al., Techno-economic and environmental assessment of 
construction and demolition waste management in the European 
Union,  Publications  Office  of  the  European  Union,  Luxembourg, 
2024, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC1354
70. 

2025 Environmental Implementation Review – Denmark 

 
 
 
Denmark (23).  Measures  to  further  increase  the  rate  of 
recycling  and  preparation  for  reuse  of  CDW  include 
separate collection at  the  source – for instance, through 
digitalised 
(‘resource 
assessments’); EPR and other economic instruments; and 
upstream  measures  such  as  increasing  the  recycled 
content 
in  construction  products  and  the  circular 
design (25) of construction works. 

pre-demolition 

audits (24) 

Boosting 
Warning Report 

implementation –  the  2023  Waste  Early 

This  section  focuses  on  the  management  of  municipal 
waste (26),  for  which  EU  law  sets  mandatory  recycling 
targets.  In  June  2023,  the  Commission  published  the 
Waste  Early  Warning  Report (27)  identifying  the  general 
trends in waste management and the Member States at 
risk of missing 2025 waste targets (see Figure 4). Denmark 
is  considered  to  be  on  track  to  meet  the  2035  landfill 
target, the 2025 municipal waste recycling target and the 
2025 targets for packaging waste recycling for all materials 
except plastic packaging. 

(23) 
(24) 

(25) 

https://www.retsinformation.dk/eli/ft/202313L00091. 
European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  EU  Construction  & 
Demolition Waste Management Protocol including guidelines for 
pre-demolition and pre-renovation audits of construction works – 
Updated edition 2024, Publications Office of the European Union, 
Luxembourg,  2024,  https://op.europa.eu/en/publication-detail/-
/publication/d63d5a8f-64e8-11ef-a8ba-01aa75ed71a1/language-
en. 
European Commission, Circular Economy – Principles for buildings 
design, 
2020, 
Brussels, 
https://ec.europa.eu/docsroom/documents/39984. 

Denmark  8 

Figure 4:  Member  States’  prospects  of  meeting  the 
preparing  for  reuse  and  recycling  targets  for  municipal 
waste and packaging waste 

Reference data: ©ESRI 

  Member  States  not  at  risk  of  missing  the  55 % 
preparing 
for 
municipal  waste  and  the  65 %  recycling  target  for 
packaging waste 

for  reuse  and  recycling  target 

  Member States at risk  of missing the preparing for 
reuse  and  recycling  target  for  municipal  waste  but 
not  at  risk  of  missing  the  recycling  target  for 
packaging waste 

  Member states at risk of missing both targets 
  Outside coverage 

Source: European Environment Agency (EEA), ‘Many EU Member States 
not on track to meet recycling targets for municipal waste and packaging 
waste’, briefing No 28/2022, Copenhagen, 2023. Reference data © ESRI. 

Under  certain  conditions,  EU  waste  legislation  enables 
some  Member  States  to  postpone  the  deadlines  for 
reaching certain waste management targets for municipal 
and packaging waste. Member States that want to use this 
possibility  have  to  notify  the  Commission  24 months  in 
advance  of  the  deadline  and  submit  an  implementation 
plan  laying  down  the  steps  they  envisage  to  reach  the 

(26)  Municipal  waste  consists  of  (i)  mixed  waste  and  separately 
collected waste from households, including paper and cardboard, 
glass, metals, plastics, biowaste, wood, textiles, packaging, WEEE, 
waste  batteries  and  accumulators,  and  bulky  waste,  including 
mattresses  and  furniture;  and  (ii)  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). 
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en. 

(27) 

2025 Environmental Implementation Review – Denmark 

 
 
 
postponed targets within a new time frame. Regarding the 
2025 targets, 11 Member States, not including Denmark, 
have used this prerogative. 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 
efforts  to  improve  their  recycling  performance.  The 
Commission  is,  on  one  hand,  working  together  with  the 
national  authorities  and  stakeholders  to  speed  up  the 
implementation  of  measures  necessary  to  meet  the 
targets,  including  through  dedicated  financing.  On  the 
other  hand,  the  Commission  is  pursuing  enforcement 
actions against those Member States that, based on data 
submitted to the Commission, do not achieve the targets 
of the Waste Framework Directive (28), the Packaging and 
Packaging Waste Directive (29) and the Directive on WEEE 
(30).  An  infringement  procedure  against  Denmark  was 
opened in 2024 because in 2021 Denmark did not attain 
certain  key  waste  targets:  (i)  the  recycling  rate  for 
municipal waste set out in the Waste Framework Directive 
and (ii) the collection rate for electronic waste set out in 
the Directive on WEEE (31). 

Municipal waste 

In 2022, Denmark generated the second highest volume of 
municipal waste in the EU, at 802 kg per capita, which is 
significantly above the estimated EU-27 average of 513 kg 
per capita (Figure 5) (32). 

Denmark  9 

Figure 5:  Municipal  waste  management  and  recycling 
(including preparation for reuse), 2010–2022 

Source:  Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
2024, 
env_wasmun, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table. 

22 October 

accessed 

In  2022,  the  preparing  for  reuse  and  recycling  rate  was 
46 % (Figure 6), but Denmark has indicated its intention to 
submit  corrected  data  for  2020–2022  that  would  give 
higher rates (e.g. 50 % in 2022) (33). 

In 2022, the country incinerated the most municipal waste 
per  person  out  of  all  Member  States,  incinerating  more 
than double the EU average. By contrast, only about 1–2 % 
is landfilled (34). 

(28)  Directive  2008/98/EC  of  the  European  Parliament  and  of  the 
Council  of  19  November  2008  on  waste  and  repealing  certain 
Directives, https://eur-lex.europa.eu/eli/dir/2008/98/oj/eng.  
European  Parliament  and  Council  Directive  94/62/EC  of  20 
December  1994  on  packaging  and  packaging  waste  (OJ  L  365, 
31/12/1994, 
https://eur-lex.europa.eu/legal-
content/en/ALL/?uri=celex%3A31994L0062.  

10–23), 

(29) 

p. 

(31) 

(30)  Directive  2012/19/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  waste  electrical  and  electronic 
equipment  (WEEE)  (OJ  L 197,  24.7.2012,  p. 38),  https://eur-
lex.europa.eu/eli/dir/2012/19/oj/eng.  
INFR(2024)2138 
(https://ec.europa.eu/commission/presscorner/detail/en/inf_24
_3228).  The  Danish  recycling  rate  for  municipal  waste  was 
calculated based on the data reported by Denmark, but it differs 
from the result given by the data in Figure 6. 
Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
env_wasmun,  waste  generated  in  kg  per  capita,  last  updated 

(32) 

2024, 

accessed 

17 January 

6 November 
2025, 
https://ec.europa.eu/eurostat/databrowser/view/env_wasmun_
_custom_9634214/default/table?lang=en.  The  Danish  national 
dataset  differs  from  the  Eurostat  data.  Based  on  the  national 
database,  Denmark  generated  746  kg  of  municipal  waste  per 
capita.  Ministry  of  Environment  of  Denmark  (2024); Danish  EPA 
(2024) –  https://mst.dk/publikationer/2024/juli/affaldsstatistik-
2022. 

(33)  Ministry of Environment of Denmark (2024); Danish EPA (2024) – 
https://mst.dk/publikationer/2024/juli/affaldsstatistik-2022. As a 
small  open  economy,  most  of  Denmark’s  recyclable  waste  is 
exported to neighbouring Member States (Germany and Sweden) 
for recycling; this is included in Denmark’s overall recycling rate. 
Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
last  updated  6 November  2024,  accessed 
env_wasmun, 
17 January 
2025, 
34https://ec.europa.eu/eurostat/databrowser/view/env_wasmun
/default/table?lang=en. 

(34) 

2025 Environmental Implementation Review – Denmark 

 
 
 
Figure 6: Recycling (including preparation for reuse) and 
landfill rates (%), 2010–2022 

Denmark  10 

Source:  Eurostat,  ‘Packaging  waste  by  waste  management  operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en. 

The recycling rate of total packaging waste has decreased 
slightly since 2010, reaching 65 % in 2022 (Figure 8). The 
significant  decrease  in  the  recycling  rates  for  paper  and 
cardboard and for plastic since 2019 can be attributed to 
the change in methodology (36). 

Figure 8: Packaging waste recycling rates (%), 2010–2022 

NB: No data are available for 2010. 
Source:  Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
env_wasmun, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table. 

accessed 

October 

22 

Packaging waste 

Denmark’s  packaging  waste  generation  has  been 
increasing since 2010, from 125 kg per capita to 187 kg per 
capita in 2022, very close to (estimated) EU27 average of 
186 kg per  capita in the same year (35) (Figure 7).  Paper 
and  cardboard  packaging,  which  constitutes  the  largest 
share  of  packaging  waste,  was  the  main  cause  of  this 
increase.  

Figure 7: Packaging waste generation, 2010–2022 

(35)   The EU average might be influenced by the situation that not all 
Member  States  already  fully  apply  the  reporting  rules  for 
packaging  waste  as  defined  in  the  Commission  Implementing 
Decision 2019/665. 
Before 2020, collected quantities were used for reporting. Starting 
from 2020, materials that are not recycled are deducted from the 
overall 
quantities. 
collected 
https://www2.mst.dk/Udgiv/publikationer/2024/11/978-87-
7038-665-4.pdf. 

(36) 

Source:  Eurostat,  ‘Packaging  waste  by  waste  management  operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en. 

Note:  Data  for  steel  and  aluminium  packaging  separately  is  obligatory 
since reference year 2020. 

Policies to encourage waste prevention 

Waste  management  plans  and  waste  prevention 
programmes are instrumental to the full implementation 
of  EU  waste  legislation.  They  set  out  key  provisions  and 
investments to ensure compliance with existing and new 
legal requirements (e.g. on waste prevention, on separate 
collection for certain waste streams, on recycling and on 
landfill targets). 

Denmark’s national plan for prevention and management 
of waste for 2020–2032 covers the entire territory and is 
supplemented by municipal waste management plans (37). 
The plan contains the 2020–2032 CEAP, which focuses on 
biomass, construction waste and plastics (38). 

(37)  Ministry  of  Environment  of  Denmark,  2021,  Action  Plan  for 
Circular Economy (in Danish), Ministry of Environment of Denmark 
(https://mim.dk/media/s0rpgnej/handlingsplan-for-cirkulaer-
oekonomi.pdf 
https://mim.dk/media/12ppwzvm/alle-faktaark-engelsk-
nyeste.pdf )) accessed 8 April 2024 

version: 

(English 

(38)  Ministry  of  Environment  of  Denmark,  2021,  Action  Plan  for 
Circular Economy (in Danish), Ministry of Environment of Denmark 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
 
 
 
Denmark  11 

incineration  of  residual  municipal  waste  and 
incineration of non-biodegradable waste (46). 

(iii) 

including  economic 

Denmark received two priority actions in all three previous 
EIRs. The first priority action was to introduce new policy 
instruments, 
instruments,  to  (i) 
promote  waste  prevention  and  (ii)  make  preparing  for 
waste  reuse  and  recycling  more  economically  attractive. 
Denmark  has made some progress  with its  initiatives on 
repair, reusable takeaway packaging and textiles. 

The  second  priority  action  was  to  shift  reusable  and 
recyclable  waste  away  from  incineration  with  energy 
its 
recovery.  Denmark  has  made  progress  through 
separate waste collection system. However, Denmark still 
incinerates a large share of its municipal waste for district 
heating instead of recycling and reusing it.  

2025 priority actions 

• 

• 

• 

• 

incineration, 

Further  shift  reusable  and  recyclable  waste  away 
from 
including  through  economic 
instruments. 
Improve municipal waste preparation for reuse and 
recycling. 
Increase  the  collection  and  recycling  rate  of  waste 
electronic and electric equipment (WEEE). 
Invest  in waste  prevention measures to reduce the 
total amount of waste generated. 

For  2025–2027,  the  Danish  parliament  has  allocated  (i) 
DKK 45 million  to 
foster  a  culture  of  repair  over 
replacement  and  (ii)  DKK 15 million  to  increase  reusable 
solutions  for  takeaway  packaging.  Furthermore,  the 
implementation of a national action plan to lower the use 
of textiles and improve recycling rates is envisaged (39). 

Policies to encourage separate collection and recycling 

Denmark has a mandatory separate collection system for 
recyclables  at  household  properties  and  in  companies. 
Since  2021,  a  harmonised  pictogram (40)  for  all  waste 
in  place  alongside  the  national 
streams  has  been 
harmonisation  of  the  separate  collection  system (41).  At 
the end of 2023, 80 out  of 98 Danish municipalities had 
introduced  a separate collection  system  for all  10 waste 
is  expected  to  be  fully 
streams  and  this  system 
implemented  by  2025 (42). 
regions  and 
municipalities,  Denmark  has  implemented  a  pay-as-you-
throw scheme (43). Furthermore, the EPR scheme will be 
introduced in 2025 for all types of packaging materials (44). 

In  some 

Denmark  applies  packaging  taxes  with  an  escalator, 
covering  beverage  packaging  (excluding  packaging  for 
dairy),  polyvinyl  chloride  (PVC)  films  for  food,  bags  and 
disposable  tableware.  It  implements  mandatory  deposit 
return systems for aluminium drink cans, glass and plastic 
drink bottles, and a voluntary system for plastic crates (45). 

Policies to discourage landfilling or incineration 

Landfilling recyclable and combustible waste is prohibited 
in  Denmark  and  taxes  are  applied  on  (i)  landfilling,  (ii) 

(39) 

(40) 

(English 

version: 

(https://mim.dk/media/s0rpgnej/handlingsplan-for-cirkulaer-
oekonomi.pdf 
https://mim.dk/media/12ppwzvm/alle-faktaark-engelsk-
nyeste.pdf )) accessed 8 April 2024.   
https://www.regeringen.dk/aktuelt/publikationer-og-
aftaletekster/aftale-om-finansloven-for-2025/. 
The  Statutory  Order  of  Waste  introduced  the  pictogram  system 
along with mandatory sorting criteria for 10 waste streams: food, 
paper,  cardboard,  glass,  metal,  plastics,  food  and  drink  cartons, 
textiles,  hazardous  waste  and  residual  waste.  Miljøministeriet, 
2020, BEK nr 2159 af 09/12/2020 Bekendtgørelse om affald (BEK).   
(41)  Door-to-door collection is mandatory for all waste streams. If this 
is  not  feasible,  collection  points  must  be  placed  within  ‘a  short 
walking  distance’.  Commingled  collection  is  allowed  for  certain 
combinations  of  waste  streams.  Ministry  of  Environment  of 
Denmark, 2024, Information provided during the Eionet review of 
the draft EEA country profile on waste management for Denmark. 
The  implementation  status  is  regularly  monitored  and  made 
publicly  available.  Ministry  of  Environment  of  Denmark,  2024, 
Information  provided  during  the  Eionet  review  of  the  draft  EEA 
country profile on waste management for Denmark.   
The  scheme  covers  80 %  of  the  population,  Denmark  —  Early 
Warning  Assessment  Related  to  the  2025  Targets  for  Municipal 

(43) 

(42) 

(44) 

(45) 

(46) 

and  Packaging  Waste,  European  Environment  Agency  (EEA) 
(https://www.eea.europa.eu/publications/many-eu-member-
states/denmark/view) accessed 26 March 2024. 
https://mim.dk/media/s0rpgnej/handlingsplan-for-cirkulaer-
oekonomi.pdf. 
Early  Warning  Assessment  Related  to  the  2025  Targets  for 
Municipal  and  Packaging  Waste,  European  Environment  Agency 
(EEA) 
(https://www.eea.europa.eu/publications/many-eu-
member-states/denmark/view) accessed 26 March 2024.   
The landfilling tax is DKK 475/t (EUR 64/t) before value added tax. 
The tax on incineration of residual municipal waste is DKK 52.5/GJ 
(EUR 7/GJ),  consisting  of  a  tax  on  heat  generated  from  waste 
incineration of DKK 20.7/GJ (EUR 3/GJ) and an incineration tax of 
DKK 31.8/GJ 
incinerated  non-
biodegradable  waste  is  DKK 179.2/t  (EUR 24/t)  of  CO2  emitted. 
The tax on heat and the CO2 tax increase annually with the national 
net  price  index.  Early  Warning  Assessment  Related  to  the  2025 
for  Municipal  and  Packaging  Waste,  European 
Targets 
Environment 
(EEA) 
Agency 
(https://www.eea.europa.eu/publications/many-eu-member-
states/denmark/view) accessed 26 March 2024.   

(EUR 4/GJ).  The 

tax  on 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
 
 
2. Biodiversity and natural capital 

Denmark  12 

Global and EU biodiversity frameworks

Biological  diversity  and  healthy  ecosystems  are  critical 
for our societies, underpin our economies and well-being 
and  are  essential  for  climate  change  adaptation  and 
mitigation.  The  Kunming–Montreal  global  biodiversity 
framework  (GBF),  adopted  in  December  2022,  sets 
comprehensive  and  measurable  targets  to  tackle 
biodiversity  loss  by  2030.  To  implement  this  global 
framework and integrate biodiversity considerations into 
national decision-making, the EU – as well as all Member 
States –  had  to  submit  national  biodiversity  strategies 
and  action  plans  (NBSAPs)  aligned  with  the  global 
targets, by the end of 2024. The EU biodiversity strategy 
for 2030 (BDS) aims to put EU biodiversity on a path to 
recovery by 2030. It sets quantified targets intended to 
protect and restore nature and manage ecosystems in a 
sustainable  manner,  as  well  as  measures  to  enable 
implementation  and  commitments  to  support  global 
biodiversity. A BDS actions tracker (47) and a dashboard 
of indicators (48) provide information on implementation 
progress.  The  recently  adopted  EU  Nature  Restoration 
Regulation (49) is the first EU-wide, comprehensive law of 
its kind and a key instrument for the EU to deliver on the 
global  biodiversity  targets  for  2030.  It  lays  down  an 
overarching  objective  at  the  EU  level  to  put  in  place 
effective  restoration  measures  on  20 %  of  EU  land  and 
sea by 2030 and for all ecosystems in need of restoration 
by  2050.  To  achieve  this,  it  sets  binding  targets  for 
Member States to restore and maintain ecosystems, as 
well as an effective implementation framework based on 
national restoration plans. 

The BDS is the main instrument used by the EU to deliver 
on  its  obligation  under  the  GBF.  The  Commission  has 
submitted  to  the  Convention  on  Biological  Diversity  its 
report on GBF-aligned EU targets that stem from the BDS 
and from other policy instruments under the European 
Green Deal. 

Member  States’  NBSAPs  need  to  provide  coherent 
frameworks  for  national  delivery  on  the  global  and  EU 

(47) 

(48) 

(49) 

Actions 

Tracker 

Strategy 

Strategy 

Dashboard 

Biodiversity 

Biodiversity 

EU 
(https://dopa.jrc.ec.europa.eu/kcbd/actions-tracker/). 
EU 
(https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1). 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
see  also 
the 
http://data.europa.eu/eli/reg/2024/1991/oj; 
Commission 
law 
the 
on 
(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 

page 

web 

In 

2030  biodiversity  targets. 
line  with  the  global 
obligations,  NBSAPs  should  also  include  a  biodiversity 
financing  plan  and  a  capacity-building  plan,  based  on 
needs  assessments,  as  well  as  an  overview  of  the 
national indicators used to measure progress. 

Denmark  adopted  its  updated  NBSAP (50)  in  October 
2024. It is structured around three overarching themes: 
more  and  better  nature,  sectoral 
integration,  and 
international  initiatives.  For  each  of  these  themes,  the 
document 
identifies  the  related  global  biodiversity 
targets and sets out national initiatives to contribute to 
their  delivery.  While  Denmark  has  not  uploaded  its 
aligned national targets into the Convention on Biological 
Diversity’s online reporting tool, Annex 2 to the updated 
NBSAP  presents  a  visual  overview  of  Denmark’s 
contribution to the global targets. 

The EU aims to allocate at least 7.5 % of annual spending 
under the EU budget to biodiversity objectives in 2024, 
in  2026  and  2027.  For  details  on 
rising  to  10 % 
biodiversity financing and investments in  Denmark, see 
‘Biodiversity and ecosystems’ in Chapter 5. 

Nature  protection  and  restoration –  Natura 
2000 

Natura  2000 (51),  the  largest  coordinated  network  of 
protected areas in the world, is key to the achievement 
of  the  objectives  set  out  in  the  Birds  and  Habitats 
Directives. These objectives are to ensure the long-term 
protection,  conservation  and  survival  of  Europe’s  most 
valuable  and  threatened  species  and  habitats  and  the 
ecosystems  they  underpin.  Key  milestones  towards 
meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are  (i)  the  setting  up  of  a  complete  and 
coherent  Natura  2000  network;  (ii)  the  designation  of 
sites of community importance (SCIs) as special areas of 

(50) 

https://api.cbd.int/api/v2013/documents/CFB4C8FC-A569-
C501-C40E-
C3F3E636AB96/attachments/615967/WEB_ENGLISH_National_
handlingsplan_for_biodiv_2024.pdf. 

(51)  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. Numbers of protected areas in Figure 9 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. An SAC is an SCI designated by a Member State. 

2025 Environmental Implementation Review – Denmark 

 
 
conservation (SACs) (52); and (iii) effective management 
of  all  Natura  2000  sites  through  the  setting  of  site-
specific conservation objectives and measures. 

respectively) (56).  By  contrast,  18.2 %  of  Denmark’s 
marine waters were covered by Natura 2000, well above 
the EU average of 9 %. (57) 

Denmark  13 

Setting up a complete and coherent network of Natura 
2000 sites 

The  setting  up  of  a  complete  and  coherent  network  of 
is  a  cornerstone  of  the  EU’s 
Natura  2000  sites 
international commitments, under the BDS and GBF, to 
legally  protect  a  minimum  of  30 %  of  its  land  area  and 
30 % of its sea area by 2030. 

the 

these 

requires 

commitments 

Meeting 
full 
implementation of Article 3 of the Habitats Directive. The 
Natura 2000 network should represent a complete and 
coherent  ecological network composed of sites hosting 
natural habitat types and species of community interest. 
Natura 2000 will enable the natural habitat types and the 
species’ habitats concerned to be maintained or, where 
appropriate,  restored  to  a  favourable  conservation 
status in their natural range. 

Denmark  hosts  60  habitat  types (53)  and  79  species (54) 
covered by the Habitats Directive. The country also hosts 
populations of  54 bird taxa  listed in the Birds Directive 
Annex I (55). 

The  Danish  Natura  2000  area,  including  the  special 
protection  areas  (SPAs)  classified  under  the  Birds 
Directive  and  the  SCIs  classified  under  the  Habitats 
Directive,  was  well  below  the  EU  average  in  2024.  The 
share  of  Natura  2000  area  out  of  the  total  national 
territory  was  the  smallest  in  the  EU,  at  8.9 %  of  the 
Danish territory (EU average: 18.6 %) (see Figure 9). SPAs 
and SCIs covered 6.2 % and 8.1 % of the Danish territory, 
and  14.3 %, 
respectively 

average:  12.8 % 

(EU 

(52) 

(53) 

(54) 

(55) 

(56) 

dashboard, 

SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 
European Environment Agency (EEA), ‘Number of habitats and 
species per Member State’, Article 17 dashboard, Annex I total, 
19 December 
2019, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
Article 17 
2019, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 
EEA , ‘Number of bird species/populations per Member State’, 
Article 12 dashboard, Annex I total, last updated 11 May 2023, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-12-national-summary-
dashboards/general-information-on-bird-species-populations. 
This  counting  only  takes  into  account  bird  taxa  for  which 
information was requested. 
EEA, ‘Natura 2000 Barometer’, 2023 data, accessed April 2025, 
https://www.eea.europa.eu/data-and-
maps/dashboards/natura-2000-barometer. 

19 December 

The latest assessment of the SPA part of the Natura 2000 
network  shows  that  Denmark’s  designation  of  the 
network of marine SPAs was insufficient to cover several 
important bird areas. Denmark classified six new SPAs in 
2021 (58) and one additional SPA in 2023 (59). The Danish 
authorities  are  investigating  if  additional  marine  areas 
fulfil the criteria to be classified as SPAs. Under the BDS, 
Denmark submitted its pledge to expand the protected 
marine area (60). 

The Danish government  initiated a  procedure to adjust 
the  boundaries  of  the  sites  within  its  Natura  2000 
network  in  2018.  The  Danish  authorities  provided, 
together  with  an  updated  Natura  2000  database (61), 
justifications  for  a  number  of  border  modifications  for 
SACs and SPAs in 2024 (62). 

Considering  both  Natura  2000  and  other  nationally 
designated  protected  areas,  Denmark  legally  protects 
15.1 % of its territory (below the EU average of 26.1 %) 
and  18.8 %  of  marine  areas  (above  the  EU  average  of 
12.3 %) (63). 

(57) 

data, 

European  Commission,  ‘EU  Biodiversity  Strategy  Dashboard’, 
2022 
2025, 
accessed 
https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1.  The  newly  classified  marine  SPAs 
increase  the  Natura  2000  marine  area.  However,  this  is  not 
reflected in the EU Biodiversity Strategy Dashboard (18.2 %) used 
for this report. 

April 

(58)  Habitatbekendtgørelsen,  BEK  No 2091  of  12 November  2021 

(https://www.retsinformation.dk/eli/lta/2021/2091). 

(59)  Habitatbekendtgørelsen,  BEK  No 1098  of  21 August  2023 

(60) 

(61) 

(62) 

(63) 

the 

Data 

EEA’s 

Eionet 

Central 

Repository 

(https://www.retsinformation.dk/eli/lta/2023/1098). 
EEA,  ‘Biodiversity  pledges –  Protected  areas’,  Reportnet,  April 
2023, https://reportnet.europa.eu/public/dataflow/703. 
See 
(https://cdr.eionet.europa.eu/dk/eu/n2000/envzd3iow). 
Accepted changes will be  reflected in the update of the Union 
lists of SCIs. 
Eurostat  dataset env_bio4, protected area percentage for 2022, 
accessed 
2025, 
https://ec.europa.eu/eurostat/databrowser/view/env_bio4/def
ault/table?lang=en.  The  newly  classified  marine  SPAs  increase 
the  legally  protected Danish  marine  area.  However,  this is not 
reflected in Eurostat data (18.8 %) used for this report. 

March 

2025 Environmental Implementation Review – Denmark 

 
 
Figure 9:  Natura  2000  terrestrial  protected  area 
coverage per Member State (%), 2023 

Source: European Environment Agency (EEA), ‘Natura 2000 Barometer’, 
2023  data,  accessed  March  2025,  https://www.eea.europa.eu/data-
and-maps/dashboards/natura-2000-barometer. 

Designating  special  areas  of  conservation  and  setting 
site-specific conservation objectives and measures 

In order to ensure that SCIs contribute to the objectives 
of the Habitats Directive, Member States must designate 
them  as  SACs,  setting  site-specific  conservation 
objectives based on the ecological needs of the species 
and  habitats  present  on  the  sites.  The  site-specific 
conservation  objectives  must  be  defined  in  terms  of 
attributes  and  targets  that  cover  the  properties  of  the 
feature  of  interest  that  are  necessary  to  describe  its 
condition  as  either  favourable  or  unfavourable.  These 
objectives  must  address  the  key  pressures  and  threats 
present  on  the  site.  Article 6  of  the  Habitats  Directive 
requires  Member  States  to  establish  and  implement 
conservation  measures  for  the  realisation  of  the 
objectives of the site. 

In Denmark, Natura 2000 management plans for 2022–
2027  have  been  drawn  up  for  all  Natura  2000  sites (64) 
except  for  the  newly  classified  marine  SPAs.  For  these 
sites,  the  collection  of  further  data  is  required  before 
management  plans  can  be  developed.  The  already 
existing  management  plans 
site-specific 
conservation objectives. 

include 

As  regards  the  quality  of  conservation  objectives,  the 
development  of  a  condition  assessment  system  is  still 

(64)  Danish  Agricultural  Agency,  ‘Natura  2000  management  plans 
https://mst.dk/erhverv/rig-

2022–2027’, 
natur/naturindsatser/natura-2000/natura-2000-planlaegning-
2022-2027. 
These  are  12  terrestrial  habitats  including  all  forest  types,  2 
freshwater habitats and 8 marine habitats. 

(65) 

Denmark  14 

pending for certain habitat types (65). 

Natura  2000  action  plans 
including  conservation 
measures for the Natura 2000 sites have been drawn up 
it 
by  the  Danish  Nature  Agency 
manages (66).  Action  plans  for  the  other  Natura  2000 
areas  have  been  prepared  by  the  municipalities  and 
other landowners. 

for  the  areas 

is  missing 

A  clear  link  between  the  regulation  of  nitrates  and  the 
in  Denmark  and  the 
Nature  Directives 
measures  undertaken  so 
far  to  reduce  nitrogen 
emissions  may  not  be  sufficient  to  correspond  to  the 
ecological requirements of sensitive habitats and species 
protected  under  the  Nature  Directives  to  reach 
favourable  conservation  status.  The  Danish  authorities 
are  working  on  setting  up  a  new  system  to  address 
ammonia  emissions,  which  will  include  methods  to 
protect sensitive habitats. 

2025 priority action 

•  Finalise 

the 

establishment 

site-specific 
conservation objectives and measures for all Natura 
2000 sites (including by adopting their management 
plans) and ensure their effective implementation. 

of 

Recovery of species 

One  objective  set  by  the  BDS  is  that,  by  2030,  there 
should be no further deterioration in conservation trends 
or  the  status  of  any  protected  species.  The  BDS  also 
states  that  Member  States  should  ensure  that  at  least 
30 % of species not currently in favourable conservation 
status  achieve  that  status  or  show  progress  towards 
doing so (e.g. by exhibiting positive population dynamics 
or stable or increasing range and habitat size), by 2030. 
According  to  the  European  Environment  Agency  (EEA), 
based  on  reporting  required  under  Article 17  of  the 
Habitats Directive, a quarter of species in the EU were of 
good conservation status as of 2018 (67). 

One of the primary objectives of the Habitats Directive is 
the  maintenance  of  or  restoration  to  favourable 
conservation status of all species of community interest. 
Moreover, the Birds Directive also aims to ensure that all 
wild  birds  in  the  EU  enjoy  a  secure  status.  In  order  to 
achieve these objectives, it will be necessary to address 
key  pressures  and  threats.  The  Birds  Directive  and  the 
Habitats  Directive  lay  down  a  framework  of  species 

(67) 

2000 

plans 

action 

(66)  Ministry  of  the  Environment,  ‘Nature  Agency  of  Denmark’s 
(2033)’, 

Natura 
https://gis.nst.dk/n2k/gaeldendenatura2000plejeplan/. 
EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
European 
2020, 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 

Luxembourg, 

2022–2027 

Union, 

2025 Environmental Implementation Review – Denmark 

 
 
 
protection rules and rules on the conservation of habitats 
and species in order to combat these threats. 

Under  Article  17  of  the  Habitats  Directive,  Member 
States are required to report on the conservation status 
of habitats and species every six years. Reports for the 
current reporting cycle, covering 2019–2024, are due for 
submission  in  July  2025.  Figures  10  and  11  show  the 
latest available conservation status data. 

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

For 2013–2018, the share of assessments showing a good 
conservation status are as follows. 

•  The share for habitats is only 5 %, which is the second 
lowest  in  the  EU  and  the  same  as  in  the  previous 
reporting period (2007–2012) (Figure 10). 

•  The share for species is 20 %, which is less than the 
32 % noted in the previous reporting period  (2007–
2012) (Figure 11) (68). 

Denmark  15 

Figure 10:  Assessments  of  conservation  status  of 
habitats  for  the  2007–2012  and  2013–2018  reporting 
periods 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in conservation status 
in a Member State may result from changes to methods or use of better 
data, rather than reflecting genuine changes. 

The  share  of  habitats  in  bad  conservation  status  has 
remained high at 77 % and the share of assessments for 
species in bad conservation status has increased to 34 %, 
as  shown  in  Figures 10  and  11 (69).  The  main  pressures 
come  from  agriculture;  mixed  sources  of  pollution, 
development; 
residential, 
commercial,  industrial  and  recreational  infrastructure; 
and alien and problematic species. 

construction; 

use  of 

Under the BDS, Denmark submitted its pledge to improve 
the conservation status of the habitats and species with 
declining trends (70). 

(68) 

(69) 

According  to  the  report  submitted  by  Denmark  on  the 
conservation status of habitats and species covered by Article 17 
of the Habitats Directive. 
EEA,  ‘State  of  nature  in  the  EU’,  infographic,  last  updated 
2021), 
4 November 

(30 September 

2024 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2025, 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

accessed 

March 

2019, 

Figure 11:  Assessments  of  conservation  status  of 
species  for  the  2007–2012  and  2013–2018  reporting 
periods 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in conservation status 
in a Member State may result from changes to methods or use of better 
data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 

https://www.eea.europa.eu/signals/signals-
2021/infographics/state-of-nature-in-the-eu/view. 
EEA, ‘Biodiversity pledges – Conservation status improvements’, 
Reportnet, https://reportnet.europa.eu/public/dataflow/705. 

(70) 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
2019, 

19 December 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

accessed 

March 

2025, 

the 
financial 
Denmark  has  used 
environment (LIFE) funding for nature projects, such as 
the LIFE Ring (71) and LIFE Orchids (72) projects. 

instrument 

for 

In  2022,  the  European  Commission  identified  three 
priority actions. The first priority action, also identified in 
2017 and 2019, was to 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  those  from  agriculture.  There  has  been  no  progress 
made.  

The  second  priority  action,  also  identified  in  2017  and 
2019,  was  to  finalise  the  update  of  the  Natura  2000 
management plans to be adopted for the next planning 
cycle  to  ensure  that  their  conservation  objectives  and 
measures  are  clearly  defined,  sufficiently  detailed  and 
linked  with  other  applicable  legislation  and  plans  to 
achieve  favourable  conservation  status.  Some  progress 
was  made  on  this  priority  action,  as  the  Natura  2000 
management  and  action  plans  have 
largely  been 
developed.  However,  Natura  2000  management  plans 
have not been developed for the marine SPAs classified 
in  2021  and  2023,  and  a  condition  assessment  system 
needs to be developed for certain habitat types to ensure 
the quality of the conservation objectives.  

The third priority action concerned the  completion and 
finalisation of the prioritised action framework (PAF), on 
which there has been no progress. Denmark was the only 
Member State that did not submit its PAF for investment 
in  Natura  2000  sites.  However,  this  action  is  not 
maintained,  as 
financial 
the  current  multiannual 
framework (MFF) period will end in two years. 

2025 priority action 

•  Continue supporting the integration of biodiversity 
actions into other policies, e.g. energy, agriculture, 
fisheries, forestry, urban and infrastructure planning 
and 
promote 
and 
communication between stakeholders.   

sustainable 

tourism, 

•  Reinforce  action 

in 
unfavourable  conservation  status,  for  example 
increased 
restoration  measures, 
through 

for  habitats  and  species 

(71) 

(72) 

October 

Database, 

European Commission, ‘Restoration of habitat complexes’, LIFE 
Public 
2024, 
accessed 
https://webgate.ec.europa.eu/life/publicWebsite/project/LIFE2
3-NAT-DK-LIFE-Ring-101147731/restoration-of-habitat-
complexes. 
European  Commission,  ‘Restore  and  connect  existing  and new 
EU  priority  dry  grasslands  (6210*,  6120*,  6230*)  to  secure 
favourable  conservation  status  of  habitat  types  and  species 
(orchids,  butterflies,  and  pollinators)’,  LIFE  Public  Database, 

Denmark  16 

connectivity,  better  policy  coordination  and 
integration, and increased funding. 

Recovery of ecosystems 

Agricultural ecosystems 

The BDS works alongside the common agricultural policy 
(CAP) to support the transition to sustainable agriculture. 

The  strategy  has  set  five  common  agriculture-related 
targets for 2030, namely to: 

—  reduce by 50 % the overall use of – and risk from – 

chemical pesticides; 

—  reduce  by  50 %  the  use  of  more  hazardous 

pesticides; 

—  reduce  by  50 %  losses  of  nutrients  from  fertilisers 
(which  will result in a  20 % reduction in the use of 
fertilisers)  while  ensuring 
is  no 
deterioration of soil fertility; 

there 

that 

—  restore  at  least  10 %  of  agricultural  area  to  have 

— 

high-diversity landscape features; and 
increase the area under organic farming to at least 
25 %. 

The “Vision for agriculture and food” (73), adopted by the 
European Commission in February 2025, sets a roadmap 
to  an  agri-food  system  that  is  attractive,  competitive, 
sustainable and fair for current and future generations. 
To  ensure  a  sustainable  future  for  EU  agriculture,  it  is 
crucial  that  these  four  priority  areas  are  pursued 
together,  and  that  public  and  private  support  are 
adequately targeted toward this objective. 

The  CAP  and  national  CAP  strategic  plans  are  key 
instruments  to  facilitate  and  strengthen  the  efforts  of 
European  farmers  to  protect  biodiversity  and  the 
environment  at 
large.  The  Commission  approved 
Member  States’  CAP  strategic  plans  in  2022  for  the 
programming period 2023-2027. The CAP is the  largest 
source  of  funding  dedicated  to  supporting  biodiversity 
and  plays  a  significant  role 
implementing  EU 
environmental policy. Strategic plans should continue to 
support  the  protection  of  soil,  water,  air  quality  and 
biodiversity. 

in 

October 

2024, 
accessed 
https://webgate.ec.europa.eu/life/publicWebsite/project/LIFE2
2-NAT-DK-LIFE-ORCHIDS-101113801/restore-and-connect-
existing-and-new-eu-priority-dry-grasslands-6210-6120-6230-
to-secure-favorable-conservation-status-of-habitat-types-and-
species-orchids-butterflies-and-pollinators. 
https://agriculture.ec.europa.eu/overview-vision-agriculture-
food/vision-agriculture-and-food_en. 

(73) 

2025 Environmental Implementation Review – Denmark 

 
 
 
Denmark  17 

and provide support for eco-schemes covering practices 
for  the  maintenance  of  non-productive  areas,  such  as 
land  lying  fallow,  and  for  the  establishment  of  new 
landscape features on arable land. 

Unlike  most  Member  States,  Denmark  did  not  exempt 
farmers from the obligation to have a minimum share of 
3–4 % of non-productive area or landscape features as of 
2023 (due to the war in Ukraine). Furthermore, after the 
changes  to  the  CAP  regulations  that  deleted  this 
obligation  for  all  EU  farmers  (78),  Denmark  decided  to 
amend  its  CAP  strategic  plan  in  2024,  to  introduce  a 
supplementary GAEC, which contains a similar obligation 
for farmers to have 3–4 % non-productive areas. 

The recently adopted Nature Restoration Regulation (79) 
focuses on the restoration of agricultural ecosystems and 
requires Member States to put in place measures which 
aim to achieve an increasing trend at the national level in 
at  least  two  out  of  three  indicators  for  agricultural 
ecosystems (80). One of these indicators is the ‘share of 
agricultural land with high-diversity landscape features’. 

Organic  farming  practices  are  highly  beneficial  to 
biodiversity. As shown in  Figure 12, it is estimated that 
11.43 %  of  Denmark’s  utilised  land  area  is  used  for 
organic  farming.  This  is  above  the  EU  average  of 
10.50 % (81).  Denmark  is  contributing  to  achieving  the 
target of 25 % of the EU’s agricultural land being used for 
organic farming by 2030. 

indicators 

certain  CAP 

focus  on 
result 
While 
interventions favouring sustainable agriculture practices 
that  regenerate  ecosystems,  the 
impact  of  these 
measures  is  difficult  to  assess.  The  uptake  of  eco-
schemes is voluntary for farmers. 

However, at the level of the Member State, at least 25 % 
of the allocations provided for direct payments must be 
reserved for  each calendar year from 2023 to 2027 for 
the eco-schemes. 

The utilised agricultural area in Denmark decreased from 
in  2023 (74). 
2 663 600 ha 
in  2012  to  2 620 950 ha 
Therefore,  agricultural  activities  occupy  about  60 %  of 
the  Danish  territory  and  dominate  other  forms  of  land 
use in Denmark (75). 

‘share  of  agricultural 

Landscape features are fragments of non-productive and 
typically – but not exclusively – semi-natural vegetation 
present in or adjacent to agricultural land. They provide 
ecosystem  services  and  support  for  biodiversity.  The 
indicator 
land  covered  with 
landscape  features’  is  the  ratio  between  the  area 
covered  by  non-productive  landscape  features  and  the 
area  covered  by  agricultural  land.  Based  on  the  Land 
Use/Cover  Area  Frame  Survey (76)  landscape  features 
estimates, the share of agricultural land covered by non-
productive  landscape  features  in  Denmark  is  5.3 %, 
slightly below the EU average. At the EU level, landscape 
features cover 5.6 % of agricultural land. 

In  2024,  the  CAP  basic  regulations  were  amended (77) 
regarding, inter alia, the standards for good agricultural 
and  environmental  condition  of  land  (GAECs).  These 
changes  removed  the  obligation  for  farmers  benefiting 
from CAP area-related support to have a minimum share 
of 3–4 % of non-productive area or landscape features in 
their  farms.  The  amended  CAP  regulations  do  not 
remove the obligation under GAEC 8 to maintain existing 
landscape  features.  The  amended  regulations  set  out, 
however,  an  obligation  for  Member  States  to  establish 

(74) 

(75) 

(76) 

(77) 

8 November 

Eurostat,  ‘Utilised  agricultural  area  by  categories’,  tag00025, 
accessed 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/tag00025/de
fault/table?lang=en. 
Statistics  Denmark,  ‘Land  use  accounts’,  16 January  2023, 
https://www.dst.dk/en/Statistik/emner/miljoe-og-
energi/areal/arealopgoerelser. 
See  the  European  Commission  web  page  on  the  survey 
(https://esdac.jrc.ec.europa.eu/projects/lucas); 
European 
Commission:  Joint  Research  Centre,  ‘Landscape  features  in 
agricultural 
is  the  extent?’,  EU  Science  Hub, 
https://joint-research-
30 September 
centre.ec.europa.eu/jrc-news-and-updates/landscape-features-
agricultural-land-what-extent-2024-09-30_en. 
Regulation (EU) 2024/1468 of the European Parliament and of 
the  Council  of  14 May  2024  amending  Regulations  (EU) 
2021/2115 and (EU) 2021/2116 as regards good agricultural and 
environmental  condition  standards,  schemes  for  climate, 
environment  and  animal  welfare,  amendment  of  the  CAP 
strategic plans, review of the CAP strategic plans and exemptions 

land:  What 

2024, 

(78) 

(79) 

(80) 

(81) 

13 

on 

land 

lying 

fallow, 

February 

from  controls  and  penalties  (OJ  L,  2024/1468,  24.5.2024), 
http://data.europa.eu/eli/reg/2024/1468/oj. 
Commission  press  release,  European  farmers  exempted  from 
rules 
2024, 
https://ec.europa.eu/commission/presscorner/detail/en/ip_24
_781.  
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
http://data.europa.eu/eli/reg/2024/1991/oj. 
The  three  indicators  are  ‘grassland  butterfly  index’,  ‘stock  of 
‘share  of 
organic  carbon 
agricultural land with high-diversity landscape features’. 
This is based on the latest available information from Eurostat, 
which 
is  currently  under  review;  European  Commission, 
Agriculture biologique au sein de l’union européenne, factsheet, 
2024, 
Brussels, 
https://agriculture.ec.europa.eu/document/download/c67458e
d-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-
organic-farning_fr.pdf&prefLang=en. 

in  cropland  mineral  soils’  and 

2025 Environmental Implementation Review – Denmark 

 
 
Figure 12:  Share  of  total  utilised  agricultural  area 
occupied  by  organic  farming  per  Member  State  (%), 
2022 

Denmark  18 

resilience (82) aims to introduce the first comprehensive 
legislation on the protection of all soils in the EU. Should 
the  directive  be  adopted,  Member  States  will  have  to 
transpose  it  into  national  legislation  and  implement  it, 
starting  with  putting  in  place  the  governance  systems 
and a sound monitoring framework building on existing 
national  soil  monitoring  frameworks.  The  objective  of 
the  proposed  directive  is  to  provide  better  and  more 
comparable  soil  health  data  with  the  view  of  attaining 
healthy soils by 2050. 

Degradation  of  soil  ecosystems  encompasses  several 
aspects. The proposed directive requires Member States 
to  assess  soil  health  according  to  a  set  of  common 
indicators  and  to  define  the  necessary  regeneration 
measures. The area of soil that is sealed is an important 
factor in monitoring land-use change and represents an 
important pressure on nature and biodiversity. Other soil 
issues  related  to  land degradation  are  soil  erosion,  soil 
compaction, 
soil 
contamination, soil salinisation and the presence in soil 
of  nitrogen  and  phosphorus  in  excess.  The  impact 
assessment accompanying the proposal, which builds on 
the data available in the EU Soil Observatory, points to 
the following soil degradation issues in Denmark (83). 

soil  organic 

loss  of 

carbon, 

Half of Denmark’s soils have concentrations of nitrogen 
exceeding 50 kg/ha; this affects 73 % of agricultural land 
area.  A  quarter  of  Danish  soils  have  concentrations  of 
phosphorus  exceeding  50 mg/kg.  45 %  of  the  national 
territory  experiences  unsustainable  soil  erosion  by 
water, wind, tillage and harvest, representing 65 % of the 
total cropland area. 

Grasslands 

Grasslands  are  among  the  most  diverse  ecosystems  in 
the EU; they can contain as many as 80 different  plant 
species per square metre and are home to a large variety 
of animals, ranging from small insects, birds and rodents 
to 
for 
large  herbivores.  Grasslands  are  essential 
agriculture and livestock herding. Natural grasslands also 
play  an  important  role  in  storing  carbon.  However, 
changes  in  agricultural  practices  and  land  uses  have 
caused  grasslands  to  disappear  at  an  alarming  rate, 
making  them  one  of  Europe’s  most  threatened 
ecosystems. 

In  Denmark,  there  are  five  grassland  habitat  types (84) 
protected  under  the  Habitats  Directive  and  the  overall 

and  resilience  (Soil  Monitoring  Law),  SWD(2023) 417  final  of 
5 July 
2023, 
https://environment.ec.europa.eu/system/files/2023-
07/IMPACT 
REPORT_ANNEXES_SWD_2023_417_part4.pdf. 
These are 6120*, 6210, 6230*, 6410 and 6430. 

ASSESSMENT 

(84) 

Source: Eurostat, ‘Area under organic farming’, sdg_02_40, accessed 5 
December 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en. 

2025 priority action 

• 

Implement  eco-schemes  and  agri-environmental 
measures and practices to address the environmental 
needs of Denmark. 

Soil ecosystems 

Soil is an essential, finite and extremely fragile resource. 
Its  increasing  degradation  poses  a  threat  to  EU  food 
security  and  climate 
resilience,  adaptation  and 
mitigation. 

The EU soil strategy, adopted in November 2021, aims to 
support  soil  protection,  sustainable  soil  management 
and  the  restoration  of  degraded  soils  to  achieve  the 
Green  Deal  objectives  as  well  as  land  degradation 
neutrality by 2030. 

This entails: 

—  preventing further soil degradation; 
—  making  sustainable  soil  management  the  new 

normal; 

—  taking action for ecosystem restoration. 

The  proposed  directive  on  soil  monitoring  and 

(82) 

(83) 

Proposal for a directive of the European Parliament and of the 
Council on soil monitoring and resilience (Soil Monitoring Law), 
COM(2023) 416 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex:52023PC0416. 
Commission  staff  working  document –  Impact  assessment 
report: Annexes – Accompanying the proposal for a directive of 
the European Parliament and of the Council on soil monitoring 

2023, 

5 July 

final 

of 

2025 Environmental Implementation Review – Denmark 

 
 
 
assessments show that all grassland habitats are ranked 
as having unfavourable-bad or unfavourable-inadequate 
conservation status (85). The main pressures and threats 
for grasslands are agriculture,  pollution (including from 
agriculture), invasive alien species (IAS) and forestry (86). 

Wetlands/peatlands 

Wetlands act as water sources and purifiers; they are the 
planet’s  greatest  natural  carbon  stores  and  they  are 
crucial  to  agriculture  and  fisheries.  Peatlands  are  a 
special  type  of  wetlands  dominated  by  peat-forming 
plants such as Sphagnum mosses. Nearly all peatlands in 
the EU are habitat types listed in Annex I to the Habitats 
Directive. Drained peatlands under intensive agricultural 
use  constitute  only  3 %  of  the  EU’s  utilised  agricultural 
area. At the same time, they are responsible for 25 % of 
the  GHG  emissions  from  the  EU’s  agricultural  sector. 
Restoring  peatlands  brings  multiple  benefits,  as 
peatlands  improve  water  retention  and  quality,  store 
carbon, reduce GHG emissions and increase biodiversity. 

In  Denmark,  there  are  seven  wetland/peatland  habitat 
types (87) protected under the Habitats Directive and the 
overall assessments show that all of them are ranked as 
having  unfavourable-bad  or  unfavourable-inadequate 
conservation status (88). The main pressures and threats 
for  wetlands/peatlands  are  pollution  (including  from 
agriculture),  modification  of  water  regimes,  IAS  and 
agriculture (89). 

Denmark has a national ambition of taking 100 000 ha of 
carbon-rich  low-lying  soils  and  buffer  areas  out  of 
production by 2030, but only a small area has been set 
aside since 2021 (90). The target increased to 140 000 ha 
according  to  the  agreement  on  a  Green  Denmark  (see 
‘Nitrates Directive’ in Chapter 3). 

2025 priority action 

• 

Implement  peatland  conservation  and  restoration 

(85) 

(86) 

(87) 
(88) 

(89) 

According  to  data  for  the  latest  reporting  period  (2013–2018) 
reported  under  Article 17  of 
the  Habitats  Directive 
(https://nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Grasslands&country=DK&region=). 
https://tableau-
public.discomap.eea.europa.eu/views/sonpressuresandthreats/
Pressuresandthreats?%3Adisplay_count=n&%3Aembed=y&%3
AisGuestRedirectFromVizportal=y&%3Aorigin=viz_share_link&
%3AshowAppBanner=false&%3AshowVizHome=n. 
These are 7110*, 7120, 7140; 7150, 7210*, 7220* and 7230. 
According  to  data  for  the  latest  reporting  period  (2013–2018) 
reported  under  Article 17  of 
the  Habitats  Directive 
(https://nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Bogs%2C+mires+%26+fens&country=DK&region=). 
https://tableau-
public.discomap.eea.europa.eu/views/sonpressuresandthreats/
Pressuresandthreats?%3Adisplay_count=n&%3Aembed=y&%3

Denmark  19 

measures and include such measures and objectives 
in the national restoration plans. 

Forest ecosystems 

Forests are important carbon sinks, and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 
The EU forest strategy for 2030, adopted in July 2021, is 
a  plan  of  actions  to  promote  the  many  services  that 
forests  provide.  Its  key  objective  is  to  ensure  healthy, 
diverse  and  resilient  EU 
forests  that  contribute 
significantly to the achievement of the EU’s biodiversity 
and climate ambitions. About 27 % of the forest area in 
the EU is covered by habitat types listed in Annex I to the 
Habitats  Directive.  Moreover,  forests  host  several 
species  protected  under  the  Birds  and  Habitats 
is  a 
Directives, 
requirement  to  designate  Natura  2000  sites  and  to 
protect breeding sites and resting places. 

including  those  for  which  there 

Several  guidelines  on  forestry  management  were 
published  in  2023.  They  covered  biodiversity-friendly 
afforestation, reforestation and tree planting; closer-to-
nature  forest  management;  and  defining,  mapping, 
monitoring  and  strictly  protecting  primary  and  old-
growth  forests.  Further  guidance  on  payment  schemes 
for ecosystems services has also been published. 

In  2023,  the  Commission  proposed  a  new  forest 
monitoring law (91) that aims to create a comprehensive 
forest  knowledge  base,  address  information  gaps  and 
enable  a  better  response  to  growing  pressures  on 
forests. 

Assessments  show  that,  of  the  27 %  of  EU  forest  area 
protected under the Habitats Directive, less than 15 % is 
of  favourable  conservation  status (92).  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27 % in 2015 to 31 % in 2018. 

(90) 

AisGuestRedirectFromVizportal=y&%3Aorigin=viz_share_link&
%3AshowAppBanner=false&%3AshowVizHome=n. 
233 ha out of 100 000 ha have been set aside since 2021. Danish 
Agricultural  Agency,  ‘Hvad  sker  der  i  indsatsen  for  at  tage 
landbrugsdrift?’,  Danish  Agricultural 
lavbundsjorder  ud  af 
Agency website, accessed 25 March 2024, https://lbst.dk/groen-
omstilling/hvad-kan-du-goere-som-landbruger/udtagning-af-
lavbundsjorder/hvad-sker-der-i-indsatsen. 

22 

COM(2023)728, 

(91)   Proposal for a Regulation of the European Parliament and of the 
Council  on  a  monitoring  framework  for  resilient  European 
2023, 
forests, 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2023)728&lang=en. 
EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
2020, 
European 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 

Luxembourg, 

November 

Union, 

(92) 

2025 Environmental Implementation Review – Denmark 

 
 
In Denmark, forests covered 15 % of the land in 2020 (93), 
with  21 000 ha 
in  Denmark  covered  by  primary 
forests (94).  There  are  nine  forest  habitat  types  (95) 
protected  under  the  Habitats  Directive  and  the  overall 
assessments showed that the conservation status of all 
forest  habitats  is  ranked  as  unfavourable-bad  (96).  The 
main  pressures  and  threats  for  forests  are  forestry, 
pollution  and  modification  of  water  regimes  (97). 
(Figure 13) (98). 

Figure 13:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  per  Member  State  (%  of 
assessments), 2013–2018 

Source: Commission staff working document – New EU forest strategy 
final  of  16 July  2021,  p. 24,  eur-
for  2030,  SWD(2021) 652 
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0652. 

(93) 

(94) 

(95) 
(96) 

(97) 

(98) 

EEA,  forest  information  system  for  Europe,  ‘Country –  FISE 
country  factsheets’,  forest  information  system  for  Europe 
website, https://forest.eea.europa.eu/countries; Denmark uses 
Food  and  Agriculture  Organization  National  Forest  Inventory 
data, which gives a higher figure of 14.7 %. 
European  Commission:  Joint  Research  Centre,  Mapping  and 
assessment  of  primary  and  old-growth  forests  in  Europe, 
Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
p. 13, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC124
671;  Denmark  uses another  source,  which gives a much lower 
figure of 1 690 ha (Sabatini et al., 2018). 
9110*, 9120*, 9130*, 9150, 9160, 9170, 91D0*, 91E0*. 
According  to  the  latest  reporting  period  (2013-2018)  under 
Article 17, Article 17 web tool – Habitat assessments at Member 
State 
nature-
level, 
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Forests&country=DK&region=. 
https://tableau-
public.discomap.eea.europa.eu/views/sonpressuresandthreats/
Pressuresandthreats?%3Adisplay_count=n&%3Aembed=y&%3
AisGuestRedirectFromVizportal=y&%3Aorigin=viz_share_link&
%3AshowAppBanner=false&%3AshowVizHome=n. 
Commission staff working document – Stakeholder consultation 
and 
document 
evidence 
from  the  Commission  to  the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – New EU forest 
strategy  for  2030,  SWD(2021) 652  final  of  16 July  2021,  p. 24, 

Accompanying 

base: 

the 

Denmark  20 

. 

However,  Denmark  envisages  creating  250 000 ha  of 
new forest by 2045 as laid down in the agreement on a 
in 
Green  Denmark 
Chapter 3) (99). 

‘Nitrates  Directive’ 

(see 

The  EU  Timber  Regulation  (EUTR) (100)  prohibits  the 
placing  on  the  EU  market  of  illegally  harvested  timber. 
According  to  the  EUTR,  Member  States’  competent 
authorities  must  conduct  regular  checks  on  operators 
and traders and apply penalties for non-compliance. 

On  29 June  2023,  the  Regulation  on  Deforestation-free 
into  force  (102).  The 
Products  (EUDR) (101)  entered 
regulation  seeks  to  guarantee  that  products  in  the  EU 
that  are  made  using  any  of  seven  listed  commodities 
have  no  links  to  deforestation.  The  EUDR  repeals  the 
EUTR.  

2025 priority action 

• 

Improve conservation status of forests by promoting 
forest  management  and  ensuring 
sustainable 
compliance  with  the  Habitats  Directive  before 
granting/renewing permits for forest logging. 

Marine ecosystems 

The  Marine  Strategy  Framework  Directive  (MSFD) 
requires Member States to achieve good environmental 
status  (GES)  for  their  marine  waters.  To  that  end, 
Member States must draw up marine strategies for their 
marine waters and cooperate with other Member States 

https://eur-lex.europa.eu/legal-
content/NL/TXT/?uri=CELEX:52021SC0652. 
(99)  Ministry  of  Environment  and  Equality, 

‘Skov’,  accessed 
11 November  2024,  https://mim.dk/vores-opgaver/natur-og-
biodiversitet/skov; see also the NBSAP adopted in October 2024 
(https://s3.amazonaws.com/km.documents.attachments/472c/
770f/a889e94e81b54a6ad8d9cf0f?AWSAccessKeyId=AKIAT3JJQ
DEDLXMBJAHR&Expires=1737367455&response-content-
disposition=inline%3B%20filename%3D%22WEB_ENGLISH_Nati
onal_handlingsplan_for_biodiv_2024.pdf%22&response-
content-
type=application%2Fpdf&Signature=XWavr%2BrnXpVJ9TmqofD
uhA%2FzoJ8%3D). 

(100)  Regulation (EU) No 995/2010 of the European Parliament and of 
the  Council  of  20 October  2010  laying  down  the  obligations  of 
operators who place timber and timber products on the market 
(OJ  L 295,  12.11.2010,  p. 23),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010R0995. 

(101)  Regulation (EU) 2023/1115 of the European Parliament and of 
the Council of 31 May 2023 on the making available on the Union 
market and the export  from the Union of certain commodities 
and  products  associated  with  deforestation  and 
forest 
degradation  and  repealing  Regulation  (EU)  No 995/2010  (OJ 
L 150,  9.6.2023,  p. 206),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461. 

(102)  The law will apply to large and medium-sized companies starting 
on  December  30,  2025,  and  to  micro  and  small  enterprises 
starting on June 30, 2026. 

2025 Environmental Implementation Review – Denmark 

 
 
 
sharing  the  same  marine  region  or  subregion.  These 
marine  strategies  comprise  different  steps  to  be 
developed and implemented over six-year cycles. 

Since the 2022 EIR report, no additional data regarding 
Member  States’  set  of  GES  characteristics  for  each 
descriptor 
in  the  MSFD  have  become  available. 
Nevertheless, Member States had to report updates by 
15 October  2024,  and  these  will  be  assessed  by  the 
Commission.  In  the  context  of  this  next  round  of 
reporting, 
in  accordance  with  the  MSFD  and  the 
Commission  GES  decision (103),  Member  States  must 
include  as  part  of  their  set  of  GES  characteristics  any 
threshold  values  for  the  descriptors  in  the  MSFD  that 
may  have  been  established  in  cooperation  with  other 
Member States at the EU or regional level (104). 

The  Commission  assessed  the  updated  monitoring 
programme reported by Member States in 2020 (105). At 
that  time  their  updates  on  the  elements,  features  and 
parameters identified monitoring gaps. The Commission 
recommended  that  Member  States  should  prioritise 
work 
levels  of 
implementation of the MSFD. 

those  gaps  at  all 

to  address 

Member States also reported their updated programmes 
of measures, which are required under Article 13 of the 
MSFD and  which must  be updated every  six years. The 
Commission has assessed Member States’ programmes 
of measures. 

However, Denmark reported its programme of measures 
with  too  much  delay  for  it  to  be  included  in  the 
Commission’s general assessment of the Member States’ 
programmes of measures. 

2025 priority action 

•  Report its updates on the state of its marine waters, 
its  targets  and  its  determinations  of  GES (106)  which 
are expected to include any threshold values for the 
in  the  MSFD  that  may  have  been 
descriptors 

Denmark  21 

established in cooperation with other Member States 
at the EU or regional level. 

Prevention and management of invasive alien 
species 

IAS  are  a  major  cause  of  biodiversity  loss  in  the  EU. 
Besides  inflicting  direct  and  indirect  damage  on  nature 
and  the  economy,  some  IAS  also  carry  and  spread 
infectious  diseases,  posing  a  threat  to  humans  and 
wildlife.  Regulation 
IAS 
Regulation) aims to prevent, minimise and mitigate the 
adverse impacts of IAS on biodiversity. It focuses action 
on a list of IAS of EU concern (the ‘Union list’), which is 
regularly updated (107). 

(EU)  No 1143/2014 

(the 

The third update of the Union list entered into force on 
2 August 2022 (108). The fourth update is in preparation. 

The IAS Regulation (109) currently lists 88 species subject 
to  restrictions  on  keeping,  importing,  selling,  breeding, 
growing  and  releasing  into  the  environment.  Member 
States are required to take measures to (i) prevent the 
introduction of IAS, (ii) ensure early detection and rapid 
eradication  of  IAS  and  (iii)  manage  species  that  are 
already widespread on their territory. 

This  aligns  with  target 6  of  the  GBF  to  reduce  the 
introduction of IAS by at least 50 % by 2030 and minimise 
their impact. 

Preventing  the  introduction  and  spread  of  IAS,  and 
managing  them, 
including  through  eradication  and 
control,  can  result  in  a  substantial  cost  saving.  Studies 
estimate  that  the  total  cost  of  IAS  in  Europe  (damages 
and  management)  amounted  to  EUR 116.61 billion 
between 1960 and 2020 (110). More recent studies have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 

(103)  Commission  Decision  (EU) 2017/848  of  17 May  2017  laying 
down  criteria  and  methodological  standards  on  good 
environmental  status  of  marine  waters  and  specifications  and 
standardised  methods  for  monitoring  and  assessment,  and 
repealing  Decision 2010/477/EU  (OJ  L 125,  18.5.2017,  p. 43), 
http://data.europa.eu/eli/dec/2017/848/oj. 

(104)  Communication  from  the  Commission  of  11 March  2024 – 
Commission notice on the threshold values set under the Marine 
Strategy  Framework  Decision  (Directive  2008/56/EC)  and 
Commission  Decision  (EU)  2017/848  (OJ  C,  C/2024/2078, 
11.3.2024), http://data.europa.eu/eli/C/2024/2078/oj. 

(105)  https://environment.ec.europa.eu/system/files/2023-

04/C_2023_2203_F1_COMMUNICATION_FROM_COMMISSION
_EN_V5_P1_2532109.PDF. 
In accordance with Article 17 of Directive 2008/56/EC. 

(106) 
(107)  Commission Implementing Regulation (EU) 2016/1141 of 13 July 
2016 adopting a list of  invasive alien species of Union concern 
pursuant  to  Regulation  (EU)  No 1143/2014  of  the  European 

Parliament  and  of  the  Council  (OJ  L 189,  14.7.2016,  p. 4),  as 
amended  by  Commission 
Implementing  Regulations  (EU) 
2017/1263,  (EU)  2019/1262  and  (EU)  2022/1203,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN. 

(108)  Commission Implementing Regulation (EU) 2022/1203 of 12 July 
2022  amending  Implementing  Regulation  (EU)  2016/1141  to 
update  the  list  of  invasive  alien  species  of  Union  concern  (OJ 
L 186,  13.7.2022,  p. 10),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32022R1203. 

(109)  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 (OJ L 317, 4.11.2014, p. 35). 

(110)  Haubrock, P. J., Turbelin, A. J., Cuthbert, R. N. et al., ‘Economic 
costs of invasive alien species across Europe’, NeoBiota, Vol. 63, 
2021, pp. 153–190. 

2025 Environmental Implementation Review – Denmark 

 
 
increasing  to  USD 148.2 billion  by  2040 (111),  and  at 
USD 423 billion annually at the global level (112). 

capital accounting. 

Denmark  22 

The total number of IAS of Union concern in the country 
is 39. This includes 18 species recorded in the previous 
EIR  (2021)  and  21  additions.  Of  these  21  additions,  14 
were  already  on  the  Union  concern  list  in  2021,  and  7 
were  added  later  under  Commission  Implementing 
Regulation  (EU)  2022/1203.  The  spread  can  be  seen  in 
Figure 14. 

Figure 14:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Denmark, 2024 

2025 priority actions 

•  Step  up  implementation  of  the  IAS  Regulation, 
including with regard to enforcement and capacity of 
inspection authorities. 

Ecosystem assessment and accounting 

The  BDS  calls  on  Member  States  to  better  integrate 
biodiversity  considerations  into  public  and  business 
decision-making  at  all  levels  and  to  develop  natural 

(112) 

(111)  Henry, M., Leung, B., Cuthbert, R. N. et al., ‘Unveiling the hidden 
economic  toll  of  biological  invasions  in  the  European  Union’, 
Environmental Sciences Europe, Vol. 35, No 1, 2023, p. 43. 
Platform 
IPBES 
Biodiversity 
Summary 
Policymakers – 
https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 

on 
Science-Policy 
for 
Services), 
Invasive  alien  species  assessment,  2023, 

(Intergovernmental 

Ecosystem 

and 

(113)  Decision 15/4 adopted by the Conference of the Parties to the 
Convention  on  Biological  Diversity:  Kunming–Montreal  global 
biodiversity 
framework 
(https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-
en.pdf). 

(114)  European  Commission:  Joint  Research  Centre  and  EEA,  EU 
policymakers, 

Assessment – 

Ecosystem 

Summary 

for 

Similarly, target 14 of the GBF (113) aims to ensure the full 
integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 
accounting.  This  requires  effective  and  coherent 
biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (114). 

The amended Regulation (EU) No 691/2011 on European 
environmental  economic  accounts (115)  introduces  new 
requirements  for  Member  States  to  report  on  the 
condition  of  ecosystems  including  urban  ecosystems, 
croplands,  grasslands,  forest  and  woodlands,  coastal 
beaches,  dunes  and  wetlands.  Data  reported  by  the 
Member  States  will  feed  into  the  second  European 
ecosystem assessment, due in 2027, and can also be used 
to support policy decisions. 

An ecosystem assessment is an analysis of the condition 
of ecosystems and the pressures acting on them, as well 
as  the  benefits  that  they  provide  to  people,  either 
directly or indirectly through the economy. 

An 
increasing  number  of  platforms,  networks  and 
communities of practice involve businesses in protecting 
biodiversity,  including  the  EU  Business  &  Biodiversity 
Platform (116). These platforms and communities are key 
tools  for  promoting  and  facilitating  natural  capital 
assessments  among  businesses  and  financial  services 
providers. 

Natural  capital  assessments  help  private  businesses  to 
better  understand  both  the  negative  and  positive 
impacts that they have on nature, and to appreciate how 
nature contributes to their success. Such understanding 
contributes to the implementation of the EU’s BDS. 

their 

In 2022, Denmark received a priority action to continue 
supporting the mapping and assessment of ecosystems 
and 
services,  and  ecosystem  accounting 
development,  as  well  as  to  continue  supporting  the 
development  of  national  business  and  biodiversity 
platforms.  

Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
https://op.europa.eu/en/publication-detail/-
/publication/81ff1498-b91d-11eb-8aca-
01aa75ed71a1/language-en. 

(115)  Proposal for a regulation of the European Parliament and of the 
Council  amending  Regulation  (EU)  No 691/2011  as  regards 
introducing  new  environmental  economic  accounts  modules, 
COM(2022) 329 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:329:FIN. 

11 July 

2022, 

final 

of 

(116)  The  EU  Business  &  Biodiversity  Platform  (https://green-
business.ec.europa.eu/business-and-biodiversity_en)  aims  to 
promote  the  business  case  for  biodiversity  to  businesses  and 
financial institutions through workshops, seminars, reports and 
a cross-media communication strategy. 

2025 Environmental Implementation Review – Denmark 

 
  
 
Six Danish organisations are members of the EU Business 
and  Biodiversity  Platform.  (117)  In  addition,  Denmark 
initiated  a  multistakeholder 
the 
Biodiversity  Partnership,  where  business  organisations, 
NGOs,  knowledge  institutions  and  trade  unions  alike 

initiative  called 

have  joined  forces  to  develop  recommendation  to 
businesses  (118)  on  how  to  operationalize  efficient 
biodiversity action. 

Denmark  23 

(117)  European  Commission,  Business  &  Biodiversity  membership, 

https://green-business.ec.europa.eu/business-and-
biodiversity/about/our-members_en. 

(118)  State of Green, The task of the Danish Biodiversity Partnership, 
https://stateofgreen.com/en/news/the-task-of-

21.10.2024. 
the-danish-biodiversity-partnership/ 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
Denmark  24 

3. Zero pollution 

Clean air 

EU  clean  air  policies  and  legislation  have  successfully 
reduced  emissions  of  key  air  pollutants  and  significantly 
improved  air  quality,  which  is  now  moving  towards  the 
levels  recommended  by  the  World  Health  Organization 
(WHO).  This  has  resulted  in  clear  health  benefits  and 
reduced adverse impacts on ecosystems and biodiversity. 
However, to achieve the WHO-recommended levels, more 
efforts  are  needed,  including  full  compliance  with  EU 
legislation.  To  guide  these  efforts,  the  EU  zero  pollution 
action plan sets targets for 2030 relative to. 2005. These 
are to reduce the health impacts of air pollution by 55 % 
and  to  reduce  the  EU  ecosystems  threatened  by  air 
pollution by 25 %. 

The EU has developed a comprehensive suite of air quality 
policies (119).  These  set  health-based  EU  air  quality 
standards (120)  and  stipulate  Member  States’  national 
emission  reduction  commitments (121)  for  several  air 
pollutants. 

The  air  quality  in  Denmark  is  generally  good,  with  some 
exceptions. 

The  latest  available  annual  estimates  (for  2022)  by  the 
EEA (122) for Denmark attribute 1 200 deaths each year (or 
12 100 years  of  life  lost  (YLL))  to  fine  particulate  matter 
(PM2.5) (123), 50 deaths each year (or 540 YLL) to nitrogen 
dioxide (NO2) (124) and 540 deaths each year (or 5 500 YLL) 
to ozone (125). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Denmark since 2005, while GDP growth has 
continued  (see  Figure 15).  According  to  the  inventories 
submitted  under  Article 10(2)  of  the  National  Emission 
Reduction  Commitments  Directive  (NECD) (126)  in  2024, 
Denmark has met its emission reduction commitments for 

(119)  European  Commission,  ‘Air’,  European  Commission  website, 

https://environment.ec.europa.eu/topics/air_en. 

(120)  European  Commission,  ‘EU  air  quality  standards’,  European 
website, 

Commission 
https://environment.ec.europa.eu/topics/air/air-quality/eu-air-
quality-standards_en.  

(121)  European  Commission,  ‘Reducing  emissions  of  air  pollutants’, 
website, 

European 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants_en. 

Commission 

(122)  EEA, Harm to human health from air pollution in Europe: Burden 
of  disease  2024,  briefing  No 21/2024,  Copenhagen,  2024, 
https://www.eea.europa.eu/en/analysis/publications/harm-to-
human-health-from-air-pollution-2024. 

(123)  Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) covering a wide range of sizes and chemical compositions. 
PM10  refers  to  particles  with  a  diameter  of  10 µm  or  less.  PM2.5 

2020–2029 for air pollutants  nitrogen oxides (NOx), non-
methane  volatile  organic  compounds  (NMVOC),  sulphur 
dioxide (SO2), ammonia (NH3) and PM2.5. According to the 
latest  projections  submitted  under  Article 10(2)  of  the 
NECD in 2023, Denmark is projected to meet its emission 
reduction  commitments  for  2030  onwards  for  NOx, 
NMVOC, SO2, NH3 and PM2.5. 

Denmark  submitted  its  updated  national  air  pollution 
control  programme  (NAPCP)  to  the  Commission  on 
31 March 2023. 

Figure 15:  Emission  trends  of  main  pollutants /  GDP  in 
Denmark (%), 2005–2022 

200%

150%

100%

50%

0%

NH₃

PM2.5
PM2.5

NMVOC

SO₂

NOₓ

GDP

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

refers to particles with a diameter of 2.5 µm or less. PM is emitted 
from many human sources, including combustion. 

(124)  Nitrogen  dioxide  (NO2)  pertains  to  a  group  of  gases  called  NOx, 
which  also  comprises  nitrogen  monoxide  (NO).  NOx  is  emitted 
during fuel combustion – for example, from industrial facilities and 
the road transport sector. 
Low-level  ozone 
is  produced  by  photochemical  action  on 
pollution.  This  year,  for  the  first  time,  the  impact  of  long-term 
exposure to ozone has also been taken into account. In previous 
analysis by the EEA, only the impact of short-term exposure was 
estimated. 

(125) 

(126)  Directive (EU) 2016/2284 of the European Parliament and of the 
Council  of  14 December  2016  on  the  reduction  of  national 
emissions of certain atmospheric pollutants, amending Directive 
2003/35/EC  and  repealing  Directive  2001/81/EC  (OJ  L 344, 
17.12.2016, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2016.344.01.0001.01.ENG. 

p. 1), 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
Figure 16: PM2.5 and NOx emissions by sector in 
Denmark (%), 2022 

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5
PM2.5
2,98%

19,09%

NOₓ

0,18%

49,44%

56,05%

4,90%

8,41%

7,21%

3,76%

9,71%

16,21%

22,06%

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

Denmark  25 

values and target values. Since 2019, downward emission 
trends have been reported for all main pollutants except 
for NMVOC. 

2025 priority actions 

•  As  part  of  the  NAPCP,  take  action  towards  reducing 

emissions of air pollutants.  

•  Ensure  full  compliance  with  the  current  AAQD 
standards, also in light of future stricter requirements 
under the revised AAQD. 

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to: 

(i)  protect  air,  water  and  soil  and  to  prevent  harmful 
effects on human health and the environment; 

(ii)  prevent and manage waste; 
(iii)  improve  energy  and  resource  efficiency,  including 

water; 

(iv)  contribute to decarbonisation. 

The  cornerstone  of  the  policy  is the  Industrial  Emissions 
Directive  (IED),  which  was  revised  in  2024 (129).  The 
revision improves the directive’s contribution to the zero 
pollution  objective.  It  has  a  strong  focus  on  innovation, 
and 
depollution, 
decarbonisation and circularity, making it a key regulatory 
tool  to  accompany  the  green  transformation  of  EU 
industry by 2050. 

between 

builds 

solid 

links 

In 2023, no exceedances above the limit values set by the 
Ambient Air Quality Directive (AAQD) (127) were registered 
in Denmark (128). 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 (130). 

In the 2022 EIR, the European Commission identified two 
priority  actions.  The  first  priority  action  was  to  further 
reduce emissions in the context of the NAPCP. Denmark 
has  made  substantial  progress  on  this,  as  the  latest 
reported  data  show  that  the  2020–2029  emission 
reduction  commitments  have  been  met  and  that  the 
emission  reduction  commitments  for  2030  onwards  are 
projected to be reached. The second priority action was to 
ensure full compliance with EU air quality standards and 
maintain downward emission trends. Based on the latest 
data,  Denmark  has  made  substantial  progress  in  this 
regard.  Full  compliance  has  been  ensured  for  all  limit 

In Denmark, around 2 470 industrial installations require 
permits under the IED. Most of these installations in 2022 
were for intensive poultry and pig rearing (73 %), followed 
by  the  waste  management  sector,  including  landfills 
(14 %),  the  food,  drink  and  milk  sector  (4 %)  and  the 
energy sector (3 %). 

Figure 17  shows  the  damage  to  health  and 
the 
environment due to the main industrial air pollutants. As 
this  depends  on,  among  other  factors,  the  size  of  the 
industrial  sector  in  each  Member  State,  the  figure  also 
shows  the  ratio  between  the  damage  and  the  industrial 
activity  (expressed  in  gross  value  added  (GVA)),  which 

(127)  Directive  2008/50/EU  of  the  European  Parliament  and  of  the 
Council of 21 May 2008 on ambient air quality and cleaner air for 
Europe 
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0050. 

11.6.2008, 

L 152, 

p. 1), 

(OJ 

(128)  EEA, 

Eionet 
(https://cdr.eionet.europa.eu/). 

Central 

Data 

Repository 

(129)  Directive  2010/75/EU  of  the  European  Parliament  and  of  the 
Council of 24 November 2010 on industrial and livestock rearing 

emissions (integrated pollution prevention and control) (OJ L 334, 
17.12.2010, p. 17), as amended by Directive (EU) 2024/1785 of the 
European  Parliament  and  of  the  Council  of  24 April  2024, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02010L0075-
20240804&qid=1725983863299. 
European 

Portal, 
Industrial 
https://industry.eea.europa.eu/, 2022 being the baseline year for 
all reports. 

Emissions 

(130)  EEA, 

2025 Environmental Implementation Review – Denmark 

 
 
 
Denmark  26 

it 

is  below 

gives an indication of the emissions  ‘intensity’. Denmark 
has relatively low damage (the seventh lowest damage in 
the  EU)  and 
the  EU  average  of 
EUR 27.5/EUR 1 000  GVA  for  emissions  intensity  (third 
lowest in terms of damage in the EU). The main industrial 
contributors to emissions to air (131) are the energy sector 
(including  refineries  and  gasification)  and  the  mineral 
sector. 

account  the  human  toxicity  of  each  metal,  as  well  as 
emissions  intensity,  based  on  its  ratio  with  industrial 
activity (expressed in GVA). Denmark has the ninth lowest 
emissions  of  heavy  metals  to  water  and  ranks  seventh 
average: 
lowest 
0.864 kg/EUR 1 billion  GVA).  As  shown  in  Figure 20,  the 
main  industrial  contributor  to  emissions  to  water  in 
Denmark is incineration with energy recovery. 

emission 

intensity 

(EU 

for 

Figure 17:  Industrial  air  pollution  damage  and  intensity 
per Member State, 2021 

Figure 19:  Industrial  releases  and  intensity  of  heavy 
metals to water per Member State, 2022 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
air  pollution  damage  costs  intensity’,  European  Industrial  Emissions 
Portal, 
https://industry.eea.europa.eu/analyse/industrial-
emissions-indicator. 

2024, 

Overall, the industrial emissions to water in the EU have 
decreased  over  time  for  all  the  main  pollutants.  On 
average in the EU, they appear to be decoupled from the 
industrial  activity,  which  has  increased  over  the  same 
period (expressed in GVA), as shown in Figure 18. 

Figure 18: Industrial releases of pollutants to water and 
industrial activity in the EU-27 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
water  pollution  intensity’,  European  Industrial  Emissions  Portal,  2024, 
https://industry.eea.europa.eu/analyse/industrial-emissions-indicator. 

Figure 20:  Relative  releases  to  water  from  industry  in 
Denmark (%), 2022 

100%

75%

50%

25%

0%

Heavy Metals
Ecotoxicity

Heavy Metals
Human Toxicity

Total nitrogen

Total organic
carbon (TOC)

Total phosphorus

Chemicals
Ferrous metal
Incineration with energy recovery
Other manufacturing
Pulp, paper and wood

Electricity and heat production
Food and drink
Landfill
Other waste management
Refineries

Source: EEA, ‘Industrial reporting under the Industrial Emissions Directive 
2010/75/EU  and  European  Pollutant  Release  and  Transfer  Register 
Regulation (EC) No 166/2006 – ver. 12.0 Sep. 2024 (tabular data)’, EEA 
Geospatial 
2024, 
Catalogue, 
https://doi.org/10.2909/cf5e54c1-be99-4426-bcad-baa26c4f27a0. 

13 September 

Data 

NB:  Cd,  cadmium;  Hg, mercury;  Ni,  nickel;  Pb,  lead;  TOC,  total  organic 
carbon; total N, total nitrogen; total P, total phosphorous. 

Source:  EEA,  ‘Industrial  pollutant  releases to  water  in Europe’,  30 May 
2024, 
https://www.eea.europa.eu/en/analysis/indicators/industrial-
pollutant-releases-to-water. 

Concerning  Denmark  in  particular,  Figure 19  shows  the 
industrial emissions of heavy metals to water, taking into 

IED  provisions  on  public  information  and  participation 
require Member States to adopt transposition legislation 
enabling members of the public to have access to relevant 
information  and  participate  in  the  approval  process  for 
potentially  polluting  installations.  Thus,  the  public  and 
(NGOs),  alongside 
non-governmental  organisations 
competent authorities, play a role in ensuring compliance 
of  these  permits  with  EU  legislation.  The  IED  contains 
mandatory  requirements  on  environmental  inspections, 

(131)  European  Environment  Agency,  LRTAP,  Air  pollutant  emissions 
data viewer (Gothenburg Protocol, LRTAP Convention) 1990-2022, 

https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/air-pollutant-emissions-data-viewer-1990-2022. 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
 
 
requiring a site visit to take place at least every 1–3 years, 
using  risk-based  criteria.  In  addition,  IED  enforcement 
provisions require Member States to determine effective, 
proportionate,  and  dissuasive  penalties  applicable  to 
infringements  of  IED-based  national  provisions.  In  the 
revised  directive, 
that  worst 
the  provisions 
infringements can be sanctioned by fines of at least 3% of 
the  annual  EU  turnover  of  the  legal  person.  The  revised 
IED  also  introduces  a  right  to  compensation  for  people 
whose health has been harmed by such infringements. 

set 

The development of best available techniques (BATs), BAT 
reference  documents  and  BAT  conclusions  ensures 
effective collaboration between stakeholders and enables 
better implementation of the IED. 

Since  the  2022  EIR,  the  Commission  has  adopted  BAT 
conclusions on (i) ferrous metal processing, (ii) the textiles 
industry,  (iii)  common  waste  gas  management  and 
treatment  systems 
in  the  chemical  sector  and  (iv) 
smitheries and foundries. 

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. This should result in considerable 
and continuous reductions in pollution. 

In  the  2019  EIR,  Denmark  received  priority  actions  to 
review  permits  to  comply  with  the  newly  adopted  BAT 
conclusions  and  to  step  up  checks  and  enforcement  to 
ensure compliance with BAT conclusions. The information 
available did not allow for progress measurement in 2022 
or 2024. Therefore, the priority action is repeated in the 
2025 EIR. 

2025 priority actions 

•  Engage  with  industry  and  environmental  NGOs  to 
ensure proper contribution to and implementation of 
BAT conclusions and ensure timely update of permits 
following publication of BAT conclusions. 

•  Ensure  effective  public  participation  and  access  to 

justice in relation with 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 

(ii) 

substances, especially chemicals; 
limit the consequences of  such accidents for human 
health and the environment; 

Denmark  27 

(iii)  continuously 

improve 

the 

prevention 

of, 

preparedness for and response to major accidents. 

The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive) (132). 

The overview below of industrial plants regulated by the 
Seveso III Directive (‘Seveso establishments’) is based on 
data  reported  on  eSPIRS  (e-Seveso  Plants  Information 
Retrieval  System)  for  2022–2024 (133)  and  the  report  by 
Denmark  on  the 
implementation  of  the  Seveso III 
Directive for 2019–2022 (134). 

In Denmark, of the 131 Seveso establishments in 2024, 64 
were categorised as lower-tier establishments and 67 as 
upper-tier establishments (UTEs), based on the quantity of 
hazardous  substances  likely  to  be  present.  UTEs  are 
subject  to  more  stringent  requirements.  Changes  in  the 
number of Seveso establishments in Denmark are shown 
in Figure 21. 

Figure 21: Number of Seveso establishments in Denmark, 
2018, 2022 and 2024 

150

100

50

0

61

61

55

65

64

67

2018

2022

2024

UTE

LTE

NB: LTE, lower-tier establishment. 

of 

the 

Union, 

European 

Sources: Directorate-General for Environment, Assessment and summary 
of  Member  States’  implementation  reports  for  Implementing  Decision 
2014/896/EU  (implementing  Directive  2012/18/EU  on  the  control  of 
major  accident  hazards  involving  dangerous  substances),  Publications 
Office 
2022, 
https://op.europa.eu/en/publication-detail/-/publication/94d57d74-
735b-11ec-9136-01aa75ed71a1/language-en/format-PDF/source-
search;  eSPIRS  data,  extractions  from  2022  and  2024;  Analysis  and 
summary  of  Member  States'  reports  on  implementation  of  Directive 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances  according  to  the 
format  established  by 
Commission Implementing Decision 2014/896/EU - Publications Office of 
https://op.europa.eu/en/publication-detail/-
the 
/publication/9bd73087-e9b8-11ef-b5e9-01aa75ed71a1/language-en. 

Luxembourg, 

EU, 

Member  States  are  required  to  draw  up  external 
emergency plans (EEPs). These EEPs are essential to allow 
proper  preparation  and  effective  implementation  of  the 

(132)  Directive  2012/18/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  the  control  of  major-accident  hazards 
involving  dangerous  substances,  amending  and  subsequently 
repealing  Council  Directive  96/82/EC  (OJ  L 197,  24.7.2012,  p. 1), 
https://eur-lex.europa.eu/eli/dir/2012/18/oj. 

(133)  https://espirs.jrc.ec.europa.eu/en/espirs/content; data extracted 

in September 2024. 

(134)  As provided for by Article 21(2) of the Seveso III Directive. 

2025 Environmental Implementation Review – Denmark 

 
 
 
necessary  actions  to  protect  the  environment  and  the 
population should a major industrial accident. 

According to Denmark, 65 UTEs had an EEP in 2022. Over 
the  last  three  years,  51  of  these  UTEs  have  been  tested 
(Figure 22). 

Figure 22: Situation regarding EEPs in Denmark, 2022 

65

65

65

51

70
60
50
40
30
20
10
0

UTE with EEP

Total of UTE

UTE for
which EEP
were
required

UTE for
which EEP
were tested
over the last
three years

of 

the 

Union, 

European 

Sources: Directorate-General for Environment, Assessment and summary 
of  Member  States’  implementation  reports  for  Implementing  Decision 
2014/896/EU  (implementing  Directive  2012/18/EU  on  the  control  of 
major  accident  hazards  involving  dangerous  substances),  Publications 
Office 
2022, 
https://op.europa.eu/en/publication-detail/-/publication/94d57d74-
735b-11ec-9136-01aa75ed71a1/language-en/format-PDF/source-
search;  eSPIRS  data,  extractions  from  2022  and  2024;  Analysis  and 
summary  of  Member  States'  reports  on  implementation  of  Directive 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances  according  to  the 
format  established  by 
Commission Implementing Decision 2014/896/EU - Publications Office of 
the 
https://op.europa.eu/en/publication-detail/-
/publication/9bd73087-e9b8-11ef-b5e9-01aa75ed71a1/language-en. 

Luxembourg, 

EU, 

The information  for the public referred to in  Annex V to 
the Seveso III Directive – especially about how the public 
concerned  will  be  warned  if  there  is  a  major  accident, 
appropriate  behaviour  in  the  event  of  a  major  accident 
and the date of the last site visit – is permanently available 
for 98 % of Seveso establishments in Denmark (135). This is 
an important provision of the Seveso III Directive, as this 
public  knowledge  could  reduce  the  consequences  of  a 
major industrial accident. 

The  shares  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public in 2022 in the EU-27 are presented 
in Figure 23. This provision on knowledge is an important 
provision of the Seveso III Directive, as awareness by the 
public  of 
the 
consequences of a major industrial accident. 

information  may  ameliorate 

this 

Denmark  28 

Figure 23: Share of UTEs for which information on safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public per Member State (%), 2022 

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

T
A

E
B

G
B

Y
C

Z
C

E
D

K
D

E
E

L
E

S
E

I
F

R
F

R
H

E
U I
H

T
I

T
L

U
L

V
L

T
M

L
N

L
P

T
P

O
R

I

E S
S

K
S

NB: No data available for Greece. 

of 

the 

Union, 

European 

Luxembourg, 

Sources: Directorate-General for Environment, Assessment and summary 
of  Member  States’  implementation  reports  for  Implementing  Decision 
2014/896/EU  (implementing  Directive  2012/18/EU  on  the  control  of 
major  accident  hazards  involving  dangerous  substances),  Publications 
Office 
2022, 
https://op.europa.eu/en/publication-detail/-/publication/94d57d74-
735b-11ec-9136-01aa75ed71a1/language-en/format-PDF/source-
search;  eSPIRS  data,  extractions  from  2022  and  2024;  Analysis  and 
summary  of  Member  States'  reports  on  implementation  of  Directive 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
format  established  by 
dangerous  substances  according  to  the 
Commission Implementing Decision 2014/896/EU - Publications Office of 
the 
https://op.europa.eu/en/publication-detail/-
/publication/9bd73087-e9b8-11ef-b5e9-01aa75ed71a1/language-en. 
No data available for Greece. 

EU, 

In 2022, Denmark received a priority action to strengthen 
control and enforcement  to  ensure compliance with  the 
Seveso III Directive rules, especially those on the provision 
of information to the public and on EEPs. Data reported on 
the implementation of the directive for 2019–2022 show 
substantial  progress  in  the  numbers  of  EEPs  established 
for UTEs in Denmark. 

2025 priority actions 

•  Strengthen  compliance  with  requirements  on  safety 
measures  to  prevent  major  accidents  and  ensure 
appropriate preparedness and response in relation to 
UTEs,  in  particular  as  regards  reviewing,  testing  and 
updating  EEPs,  at  intervals  of  no  more  than  three 
years. 

•  Ensure  access  to  transparent  and  clear  information 
towards  citizens  on  risks  and  behaviour  in  case  of 
accidents. 

(135)  https://www.brs.dk/en/what-you-can-do/in-case-of-an-

emergency/public-warnings-in-case-of-emergencies/.  

2025 Environmental Implementation Review – Denmark 

 
 
 
 
Mercury Regulation 

The  Mercury  Regulation  establishes  measures  and 
conditions concerning the use and storage of and trade in 
mercury,  mercury  compounds  and  mixtures  of  mercury, 
the manufacture and use of and trade in mercury-added 
products and the management of mercury waste, in order 
to ensure a high level of protection of human health and 
the  environment  from  anthropogenic  emissions  and 
releases of mercury and mercury compounds. The revision 
of the Mercury Regulation adopted in 2024 sets out rules 
to address the last intentional uses of mercury in the EU 
by  phasing  out  the  use  of  dental  amalgam  by  1 January 
2025 except when deemed strictly necessary by the dental 
practitioner  based  on  the  specific  medical  needs  of  the 
patient,  and  prohibiting  the  manufacture  and  export  of 
additional mercury-containing lamps from 1 January 2026 
or 1 January 2027 (depending on the lamp category). 

Measures  should  have  been  put  in  place  in  Denmark  to 
ensure  a  socially  and  economically  sound  phase-out, 
including an adequate reimbursement of the alternatives 
to dental amalgam through the health insurance scheme 
and the training of dental practitioners.  The Commission 
is  monitoring  whether  the  phase-out  has  taken  place 
under  the  terms  and  conditions  of  the  regulation. 
Denmark  will  also  need  to  ensure  that  the  manufacture 
and export of mercury-containing lamps are prohibited by 
the deadlines set out in the Mercury Regulation. 

In Denmark, responsibility for checking compliance with 
the  Mercury  Regulation 
the  Danish 
Environmental Protection Agency except  when it comes 
to article 10 paragraph 4 and 6 and article 11. In the latter 
cases,  the  responsibility  lies  with  the  Municipalities  in 
Denmark (136). 

lies  with 

for 

the  Commission 

The revision of the Mercury Regulation adopted in 2024 
the 
provides 
implementation and impact of a guidance on abatement 
technologies  for  emissions  of  mercury  and  mercury 
compounds  from  crematoria.  Denmark  has  already 

report  on 

to 

(136)  Bekendtgørelse  om  udførelse  af  opgaver  i  henhold  til  Europa-
Parlamentets og Rådets forordning (EU) nr. 2017/852 om kviksølv, 
BEK 
09/04/2022, 
https://www.retsinformation.dk/eli/lta/2022/456. 

456 

nr 

af 

(137)  Bekendtgørelse 
listevirksomhed, 
https://www.retsinformation.dk/eli/lta/2021/2079. 

standardvilkår 

2079 

BEK 

om 

nr 

i 

godkendelse 
af 

af 
15/11/2021, 

(138)  Directive  2002/49/EC  of  the  European  Parliament  and  of  the 
Council  of  25 June  2002  relating  to  the  assessment  and 
management  of  environmental  noise –  Declaration  by  the 
Commission  in  the  Conciliation  Committee  on  the  directive 
relating  to  the  assessment  and  management  of  environmental 
noise (OJ L 189, 18.7.2002, p. 12), https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32002L0049. 

(139)  WHO,  Environmental  Noise  Guidelines  for  the  European  Region, 
Copenhagen, 
2018, 
https://www.who.int/europe/publications/i/item/978928905356
3. 

Denmark  29 

implemented standard conditions for crematoria: Filters 
for  retaining  dust  and  mercury  are  required  in  all 
crematoria. Furthermore, an emission limit for mercury of 
0.1 mg/normal m3 applies. (137) 

the 

from 

In 2024, Denmark initiated a procedure for the removal of 
mercury  compounds 
list  of  permitted 
preservatives  in  entries  16  and  17  in  Annex  V  of  the 
Cosmetic  Products  Regulation  with  the  ultimate  view  of 
enabling  the  EU  and  its  Member  States  to  propose  a 
removal of the exemption for the use of mercury in eye 
area cosmetics under the Minamata Convention. 

Noise 

The  Environmental  Noise  Directive (138)  requires  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  noise.  The  designated  authorities  are 
responsible  for  making  and  approving  noise  maps  and 
action  plans  for  agglomerations,  major  roads,  major 
railways  and  major  airports.  Member  States  decide  on 
noise limits that are not set at the EU level. Nevertheless, 
the zero pollution action plan sets as a 2030 target a 30 % 
reduction  compared  with  2017  in  the  share  of  people 
chronically disturbed by transport noise. 

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental health‐related issues in 
the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress (139). 

In Denmark, environmental noise is estimated to cause at 
least  around  100  cases  of 
ischaemic  heart  disease 
annually (140)  and  some  32 700  people  to  suffer  from 
disturbed sleep (141). 

Based on the latest set of information analysed, Denmark 
has  completed  its  noise  mapping  of  agglomerations, 
roads, railways and airports. 

Action  plans  for  noise  management  for  agglomerations, 
roads,  railways  and  airports  must  be  updated  and 
submitted  to  the  Commission  every  five  years.  The 

(140)  These figures are an estimation by the EEA based on (i) the data 
reported  by  Member  States  on  noise  exposure  covered  by 
Directive 2002/49/EC for the round of noise mapping of 2022; (ii) 
European  Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Industrial  Pollution  (ETC/ATNI),  Noise 
Indicators  under  the 
Environmental Noise Directive 2021: Methodology for estimating 
missing  data,  Eionet  report  ETC/ATNI  No 2021/06,  Kjeller,  2021; 
and  (iii)  the  methodology  for  health  impact  calculations  in 
European  Topic  Centre  on  Air  Pollution  and  Climate  Change 
Mitigation  (ETC/ACM),  Implications  of  environmental  noise  on 
in  Europe,  Eionet  report  ETC/ACM 
health  and  wellbeing 
No 2018/10, 
2018, 
https://www.eionet.europa.eu/etcs/etc-atni/products/etc-atni-
reports/eionet_rep_etcacm_2018_10_healthimplicationsnoise.  

Bilthoven, 

(141)  More information on the adverse health effects of noise pollution 

is available at: 
https://www.eea.europa.eu/themes/human/noise/noise-2 

2025 Environmental Implementation Review – Denmark 

 
 
  
deadline for reporting noise action plans under the most 
recent  reporting  cycle  was  18 January  2025;  these  plans 
have not been assessed yet. 

2025 priority action 

•  Complete  and 
management. 

implement  action  plans  on  noise 

Water quality and management 

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

Water Framework Directive 

Directive 
form 

The Water Framework Directive (142) is the cornerstone of 
EU  water  policy  in  the  21st  century (143).  The  Water 
Framework 
other  water-related 
and 
directives (144) 
the  basis  of  sustainable  and 
integrated  water  management  in  the  EU.  They  aim  to 
achieve  a  high  level  of  protection  of  water  resources, 
prevention  of  further  deterioration  and  restoration  to 
good status. These objectives are very important for the 
EU’s  competitiveness,  strategic  autonomy  and  security, 
yet  have  become  even  more  challenging  in  the  face  of 
climate change affecting our precious water resources. 

The Water Framework Directive establishes a procedural 
framework for reaching good surface water ecological and 
chemical  status  and  good  groundwater  quantitative  and 
chemical status. This implies monitoring and classification 
of all waterbodies, assessment  of pressures and impacts 
and identification of the most cost-effective measures to 
achieve the objectives of the directive. The directive dates 
from 2000 and set an initial deadline of 2015 for achieving 
its objectives, with the option to extend the deadline to 
the  end  of  2027.  Every  six  years,  Member  States  must 

(142)  https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=CELEX:32000L0060. 

(143)  https://environment.ec.europa.eu/topics/water_en. 
(144)  These 

include 

the  Groundwater  Directive 

(https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32006L0118), 
the  Environmental  Quality  Standards  Directive  (https://eur-
lex.europa.eu/eli/dir/2008/105/oj), 
Directive 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32007L0060), the Bathing Water 
(https://eur-lex.europa.eu/legal-
Directive 
content/EN/TXT/?uri=celex%3A32006L0007), 
Urban 
Wastewater 
(https://eur-
Directive 
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31991L0271), 

Treatment 

Floods 

the 

the 

Denmark  30 

report their river basin management plans (RBMPs) to the 
Commission. They should cover river basin districts in their 
countries,  some  of  which  may  be  shared  with  other 
countries. The Commission has assessed the third cycle of 
RBMPs, which were to be submitted by March 2022, and 
reported  its  findings  to  the  European  Parliament  and  to 
the Council on 4th February 2025 (145). 

Denmark’s four river basin districts include 7 812 surface 
waterbodies and 2 050 groundwater bodies. 5.64 % of the 
rivers  are  heavily  modified  and  3.21 %  are  artificial 
waterbodies.  Furthermore,  3.67 %  of  coastal  waters  are 
heavily  modified.  Heavily  modified  water  and  artificial 
waterbodies must reach good ecological potential rather 
than  good  ecological  status,  which  means  that  all 
measures must be taken to mitigate the adverse impact of 
the sustainable human development activities causing the 
waterbody  to  be  heavily  modified /  artificial,  while  not 
significantly affecting these activities. 

in 

the 

show 

change 

Figures 24–27 
ecological 
status/potential  and  chemical  status  of  surface  waters, 
and the quantitative and chemical status of groundwater 
in 2010, 2015 and 2021. It follows from the assessment of 
the third RBMPs that 29.9 %  of the surface waterbodies 
have good ecological status/potential, while 57.8 % have 
a  lower  status  and  12.3  %  have  unknown  status.  The 
changes  in  number  of  quality  elements,  among  other 
things, complicate comparison of the 2nd and 3rd RBMPs. 
For  chemical status, the situation is far worse, with only 
1.7 %  having  good  chemical  status,  5.6 %  classified  as 
failing to achieve good status and 92.7 % having unknown 
chemical status, despite it being more than 20 years since 
the entry into force of the directive. 

Directive 

(https://eur-

the 

Nitrates 
(https://eur-lex.europa.eu/legal-
MSFD 

the 

Drinking  Water 

the 
new 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32020L2184), 
Directive 
content/EN/ALL/?uri=celex%3A31991L0676), 
(https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32008L0056) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075). 

and 

the 

IED 

(145)  European 

Commission, 

2025  

https://webgate.ec.europa.eu/circabc-ewpp/ui/group/c04f478b-
d4dc-44f9-a211-087c01165b2c/library/faada4be-9fc3-4a48-
b972-f71e356019d5?p=1&n=10&sort=modified_DESC.  

2025 Environmental Implementation Review – Denmark 

 
 
Figure 24:  Ecological 
waterbodies in each RBMP cycle (%) 

status/potential  of 

surface 

Denmark  31 

while it was nearly absent in the second RBMP cycle. The 
number  of  waterbodies  affected  by  cadmium,  lead  and 
nonylphenol has also increased markedly. 

Figure 26: Quantitative status of groundwater bodies in 
each RBMP cycle (%) 

In general, eutrophication caused by nutrients is the main 
cause  of  the  persistent  failure  to  improve  ecological 
quality in a timely manner: this concerns phosphorus for 
lakes and nitrates for coastal waters. The main pressure is 
agriculture’s use of manure and fertilisers, while there are 
also significant contributions from wastewater plants and 
aquaculture. The agreement on a Green Denmark of 2024 
envisages  reducing  nitrogen  pollution  by  13  780  tonnes 
annually and removing 140 000 ha of carbon-rich low-lying 
land  from  agricultural  use  (see  ‘Nitrates  Directive’  in 
Chapter 3) (146). 

Figure 25: Chemical status of surface waterbodies in each 
RBMP cycle (%) 

As  in  the  second  RMBPs,  almost  all  groundwater  bodies 
are  of  good  quantitative  status  (99.6 %).  Most  drinking 
water  comes  from  groundwater  reservoirs  (1 705  out  of 
2 050), with only minimal treatment requirements. Only 9 
out of 2 050 groundwater bodies (0.4 %) were found to be 
of  poor  quantitative  status  in  2021,  which  was  due  to 
overabstraction.  This  suggests  an  emerging  scarcity 
problem, partly because 4 % of groundwater bodies were 
identified  as  being  at  risk  of  failing  to  achieve  good 
quantitative status by 2027. 

Figure 27: Chemical status of groundwater bodies in each 
RBMP cycle (%) 

The chemical status assessment includes only 25 priority 
substances  out  of  the  53  listed  in  the  Environmental 
Quality  Standards  Directive.  It  is  not  explained  why  the 
chemical  status  assessment  does  not  cover  all  priority 
substances to which the legislation applies. 

Data  from  the  small  sample  of  classified  surface 
waterbodies suggest a worsening level of water pollution, 
the  actual  size  of  which  remains  unclear.  For  about  one 
out  of  every  two  surface  waterbodies  with  poor  status, 
mercury  pollution  can  count  as  the  reason.  Anthracene 
pollution  is  a  problem  in  almost  as  many  waterbodies, 

A  large  majority  of  groundwater  bodies  have  good 
chemical status (88.8 %). Chemical status is poor in 9.4 % 
and unknown in 1.9 % groundwater bodies. Pesticides are 
the main cause of the failure to attain good status in 7 % 
of all groundwater bodies. This is to a large extent a legacy 
effect,  as  most  of  the  pesticides  concerned  have  been 

(146)  Ministry  of  Environment  and  Equality, 

‘Skov’,  accessed 
11 November  2024,  https://mim.dk/vores-opgaver/natur-og-
biodiversitet/skov; see also the NBSAP adopted in October 2024 
(https://s3.amazonaws.com/km.documents.attachments/472c/7
70f/a889e94e81b54a6ad8d9cf0f?AWSAccessKeyId=AKIAT3JJQDE

DLXMBJAHR&Expires=1737367455&response-content-
disposition=inline%3B%20filename%3D%22WEB_ENGLISH_Natio
nal_handlingsplan_for_biodiv_2024.pdf%22&response-content-
type=application%2Fpdf&Signature=XWavr%2BrnXpVJ9TmqofDu
hA%2FzoJ8%3D). 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
 
 
banned  already.  Nitrates  and  trace  particles  are  less 
prevalent causes. (147) 

Until the end of 2027, Member States can still apply time-
related  exemptions,  subject  to  providing  evidence  of 
compliance  with  the  strict  criteria  set  out  in  the  Water 
Framework  Directive.  After  2027,  the  possibilities  for 
applying exemptions will be much more limited. 

improve 

In  respect  of  the  previous  priority  actions  to  improve 
monitoring of surface waters and the assessment methods 
for biological quality elements, Denmark has made some 
efforts  to 
in  the 
classification  of  surface  waters.  Still,  a  number  of 
monitoring deficiencies and a number of waterbodies with 
‘unknown’  status  remain,  hindering  the  possibility  for 
Danish  surface  waters  to  achieve  compliance  with  the 
Water Framework Directive objectives. 

its  monitoring  and  gaps 

The third RBMPs mainly focus on measures to reduce the 
nitrogen loads that have led to widespread eutrophication 
and  oxygen  depletion 
in  coastal  waters,  with  the 
assumption  that  75 %  of  the  estimated  load  reductions 
planned  in  the  second  RBMP  period  are  expected  to  be 
implemented  and  additional  measures  are  to  be 
introduced to cover around 80 % of the nitrogen reduction 
need.  The  third  RBMPs  also  clearly  describe  additional 
measures to further improve wastewater treatment  and 
reduce polluting discharges to rivers and lakes, on top of 
the measures from the second RBMPs that have not yet 
been  fully  implemented.  The  third  RBMPs  furthermore 
identify the need for watercourse restoration in 5 500 km 
of rivers, but with implementation limited to 3 850 km of 
rivers, while indicating the need for an update of the third 
RBMPs in 2024 to close the remaining gap. 

2025 priority actions 

Without prejudice to the list of recommended actions in 
the Commission report to the European Parliament and to 
the  Council  on  the  assessment  of  the  third  RBMPs,  the 
following priority actions can be highlighted. 

• 

Improve river continuity and ecological flows, boosting 
reduce 
efforts  on  nature-based 
hydromorphological pressures. 

solutions 

to 

•  Reduce  pollution  from  nutrients,  chemicals,  metals 

and saline discharges. 

•  Better justify exemptions to the achievement of good 

• 

status. 
Improve  the  classification  of  water  bodies  and 
strengthen monitoring systems.  

Denmark  32 

identified 

•  Develop more robust programmes of measures, tackle 
implementation  of 
in 
obstacles 
measures  and  ensure  adequate 
for 
financing 
implementation,  including  through  better  use  of  the 
cost recovery and polluter pays principle. 

the 

Floods Directive 

Every six years, following the same reporting cycle as the 
RBMPs,  all  Member  States  also  report  their  flood  risk 
management  plans  (FRMPs),  based  on  the  flood  hazard 
and risk maps and the preliminary flood risk assessments 
drawn up during the second cycle (2016–2021). 

The  Commission  also  assessed  the  FRMPs (148),  and 
reported  its  findings  to  the  European  Parliament  and  to 
the  Council  on  4th  February  2025,  together  with  the 
assessment of the RBMPs. 

The  four  Danish  FRMPs  for  the  second  FRMP  cycle 
constitute improvements over the first-generation FRMPs 
in  that  they  explicitly  address  the  reduction  of  adverse 
consequences and more generally the risk of flooding. The 
second  FRMPs  also  provide  details  on  the  process  to 
monitor  the  progress  of  measures  and  are  better 
coordinated  with  the  RBMPs.  There  also  appears  to  be 
greater attention paid to nature-based solutions. 

2025 priority actions 

•  FRMPs should provide details on how the FHRMs were 
used  in  the  choice  of  measures  and  how  to  consider 
pluvial flooding. 

•  Better explain the choice and implementation of flood 
prevention  and  protection  measures  (prioritisation, 
monitoring, costs of measures). 

Drinking Water Directive 

The objectives of the Drinking Water Directive (149) are to 
protect human health by ensuring the quality intended for 
human  consumption  and  to  improve  access  to  drinking 
water.  The  recast  Drinking  Water  Directive 
is  now 
applicable,  and  Member  States  were  required  to 
transpose  its  provisions  into their  national  legal systems 
by 12 January 2023. Since the entry into force of the recast 
directive, the Commission has adopted several delegated 
and  implementing  acts  establishing  (i)  a  watch  list  of 
substances  and  compounds  of  concern  for  drinking 

(147)  The number of groundwater bodies included to the 3rd RBMPs was 
significantly higher than in the 2nd RBMPs. Therefore, the share of 
groundwater bodies in good chemical status in the 3rd RBMPs can’t 
in  the  2nd  RBMPs.  European 
be  compared  to  the  share 
  https://webgate.ec.europa.eu/circabc-
Commission,  2025 
ewpp/ui/group/c04f478b-d4dc-44f9-a211-
087c01165b2c/library/faada4be-9fc3-4a48-b972-
f71e356019d5?p=1&n=10&sort=modified_DESC. 

(148)  European 

Commission, 

2025  

https://webgate.ec.europa.eu/circabc-ewpp/ui/group/c04f478b-
d4dc-44f9-a211-087c01165b2c/library/faada4be-9fc3-4a48-
b972-f71e356019d5?p=1&n=10&sort=modified_DESC. 

(149)  Directive (EU) 2020/2184 of the European Parliament and of the 
Council of 16 December 2020 on the quality of water intended for 
human  consumption  (OJ  L 435,  23.12.2020,  p. 1),  https://eur-
lex.europa.eu/eli/dir/2020/2184/oj. 

2025 Environmental Implementation Review – Denmark 

 
 
water (150), (ii) a methodology for measuring microplastics 
in drinking water (151) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (152). Member States will have to take 
into  account  when 
these  various  Commission  acts 
implementing the recast directive. 

The recast Drinking Water Directive also introduces a risk-
based approach to water safety. It covers the entire supply 
chain,  from  the  river  basin  to  extraction,  treatment, 
storage  and  distribution.  These  assessments  must  be 
reviewed  periodically,  in  particular  to  address  threats 
posed by extreme weather phenomena linked to climate 
change,  known  variations  in  human  activities  in  the 
extraction area or accidents affecting the source. 

Denmark has not yet communicated to the Commission all 
its national measures transposing the recast directive. An 
infringement  procedure  for  the  non-communication  of 
the Danish transposition measures is ongoing (153). 

The  Commission  has  now  received  data  from  Member 
States on the quality of drinking water in 2017–2019. 

The  quality  of  drinking  water  (supplied  by  large  water 
suppliers) in Denmark does not give rise to concern (154). 
From  January  2026,  the  European  quality  standards  for 
PFAS  in  drinking  water  will  apply,  ensuring  harmonised 
Member States’ reporting of PFAS monitoring data in the 
future. 

2025 priority action 

•  Take  actions  to  ensure  full  compliance  with  the 

Drinking Water Directive. 

Bathing Water Directive 

The  Bathing  Water  Directive  requires  Member  States  to 
monitor and assess bathing water. It requires that, during 
the  bathing  season,  Member  States  disseminate  to  the 
public information on bathing water quality actively and 
promptly. In particular, notices banning or advising against 
bathing should be rapidly and easily identifiable. 

(150)  https://environment.ec.europa.eu/publications/implementing-

decision-drinking-water-directive-watch-list_en. 

(151)  Commission Delegated Decision (EU) 2024/1441 of 11 March 2024 
supplementing  Directive  (EU)  2020/2184  of  the  European 
Parliament and of the Council by laying down a methodology to 
measure microplastics in water intended for human consumption 
(notified  under  document  C(2024) 1459)  (OJ  L,  2024/1441, 
21.5.2024), http://data.europa.eu/eli/dec_del/2024/1441/oj. 
2024/365, 

(152)  OJ L, 

23.4.2024, 
http://data.europa.eu/eli/dec_impl/2024/365/oj; OJ L, 2024/367, 
http://data.europa.eu/eli/dec_impl/2024/367/oj; 
23.4.2024, 
OJ L, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/369/oj;  OJ L,  2024/368, 
23.4.2024, http://data.europa.eu/eli/dec_impl/2024/368/oj; OJ L, 
2024/370, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/370/oj;  OJ L,  2024/371, 
23.4.2024,  http://data.europa.eu/eli/reg_del/2024/371/oj;  see 

2024/369, 

Denmark  33 

Figure 28  shows  that  in  2023,  out  of  the  1 044  Danish 
bathing  waters,  981  (94 %)  were  of  excellent  quality,  45 
bathing waters (4.3 %) were of good quality and 2 bathing 
waters (0.2 %) were of sufficient quality; 5 bathing waters 
(0.5 %) were of poor quality (155). 

Figure 28: Bathing water quality per Member State, 
Albania and Switzerland (%), 2020 

Source:  EEA,  European  Bathing  Water  Quality 
No 04/2024, 
https://www.eea.europa.eu/publications/european-bathing-water-
quality-in-2023/. 

in  2023,  briefing 
2024, 

Copenhagen, 

Nitrates Directive 

The  Nitrates  Directive (156)  aims  to  protect  water  quality 
across  Europe  by  preventing  nitrates  from  agricultural 
sources that can pollute groundwater and surface waters 
and by promoting the use of good farming practices. 

The  latest  Commission  report  on  the  implementation  of 
the Nitrates Directive (157), dating back to 2021, warns that 
nitrates are still causing harmful pollution to water in the 
EU. Excessive nitrates in water are harmful to both human 
health  and  ecosystems,  causing  oxygen  depletion  and 
eutrophication. Cleaning of waters by national authorities 
or  farmers,  where  it  has  been  undertaken,  has  had  a 
positive  impact  on  the  drinking  water  supply  and  on 
biodiversity.  It  has  also  benefited  the  sectors –  such  as 
fisheries and tourism – that depend on biodiversity and on 

the  Commission  web  page  on  all  six  delegated  acts  for  more 
information 
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en). 
INFR(2023)0060 
(https://ec.europa.eu/commission/presscorner/detail/en/inf_23
_6211). 
In summary, the compliance for all parameter groups in Denmark 
was at least 98.33 % in 2017, 98.65 % in 2018 and 98.56 % in 2019. 
In total, 11 bathing waters (1.1 %) were not classified. 

(153) 

(154) 

(155) 
(156)  https://eur-lex.europa.eu/legal-

content/EN/TXT/?qid=1561542776070&uri=CELEX:01991L0676-
20081211. 

(157)  https://environment.ec.europa.eu/topics/water/nitrates_en. The 
report  on the  implementation of  the  Nitrates Directive  covering 
2020–2023 will be available in 2025. 

2025 Environmental Implementation Review – Denmark 

 
 
 
a good supply of drinking water. Nevertheless, excessive 
fertilisation remains a problem in many parts of the EU.  

and/or phosphorus (i.e. eutrophic or tending to become 
eutrophic). 

Denmark  34 

As  mentioned  earlier,  the  analysis  of  the  RBMPs  of 
Denmark  has  identified  nutrients  from  agriculture  as  an 
important  pressure  on  surface  waters  that  is  affecting 
their  good  status  and  as  one  of  the  main  factors  in  not 
meeting the Water Framework Directive objectives. 

Furthermore,  in  2023,  Denmark  recorded  the  worst 
oxygen  depletion  in  21 years,  affecting  large  areas  of 
Danish coastal and marine waters. In 2024, the situation 
deteriorated by almost 50 % (158). 

Denmark’s broad political agreement on a Green Denmark 
of  2024  includes  reforms  to  address  pollution  from 
agriculture, in particular nitrates. The agreement contains, 
among  other  things,  (i)  introduction  of  a  CO2eq  tax  on 
transformation  of  around 
livestock  emissions  and 
400 000 hectares  of  agricultural 
into  nature, 
including carbon-rich low-lying areas and forests; and (ii) a 
reduction  of  nitrogen  pollution  by  13  780  tonnes 
annually (159).  

land 

In all previous EIRs, Denmark received a priority action on 
tackling  nutrient  pollution,  especially  nitrates  from 
agriculture,  through  the  implementation  of  the  Nitrates 
Directive. Since the report on the implementation of the 
Nitrates  Directive  covering  2020–2023  will  become 
available in 2025, the 2022 EIR priority action cannot be 
assessed and is repeated. 

2025 priority action 

•  Tackle  nutrients  pollution,  especially  nitrates  from 
agriculture through the implementation of the Nitrates 
Directive. 

Urban Wastewater Treatment Directive 

The  Urban  Wastewater  Treatment  Directive  (UWWTD) 
aims to protect human health and the environment from 
the effects of untreated urban waste water. It therefore 
requires Member States to collect and treat (secondary or 
biological  treatment)  waste  water  in  all  urban  areas  of 
more  than  2 000  people,  and  to  apply  a  more  stringent 
treatment 
than  secondary,  with  nitrogen  and/or 
phosphorus  removal,  to  the  waste  water  generated  in 
urban areas, also known as agglomerations, of more than 
10 000 people, before they are discharged into waters and 
their  catchments,  when  they  are  sensitive  to  nitrogen 

(158)  Danish  Centre  for  Environment  and  Energy,  ‘Iltsvind  i  danske 
farvande  24.  August –  21.  September  2023’,  note  No 2023/44, 
29 September 
Roskilde, 
https://dce.au.dk/fileadmin/dce.au.dk/Udgivelser/Notater_2023
/N2023_44.pdf;  Danish  Centre  for  Environment  and  Energy, 
‘Iltsvind i danske farvande 29. August – 25. September 2024’, note 
Roskilde, 
No 2024/53, 

4 October 

2024, 

2023, 

Overall,  in  Denmark,  the  compliance  rate  was  99.7 %  in 
2020.  Only  three  agglomerations,  generating  30 731 
population  equivalent  of  urban  waste  water,  did  not 
comply with the requirements of the directive. 

Figure 29: Proportion of urban waste water that fully 
complies with the UWWTD (%), 2020 

Source:  European  Commission:  Directorate-General  for  Environment, 
Fribourg-Blanc,  B.,  Dhuygelaere,  N.,  Berland,  J.  and  Imbert,  F.,  12th 
technical  assessment  of  UWWTD  implementation  –  Final  version, 
2024, 
the 
Publications 
https://data.europa.eu/doi/10.2779/318637. 

European 

Union, 

Office 

of 

The  directive  has  been  revised (160)  in  order  to,  among 
other things, strengthen existing treatment standards and 
establish  an  additional  treatment  of  micropollutants  in 
urban  waste  water.  Other  new  requirements  relate  to 
moving  towards  the  energy  neutrality  of  the  sector, 
establishing an EPR system to ensure sustainable financing 
of  micropollutant  treatment  by  the  most  polluting 
industries and ensuring access to sanitation, especially for 
vulnerable  and  marginalised  groups.  Denmark  has  until 
31 July  2027  to  transpose  the  new  directive  into  its 
national legal system. 

In  2025,  Denmark  will  draw  up  a  plan  for  the 
implementation  of  the  directive  -  and  start  discussions 
with the industry regarding the particular implementation 
of Article 9 on extended producer responsibility. 

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 

https://dce.au.dk/fileadmin/dce.au.dk/Udgivelser/Notater_2024
/N2024_53.pdf. 

(159)  Ministry for Green Transition of Denmark, Bred politisk aftale om 

Den Grønne Trepart indgået, (https://mgtp.dk/aftaler/). 

(160)  Directive (EU) 2024/3019 of the European Parliament and of the 
Council  of  27 November  2024  concerning  urban  wastewater 
treatment 
12.12.2024), 
http://data.europa.eu/eli/dir/2024/3019/oj. 

2024/3019, 

(OJ 

L, 

2025 Environmental Implementation Review – Denmark 

 
 
 
2020, the Commission published its chemicals strategy for 
sustainability  towards  a  toxic-free  environment (161), 
which  led  to  some  systemic  changes  in  EU  chemicals 
legislation. The strategy is part of the EU’s zero pollution 
ambition –  a  key  commitment  of  the  European  Green 
Deal. 

The  EU’s  chemicals  legislation (162)  provides  a  baseline 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating in the internal market. 

and 

enforcement 

Since 2007, the Commission has gathered information on 
the  Registration,  Evaluation, 
the  enforcement  of 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 
assessed  the  Member  States’  reports (163)  on  the 
implementation 
these 
regulations (164).  It  is  apparent  from  the  Commission’s 
report  that  there  are  still  many  disparities 
in  the 
implementation  of  the  REACH  and  CLP  Regulations, 
notably  in  the  area  of 
law  enforcement.  Recorded 
compliance levels in Member States, generally quite stable 
over time, appear to be getting slightly worse. This may be 
because  (i)  enforcement  authorities  are  becoming  more 
effective in detecting non-compliant products/companies 
and (ii) more non-compliant products are being placed on 
the EU market. 

of 

(161)  Communication 

to 

from 

the  Commission 

the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Chemicals 
strategy  for  sustainability:  Towards  a  toxic-free  environment, 
COM(2020) 667 
final  of  14 October  2020,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A667%3AFIN;  Regulation 
(EC) No 1272/2008 of the European Parliament and of the Council 
of 16 December 2008 on classification, labelling and packaging of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
p. 1), 
L 353, 
https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2. 

31.12.2008, 

(OJ 

(162)  Namely,  Regulation 

(EC)  No 1907/2006  of  the  European 
Parliament  and  of  the  Council  of  18 December  2006  concerning 
the  registration,  evaluation,  authorisation  and  restriction  of 
chemicals  (REACH),  establishing  a  European  Chemicals  Agency, 
amending Directive 1999/45/EC and repealing Council Regulation 
(EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as 
well as Council Directive 76/769/EEC and Commission Directives 
91/155/EEC,  93/67/EEC,  93/105/EC  and  2000/21/EC  (OJ  L 396, 
30/12/2006, 
https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32006R1907; and Regulation (EC) 
No 1272/2008 of the European Parliament and of the Council of 
16 December  2008  on  classification,  labelling  and  packaging  of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
L 353,  31.12.2008,  p. 1),  https://eur-
(OJ 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 
(163)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 

p. 1), 

Denmark  35 

In August 2021, the Commission published a measurable 
assessment  of the enforcement (165) of the two  main EU 
regulations  on  chemicals  using  a  set  of  indicators  on 
different  aspects  of  enforcement.  Since  2021,  the  list  of 
chemicals  subject  to  restrictions  has  been  expanded  as 
new entries have been added to Annex XVII to the REACH 
Regulation (166). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (167).  The  new  hazard 
classes cover endocrine disruptors for human health and 
the  environment  and  persistence,  bioaccumulation  and 
toxicity-related  hazards  while  the  revision  of  the 
regulation  encompasses  new  rules  on  online  sales  to 
better  tackle  non-compliances  observed  over  the  years. 
Also  in  2023,  the  Conference  of  the  Parties  of  the 
Stockholm  Convention  (COP)  decided  to  include,  in  its 
Annex A  (which  lists  banned  substances),  three  new 
chemicals (168).  The  Commission 
is  working  on  the 
delegated acts to include these substances in Annex I to 
the  Persistent  Organic  Pollutants  Regulation  by  2025  at 
the latest. 

In  Denmark,  responsibility  for  ensuring  compliance  with 
the REACH Regulation lies with the Danish Environmental 
Protection Agency (169). 

The  Member  States’  reporting  exercise  set  out 
in 
Article 117 of the REACH Regulation and Article 46 of the 

Union, 

REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
2020, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 
In 
Article 46(2) of the CLP Regulation. 

line  with  Article 117(1)  of  the  REACH  Regulation  and 

Luxembourg, 

(164) 

the 

European 

Luxembourg, 

(165)  European  Commission,  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  REACH  and  CLP 
Enforcement: EU-level enforcement indicators, Publications Office 
of 
2021, 
Union, 
https://op.europa.eu/en/publication-detail/-
/publication/e5c3e461-0f85-11ec-9151-01aa75ed71a1/. 
(166)  These are substances in tattoo inks and permanent make-up, N,N-
dimethylformamide, formaldehyde (and formaldehyde releasers), 
lead in PVC, siloxanes (D4, D5, D6) and, finally, microplastics. 
(167)  Regulation (EU) 2024/2865 of the European Parliament and of the 
Council  of  23  October  2024  amending  Regulation  (EC)  No 
1272/2008 on classification, labelling and packaging of substances 
and mixtures, OJ L, 2024/2865, 20.11.2024, p.1 (Regulation - EU - 
2024/2865 - EN - EUR-Lex) 

(168)  These are methoxychlor, dechlorane plus and UV-328. In the case 
of the pesticide methoxychlor, there are no exemptions from the 
ban. However, for the two plastic additives, dechlorane plus and 
lists  some  time-limited  specific 
UV-328,  the  COP  decision 
exemptions. 

(169)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
p. 68, 
European 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

2025 Environmental Implementation Review – Denmark 

 
 
Denmark  36 

Figure 31:  Number  of  REF-8  checks  performed  per 
100 000 inhabitants (EU average = 1.24) 

CLP Regulation is conducted every five years. The results 
of  the  coming  one  are  expected  in  2025,  hence  the 
absence  of  new  country-specific  data  on  enforcement 
since 2022. 

In  Denmark,  4.5 person  years  were  allocated  to  the 
enforcement  of  the  REACH  and  CLP  Regulations  in 
2022 (170). 

In  2020,  Denmark  participated  in  an  EU  coordinated 
enforcement  project  on  products  sold  online,  called  the 
REACH-EN-FORCE  (REF)-8  project (171).  The  report  was 
adopted in November 2021, so it could not be taken into 
account in the previous EIR. 

Figure 30: Compliance of imported products – results of 
the REF-8 project (%) 

Denmark’s  participation 
enforcement project was around the EU average. 

the  REF-8  coordinated 

in 

In  2022,  the  European  Commission  identified  a  priority 
action  related  to  upgrading  administrative  capacities  in 
implementation  and  enforcement  to  move  towards  a 
policy of zero tolerance of non-compliance. In the absence 
of  formal  reporting  since  2022,  no  progress  has  been 
shown and this priority action remains valid in 2025, partly 
because of the experience with the REF-8 project. 

2025 priority actions 

A  risk  approach  was  used  for  the  targeting  of  control 
measures in order to maximise the chances of finding non-
rates 
compliances.  Therefore, 
presented above cannot be considered the average non-
compliance  rates  of  products  in  the  EU.  However,  the 
proportion  of  non-compliance  cases  found  in  the  REF-8 
project are of concern. 

the  non-compliance 

(170)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
p. 74, 
European 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

•  Upgrade 

the 

capacities 

in 
administrative 
implementation and enforcement towards a policy of 
zero tolerance for non-compliance. 
Increase involvement in the activities of the Forum for 
Exchange  of  Information  on  Enforcement  of  the 
European  Chemicals  Agency, 
the 
in 
coordinated enforcement projects, called REFs. 
Increase  customs  controls  and  controls  of  products 
sold online with regard to compliance with chemicals 
legislations.

including 

• 

• 

(171)  European Chemicals Agency, REF-8 project report on enforcement 
of the CLP, REACH and BPR duties related to substances, mixtures 
and 
p. 20, 
https://echa.europa.eu/documents/10162/17088/project_report
_ref-8_en.pdf/ccf2c453-da0e-c185-908e-
3a0343b25802?t=1638885422475. 

Helsinki, 

articles 

online, 

2021, 

sold 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
Denmark  37 

4. Climate action 

The impacts of climate change have continued to increase 
in recent years, inflicting damage and suffering in the EU 
and around the world. Globally, 2023 was the hottest year 
on  record,  while  Europe  has  been  warming  twice  as 
quickly  as  the  global  average,  and  is  now  the  fastest-
warming  continent.  The  frequency  and  severity  of 
extreme  climate  events  are  also  increasing.  Against  this 
backdrop, the EU has demonstrated its determination to 
implement  the  European  Green  Deal  and  to  become 
climate neutral and resilient by 2050, ensuring sustainable 
competitiveness  and  supporting  EU  industry  in  the  net-
zero  transition.  The  European  Climate  Law  is  the  EU’s 
response  to  the  need  for  action.  It  sets  the  objective  of 
achieving climate neutrality by 2050 and a midterm target 
of a reduction in GHG emissions of at least 55 % by 2030, 
and outlines the adaptation efforts necessary to adjust to 
climate  change’s  present  and  future  impacts.  Almost  all 
the  ‘Fit  for  55’  proposals set  out  in  the  European  Green 
Deal  have  been  agreed 
law,  and  the  European 
in 
Commission  recommended  a  new  intermediate  climate 
target of a 90 % reduction in emissions by 2040. In 2024, 
the  Member  States  submitted  updated  national  energy 
and climate plans for 2021–2030, reflecting the increased 
ambition  of  the  revised  EU  legislation.  In  2024,  the 
European Commission also released, jointly with the EEA, 
the first-ever European climate risk assessment. 

The  package  has  been  almost  fully  adopted,  and  the 
Member States have been implementing the legislation. 

The key strategic document at country level is the National 
Energy and Climate Plan (NECP) (174). Denmark submitted 
its updated plan in June 2024 in line with the deadline set 
by the regulation. The European Commission assessed the 
final plan and the extent to which Denmark has followed 
the recommendations for the draft version. The findings 
from the assessment are: 

•  Emissions  under  the  Effort  Sharing  Regulation  (ESR) 
will decrease by 44% in 2030 compared to 2005, and 
Denmark will have to implement additional measures 
to meet its target of 50%. 

•  Denmark  is  in  line  with  its  Land  Use  and  Land-Use-

Change and Forestry (LULUCF) target.  

•  Denmark has a gap towards the target for the share of 

renewable energy. 

•  Denmark is in line with its energy efficiency targets. 

To minimise the impacts of climate policies on vulnerable 
people and sectors, Denmark is using the Just Transition 
Fund and will use the Social Climate Fund from 2026. (for 
more information, see Chapter 5 ‘Finance’). 

Figure 32: Total GHG  emissions (excluding international 
aviation), in Denmark 1990–2022 

its  Member  States  need 

Over  the  last  three  decades,  since  1990,  the  EU  has 
achieved  steady  decreases  in  its  emissions,  reaching  a 
running  total  in  2022  of – 32.5 % (172).  However,  the  EU 
and 
their 
implementation  efforts  and  accelerate  emissions 
reduction to stay on track to reach their targets of a 55 % 
reduction  in  net  GHG  emissions  by  2030  and  climate 
neutrality  by  2050.  Between  1990  and  2022,  Denmark’s 
net  GHG  emissions  decreased  by  47 %,  making  it  one  of 
the  countries  with  an  above-average  decrease  (see 
Figure 32). 

to  step  up 

The  ‘Fit  for  55’  legislative  package  reflects  the  need  to 
speed up the green transition. It includes (i) strengthening 
and expanding the EU emissions trading system (ETS), with 
the  creation  of  a  new,  second,  ETS  for  transport  and 
buildings together with the dedicated Social Climate Fund 
to help citizens during the transition; (ii) increasing targets 
under  the  effort  sharing  regulation;  and  (iii)  a  revised 
regulation for land use, land use change and forestry (173). 

The EU emissions trading system 

The  EU  ETS  is  the  key  tool  for  reducing  GHG  emissions 
cost-effectively across all Member States. It is the world’s 
biggest carbon market, covering around 40 % of the EU’s 
total GHG emissions from electricity and heat generation, 

(172)  EU  net  domestic  emissions,  including  the  land  use,  land-use 
change and forestry (LULUCF) sector and excluding international 
aviation. 

(173)  A  full  overview  of  the  Fit  for  55  package  is  available  at 
https://commission.europa.eu/strategy-and-policy/priorities-

2019-2024/european-green-deal/delivering-european-green-
deal/fit-55-delivering-proposals_en. 

(174)  More  information  about  NECP  is  on  the  dedicated  website 
https://energy.ec.europa.eu/topics/energy-strategy/national-
energy-and-climate-plans-necps_en. 

2025 Environmental Implementation Review 2025 – Denmark 

 
 
 
the  manufacturing  industry,  aviation  within  Europe (175) 
and, from 2024, maritime transport also. 

binding  national  emission  reduction  targets  for  each 
Member State. Denmark‘s target is – 50 %. 

Denmark  38 

In  addition  to  the  2030  targets,  Member  States  have 
annual GHG emissions limits (annual emission allocations), 
reducing every year until 2030. 

There  is  some  flexibility  to  take  account  of  annual 
fluctuations 
in  emissions,  by  trading  emissions  and 
transfers from the ETS and LULUCF. 

Based  on  historical  emissions  and  the  most  updated 
projections,  Denmark  will  need  to 
implement  new 
measures  and/or  use  available  flexibilities  to  achieve  its 
2030  ESR  target.  The  projected  gap  is  5.6 percentage 
points to the 2030 target. 

The transport  and agricultural sectors are still by far the 
greatest sources of emissions in the effort sharing sectors, 
each generating 39 and 38 % of total emissions. 

for 

scope 

it  has 

transport, 

Although  Denmark  is  one  of  the  EU’s  frontrunners  on 
sustainable 
further 
improvement.  In  2023,  5.7 %  of  its  car  passenger  fleet 
were battery electric vehicles (well above EU average of 
1.3 %. In 2023, it had 18 670 publicly accessible charging 
points,  one  for  every  10  e-vehicles  (in  line  with  the  EU 
average). However, only 32 % of its rail network has been 
electrified  (against  the  EU  average  of  56 %).  Freight  is 
predominantly transported by road, at 88 %. 

Buildings  accounted  for  11 %  of  effort  sharing  emissions 
and  are  declining  steadily.  Final  energy  consumption  of 
buildings  decreased  by  around  5.2 %  between  2018  and 
2022.  The  share  of  renewables  in  heating  and  cooling  is 
slightly above 50 % and well above EU average (25 %). 

Figure 33: Effort sharing emissions by sector, 2022 

The system sets a limit or cap on the total amount of GHGs 
that  can  be  emitted  at  the  EU  level.  Within  this  limit, 
companies buy emissions allowances (one allowance gives 
the right to emit 1 t of CO2 eq (carbon dioxide equivalent)), 
in auctions or through trading allowances with others. The 
cap is reduced annually to ensure that overall emissions in 
the sectors covered decrease over time. 

The emissions under the ETS decreased by 63 % from 2005 
to 2023. 

In 2023, about 37 % of the GHG emitted by Denmark’s ETS 
installations  came  from  power  generation.  Of  the  total 
emissions  from  all  industry  sectors,  29 %  came  from 
cement  and  lime,  16 %  from  refineries,  and  55 %  from 
other industries. Between 2019 and 2023, GHG emissions 
from the power sector declined by 31 %, compared with a 
18 %  decline  for  the  industry  sectors.  Since  2013,  GHG 
emissions have declined by 77 % in the power sector and 
by  15 %  in  the  industry  sectors.  Nearly  all  emission 
decreases have taken place  since 2018, while in the  five 
years before 2018, GHG emissions in the industry sectors 
grew by about 10 %. 

From 2027, a new emissions trading system, called ETS2, 
for  buildings,  road  transport  and  additional  sectors, 
(mainly  industry  not  covered  by  the  current  ETS)  will 
become  fully  operational (176).  Member  States  should 
have  notified  full  transposition  of  the  provisions  of  the 
revised  EU  ETS  Directive  related  to  the  new  ETS2  into 
national law by 30 June 2024.  

Denmark has since notified transposition of the relevant 
provisions  of  the  ETS2  Directive  to  the  Commission.  The 
monitoring and reporting requirements and the obligation 
to hold a permit to carry out activities under ETS2  apply 
from 1 January 2025. 

Denmark is the only country that fully transpose previous 
revisions of ETS Directive (177) into national law in time. 

Effort sharing 

from  domestic  transport 

The  Effort  Sharing  Regulation (ESR) (178)  covers  GHG 
emissions 
(excluding  CO₂ 
emissions  from  aviation),  buildings,  agriculture,  small 
industry and waste. Emissions from these sectors account 
for  around  60 %  of  the  EU’s  domestic  emissions.  The 
regulation  sets  the  EU-wide  target  to  reduce  emissions 
from the effort sharing sectors by 40 % by 2030 compared 
to 2005 levels. This overall target for the EU translates to 

(175)  Flights between the EU Member States including departing flights 
to Norway, Iceland, Switzerland and the United Kingdom. 

(176)  Directive 

(EU) 

2023/959 

(https://eur-lex.europa.eu/legal-

(177)  Directive - 2023/959 - EN - EUR-Lex and Directive - 2023/958 - EN 

- EUR-Lex 
(178)  Regulation 

(EU) 

2018/842 

(https://eur-

content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.ENG) 

lex.europa.eu/eli/reg/2018/842). 

2025 Environmental Implementation Review – Denmark 

 
 
 
Land use, land-use change and forestry 

2025 priority actions 

Denmark  39 

• 

In  the  next  period  Denmark  should  focus  on 
implementing  all  polices  and  measures  that  are 
needed  to  achieve  targets  laid  down  in  the  Effort 
Sharing  Regulation  and  LULUCF  regulation.  More 
detailed priority actions are set out in the assessment 
of the final National Energy and Climate Plan (NECP). 
(180) 

The LULUCF sector plays a significant role in achieving the 
EU’s climate neutrality goal. In the EU, this sector absorbs 
more GHGs than it emits, removing significant volumes of 
carbon  from  the  atmosphere.  Thus,  it  is  the  only  sector 
with negative emissions. 

That  is  not  a  case  in  Denmark  which  had  negative 
emissions only twice since 1990 (in 2015 and 2022). This is 
due to relatively small, forested area and high emissions 
from agricultural soil. 

Denmark‘s target in 2030 is to enhance land removals by 
an additional – 0.4 Mt of CO2 equivalent compared to the 
yearly  average  of  the  period  2016–2018.  The  latest 
available  projections  show  a  surplus  compared  to  the 
2030  target  of  −0.2 Mt  of  CO2  equivalent.  Therefore, 
Denmark is on track to meet its 2030 target. 

Adaptation to climate change 

Halting all GHG emissions would still not prevent climate 
impacts that are already occurring. Therefore, adaptation 
to  climate  change  is  also  a  key  component  of  climate 
policy. 

Denmark  has  one  out  of  three  regions  identified  as  a 
hotspots  of  climate  risks  most  affected  by  climate 
change – low-lying coastal regions. (179) 

Denmark continues to face climate change risks, including 
heavier rainfall, droughts, more intense storms, and storm 
surges.  On  the  positive  side,  it  has  a  high  share  of 
insurance coverage for all climate-related risks, resulting 
in a narrow climate protection gap. 

Denmark adopted its national adaptation strategy and in 
2008 and adaptation plan in 2012. Denmark announced a 
new  adaptation  plan  in  2023.  It  focuses  on  coastal 
protection  and  groundwater 
levels  as  well  as 
strengthened  cross-sectoral  coordination  of  climate 
change adaptation. 

In  2022,  the  European  Commission  identified  a  priority 
action to further invest in the electricity grid network to 
ensure that the increasing share of renewable energy can 
be  used  efficiently,  for  example,  on  system  flexibility, 
smart  grids  and  storage.  Denmark  made  some  progress 
and increased its cross-border capacity. But it still needs 
additional 
investment  to  enable  grater  uptake  of 
renewable electricity. 

Climate 

(179)  European 

(EUCRA), 
(https://climate-adapt.eea.europa.eu/en/eu-adaptation-
policy/key-eu-actions/european-climate-risk-assessment). 
(180)  European  Commission,    National  energy  and  climate  plans, 

Assessment 

2024 

Risk 

environment/implementation-eu-countries/energy-and-climate-
governance-and-reporting/national-energy-and-climate-
plans_en. 

https://commission.europa.eu/energy-climate-change-

2025 Environmental Implementation Review – Denmark 

 
 
 
Denmark  40 

Part II: Enabling framework – implementation tools 

5. Financing

The  EU  budget  supports  climate  investment  in  Denmark 
with  significant  amounts  in  2021–2027,  with  revenues 
from the ETS also feeding into the national budget. During 
2020–2022, Denmark’s revenues from auctioning reached 
EUR 822 million in total, with 100 % of it spent on climate 
and energy. 

In  addition,  the  annual  investment  needed  to  meet  its 
environmental  objectives 
in  the  areas  of  pollution 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems  is  estimated  to  be  EUR 7 billion  per  year  in 
Denmark. 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 5.6 billion per year; thus, there is a 
gap of around EUR 1.4 billion per year. 

Of the environmental investment gap, EUR 0.8 billion per 
year  concerns  pollution  and  EUR 0.6 billion  per  year 
circular economy. 

Climate finance landmarks 

EU funding for climate action 

The  RRF  contributes  to  climate  finance  in  Denmark  with 
EUR 1.12 billion  up  to  2026,  representing  69 %  of  the 
RRP (183). 

The  European 
(EIB)  provided 
Investment  Bank 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021  and  mid  2024  to  support  energy,  transport  and 
industry  projects  that  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 2.9 billion was assigned to 
Denmark in the reference period (184). 

National  financing, 
system revenues 

including  EU  emissions  trading 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
budgets,  amounted 
in  2020, 
EUR 293 million  in  2021  and  EUR 362 million  in  2022,  in 
Denmark,  totalling  EUR 822 million  combined  in  those 
years,  corresponding  to  the  100 %  of  the  auctioning 
revenues (185). 

to  EUR 167 million 

From the remaining part of the EU ETS revenues that feed 
into  the  Innovation  Fund  and  the  Modernisation  Fund, 
further  support  is  available  to  climate  action  at  the  EU 
level. 

The EU budget supports climate action in the EU-27 with 
EUR 657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy provides EUR 120 billion (over half of it through the 
ERDF), 
(RRF) 
EUR 275.7 billion and CAP EUR 145.9 billion (181). 

recovery  and 

resilience 

facility 

the 

In  Denmark,  the  EU  cohesion  policy  (considering  the  EU 
for 
contribution  amount)  provides  EUR 206 million 
climate  action  in  2021–2027  (with  22 %  of  this  via  the 
ERDF),  with  a  further  EUR 156 million  from  European 
Maritime, Fisheries and Aquaculture Fund (EMFAF) (182). 

(181)  European  Commission,  Statement  of  Estimates  of  the  European 
Commission –  For  the  financial  year  2025,  Publications  Office  of 
pp. 94–96, 
the 
https://commission.europa.eu/document/download/7a0420e1-
599e-4246-9131-ccb7d505d6d9_en?filename=DB2025-
Statement-of-Estimates_1.pdf. 

European  Union, 

Luxembourg, 

2024, 

(182)  See 

the 

Cohesion 

Open 

Data 

Platform 

(https://cohesiondata.ec.europa.eu/). 

(183)  EU  Commission  datasets  and  the  Recovery  and  Resilience 
(https://ec.europa.eu/economy_finance/recovery-

Scoreboard 
and-resilience-scoreboard/index.html). 

the  environment 

It should be noted that investment in climate action also 
the 
supports 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (186). 

therefore, 

and, 

(184)  A 

list  of 

financed  projects 

is  provided  by 

the  EIB 

(https://www.eib.org/en/projects/loans/index.htm). 

(185)  European  Commission:  Directorate-General  for  Climate  Action, 
Progress Report 2023 – Climate action, Publications Office of the 
European 
2023, 
https://climate.ec.europa.eu/news-your-voice/news/climate-
action-progress-report-2023-2023-10-24_en. 

Luxembourg, 

Union, 

(186)  NB:  Indirect  investments  (from  climate  and  other  policies)  in 

support of the environment are accounted for via the tracking. 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
 
 
Environmental financing and investments 

Table 1: Key environmental allocations from EU funds to 
Denmark (million EUR), 2021–2027 

Denmark  41 

This  section  describes  Denmark’s 
investment  needs, 
current  financing  and  gaps  as  they  relate  to  the  four 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (187). 

The environment overall 

Investment needs 

The  overall  environmental 
investment  needs  to  be 
sufficient to enable Denmark to meet its objectives in the 
areas  of  pollution  prevention  and  control,  the  circular 
economy and waste, water protection and management, 
and biodiversity and ecosystems. The required investment 
is estimated to be EUR 7 billion per year (in 2022 prices). 

A  significant  part  of  the  estimated  requirement  (up  to 
EUR 3.8 billion per year) can be attributed to the need to 
support the circular economy. The investment needs for 
water  and  for  pollution  prevention  and  control  are 
estimated at EUR 1.4 billion and EUR 1.2 billion per year, 
respectively,  with  EUR 0.7 billion  per  year  needed  for 
biodiversity and ecosystems. 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR 5.6 billion  in  Denmark  from  EU  and  national 
sources combined (in 2022 prices). 

Total environmental funding from the MFF is estimated to 
reach  around  EUR 2 billion  for  Denmark  in  total,  during 
2021–2027 (or EUR 280 million per year). 

Instrument 

Cohesion policy 
ERDF 
Cohesion Fund 
Just Transition Fund 

CAP 
European Agricultural Guarantee Fund 
European  Agricultural  Fund  for  Rural 
Development 

European  Maritime,  Fisheries  and 
Aquaculture Fund  

Other MFF sources 
RRF (d) (2021–2026) 

Allocations 

77.2 (a) 
60.9 
0.0 
16.3 
1 262.6 (b) 
872.6 
390 

181.8 

439.3 (c) 

289.1 

(a) 

(b) 

(c) 

(d) 

European  Commission,  2021-2027  cohesion  policy  (planned) 
allocations in EU amount excluding national co-financing, based on 
the  tracking  in  the  Common  Provisions  Regulation  (CPR,  2021) 
Annex I. Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 
its  publication  date.  Note  that  Denmark  is  not  eligible  for  the 
Cohesion 
information: 
and 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

further 

Source 

Fund. 

Regulation (EU) 2021/2115 of the European Parliament and of the 
Council  of  2 December  2021  establishing  rules  on  support  for 
strategic  plans  to  be  drawn  up  by  Member  States  under  the 
common agricultural policy (CAP strategic plans) and financed by 
the  European  Agricultural  Guarantee  Fund  (EAGF)  and  by  the 
European  Agricultural  Fund  for  Rural  Development  (EAFRD)  and 
repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013 
(OJ 
https://eur-
p. 1), 
lex.europa.eu/eli/reg/2021/2115. 

6.12.2021, 

Annex XI, 

L 435 

Note that 2021-2027 combines factual data for 2021 and 2022 and 
expenditure  under  the  relevant  specific  objectives  (SOs)  of  the 
CAP strategic plans from 2023, using the EU biodiversity tracking 
methodology  (https://commission.europa.eu/system/files/2023-
06/Biodiversity%20tracking%20methodology%20for%20each%20
programme%202023.pdf). Source: European Commission.  

Space  Fund,  Horizon  Europe,  LIFE  and  the  Connecting  Europe 
Facility. 

Outside  the  MFF.  Note  that  the  RRF  applies  a  similar 
environmental tracking scheme (set in the RRF Regulation, Annex 
VI)  as  the  EU’s  cohesion  policy.  RRF  dataset  version  used:  July 
2024, prior to 2025 revisions. Data source: European Commission. 

Denmark,  in  addition  to  receiving  EU  funds  earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
the LIFE programme (188) (EUR 5.4 billion), Horizon Europe 

(187)  Research,  development  and  innovation  is  accounted  for  under 
each environmental objective. The financing needs, baselines and 
gap  estimates  are  based  on  the  Directorate-General  for 
internal  analysis  (of  2024).  Throughout  this 
Environment’s 

chapter,  specific  references are  provided to  the  most  important 
data sources used. 

(188)  https://cinea.ec.europa.eu/programmes/life_en. 

2025 Environmental Implementation Review – Denmark 

 
 
 
(189) (EUR 95.5 billion), the Connecting Europe Facility (190) 
EUR 33.7 billion) and funds that can be mobilised through 
the InvestEU programme (191). 

Denmark’s  RRP  supports  climate  objectives  through 
funding  of  EUR 1.12 billion  (68.8 %  of  total),  with  an 
additional  EUR 0.04 billion  (2.3 %  of  total)  for  the 
environment. 

The  EIB  provided  around  EUR 1 billion  in  environment-
related financial contributions to  Denmark  from 2021 to 
mid-2024,  overwhelmingly  linked  to  sustainable  energy, 
industrial  projects,  which  provides 
transport  and 
reducing  air  pollution, 
significant 
environmental noise and other pollution. 

co-benefits 

to 

The  EU’s  total  national  expenditure  on  environmental 
protection  (operating  plus  capital  expenditure)  was 
EUR 298 billion  in  2020  and  EUR 321 billion  in  2021, 
representing around 2.2 % of EU-27 GDP. In Denmark, the 
total national environmental protection expenditure was 
EUR 6.7 billion 
in  2021, 
representing 2.2 % and 2.1 % of GDP, respectively. 

in  2020  and  EUR 7.1 billion 

Of  the  total  environmental  expenditure,  the  national 
capital  expenditure 
(investment)  on  environmental 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
0.4 %  of  the  EU’s  GDP. 
In  Denmark,  the  national 
environmental  protection  investment  reached  around 
EUR 1.5 billion  in  2020,  rising  to  EUR 2.1 billion  in  2021, 
representing around 0.5 % of GDP. 

protection 

investment 

Splitting by institutional sector, 6 % of Denmark’s national 
environmental 
(capital 
expenditure) comes from the general government budget, 
with 86 % coming from specialist private-sector producers 
(of environmental protection services, such as waste and 
water  companies)  and  8.1 %  from  the  general  business 
sector,  whose  environmental  activities  are  usually 
ancillary  to  its  main  activities.  At  the  EU  level,  38 %  of 
environmental  protection 
from 
specialist  private-sector 
governments,  40 % 
producers and 22 % from the general business sector (192). 

investment  comes 

from 

Denmark  42 

92 % national financing. The total public financing (EU plus 
national public) represents 13 % of the total. 

The gap 

To meet its four environmental objectives beyond climate 
change, the additional investment need over the current 
levels (i.e. the gap) reaches an estimated EUR 1.45 billion 
per year in  Denmark, representing around  0.39 %  of the 
national GDP, being lower than the EU average (0.77 %). 

Figure 34: Environmental financing, needs and gaps  per 
Member State (% of GDP) 

Source: Analysis of Directorate-General for Environment. 

The 
following  table  provides  the  distributions  of 
Denmark’s  environmental  investment  gap  (expressed  in 
various forms) by environmental objective. 

Table 2: Summary of environmental investment gaps in 
Denmark per year, 2021–2027 

Environmental 
objective 

Investment gap per year 

Million EUR 
(2022 prices) 

% of 
total 

% of 
GDP 

Denmark’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 5.6 billion  per  year  (in  2022 
prices),  including  EU  funding  and  national  public  and 
national private expenditure. Of the total, the share of EU 
funding (including EIB funds) reaches 7.8 %, with around 

Pollution prevention 
and control 

Circular economy 
and waste 

801 

55.2  0.21 

621 

42.8  0.17 

(189)  European  Commission,  Horizon  Europe,  https://research-and-
innovation.ec.europa.eu/funding/funding-opportunities/funding-
programmes-and-open-calls/horizon-europe_en. 

(190)  The  Connecting  Europe  Facility  Transport  part  also  includes 
EUR 11.3 billion  transferred  from  the  Cohesion  Fund,  of  which 
30 % will be made available, on a competitive basis, to all Member 
States  eligible  for  the  Cohesion  Fund.  The  remaining  70 %  will 
respect the national envelopes until 31 December 2023. 

(191)  The  InvestEU  Fund  is  set  to  mobilise  over  EUR 372 billion  of 
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. 

(192)  Eurostat, 

‘Environmental  protection  expenditure  accounts’, 

env_ac_epea. 

2025 Environmental Implementation Review – Denmark 

 
 
 
Denmark  43 

269 

18.6  0.07 

further  11.1 %  from  the  RRF,  adding  up  to  18 %  of  the 
total.  EIB  financing  contributes  35.6 %  and  national 
sources reach 46.4 %. 

— 

—  — 

The gap 

Water management 
and water industries 

Biodiversity and 
ecosystems 

Total 

1 451 

100.0  0.39 

NB: For biodiversity and ecosystems, there is no significant gap expected 
based on currently available data. 
Source: Directorate-General for Environment analysis. 

Pollution prevention and control 

Investment needs 

In  pollution  prevention  and 
control,  Denmark’s 
investment  needs  are  estimated  to  reach  EUR 1.2 billion 
per  year  (including  baseline  investments)  in  2021–2027. 
Most of this, around EUR 1 billion, relates to air pollution 
control, to comply with the clean air requirements for the 
five  main  air  pollutants  under  the  NECD  by  2030.  The 
estimated  needs  to  reduce  environmental  noise  reach 
EUR 570 million per year, most of which is delivered by the 
(same) sustainable energy and transport investments that 
also  benefit  clean  air (193).  Industrial  site  remediation 
year. 
requires  an  estimated  EUR 69 million  per 
Microplastics pollution and the chemicals strategy require 
around EUR 40–50 million per year (each) (194). 

Current investments 

reach 

control 

investment 
and 

levels  supporting  pollution 
The  current 
prevention 
estimated 
an 
EUR 356 million per year in Denmark in 2021–2027. Most 
of  the  financing  concerns  clean  air  (EUR 212 million  per 
year).  Protection  from  environmental  noise  receives 
around  EUR 47 million  per  year,  with  a 
further 
EUR 32 million  a  year  for  protection  from  radiation  and 
EUR 84 million  per  year  for  industrial  site  remediation 
(195). 

In Denmark, the EU MFF provides an estimated 7 % of the 
clean  air  financing  (mostly  via  cohesion  policy),  with  a 

(193)  2021 

assessment 

Phenomena 

project 
(https://op.europa.eu/en/publication-detail/-
/publication/f4cd7465-a95d-11eb-9585-01aa75ed71a1)  and  the 
Directive 
Commission’s 
implementation 
report 
(https://environment.ec.europa.eu/system/files/2023-
03/COM_2023_139_1_EN_ACT_part1_v3.pdf). 

Environmental 

Noise 

2023 

(194)  European  Commission,  Third  Clean  Air  Outlook,  Brussels,  2022, 

https://environment.ec.europa.eu/topics/air/clean-air-
outlook_en. See also the impact assessment for the revision of the 
AAQD, available from the Commission web page on the proposed 
revision 
(https://environment.ec.europa.eu/publications/revision-eu-
ambient-air-quality-legislation_en). 

(195)  Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure (EPEA accounts, Eurostat). Note that the bulk of clean 
air  financing  is  provided  as  a  contribution  from  climate  (energy 

To meet its environmental objectives concerning pollution 
prevention and control (towards zero pollution), Denmark 
needs  to  provide  an  additional  EUR 801 million  per  year 
(0.21 % of GDP), mostly related to clean air and noise. The 
adequate 
the 
investments included for sustainable energy and transport 
would largely deliver this, while in many Member States 
additional measures and investments may be required to 
comply with the ammonia reduction requirements. 

implementation  of 

the  NECP  with 

According to the latest (2023) NAPCP review report (196), 
Denmark  did  not  comply  with  ammonia  reduction 
requirements in 2020 and 2021, and it is at low risk of non-
compliance  with  four  out  of  the  five  atmospheric  air 
pollutants concerning the NECD’s 2030 emission reduction 
commitments (and is at medium risk for PM2.5), based on 
the  policies  and  measures  in  its  NAPCP  that  take  into 
account  climate,  energy  and  CAP  plans  and  financing 
baselines. 

Circular economy and waste 

Investment needs 

Denmark’s  investment  needs  in  circular  economy  and 
waste  reach  EUR 3.8 billion  per  year  (including  baseline 
investments).  Most  of  this,  around  EUR 3.6 billion  per 
year, relates to circular economy measures in the mobility, 
food  and  built  environment  systems,  with  a  further 
for  waste  management 
EUR 356 million  necessary 
(municipal  and  packaging  waste),  covering  waste 
collection,  biowaste  treatment,  recycling  reprocessors, 
waste-sorting  facilities,  and  digitalisation  of  the  waste 
registry. The amount for waste excludes the investments 
needed for the uptake of circularity and waste prevention 
across the economy (197). 

and  transport)  measures,  as  per  the  tracking  schemes  in  the 
Common  Provisions  Regulation  Annex  I  and  the  RRF  Regulation 
Annex  VI.  Further 
tracking: 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf  
(196)  European Commission, ‘National air pollution control programmes 
website, 
European 

information  on  clean  air 

projections’, 

and 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants/national-air-pollution-control-
programmes-and-projections_en. 

Commission 

(197)  See Systemiq and Ellen MacArthur Foundation, Achieving ‘Growth 
Within’, 2017; and European Commission: Directorate-General for 
Environment, Study on investment needs in the waste sector and 
on  the  financing  of  municipal  waste  management  in  Member 
States,  Publications  Office  of  the  European  Union,  Luxembourg, 

2025 Environmental Implementation Review – Denmark 

 
 
 
Current investments 

Circular economy investments across the economy reach 
around EUR 2.9 billion per year in Denmark in 2021-2027, 
for  waste 
further  EUR 0.3 billion  provided 
with  a 
management that does not constitute circular economy. 

Around 0.3 % of this combined financing for circularity and 
waste comes from the EU MFF, without additional support 
from the RRF. EIB loans identified in support of circularity 
and  waste  represent  0.3 %  of  the  total.  The  share  of 
national  sources  is  absolutely  overwhelming,  reaching 
99.4 % of the total financing (198). 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular economy and waste, Denmark needs to increase 
investments  by  an  estimated 
circular  economy 
EUR 560 million 
additional 
EUR 61 million concerning waste management action, not 
belonging to circular economy. Combined, this amounts to 
representing  0.17 %  of 
EUR 621 million  per  year, 
Denmark’s GDP. 

year,  with 

per 

an 

Of  the  circular  economy  gap,  EUR 147 million  relates  to 
recent  initiatives,  such  as  the  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 
digital  tools,  CRM  recycling,  and  measures  proposed 
under the amendment of the Waste Framework Directive, 
and EUR 414 million constitutes further investment need 
to unlock Denmark’s circular economy potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 1.4 billion (in 2022 prices) in Denmark. This comprises 
investment needs both for the water industry and for the 
protection and the management of water. The largest part 
of  the  total  annual  need,  EUR 1.3 million,  relates  to  the 
management  of  wastewater  (also  including  additional 
costs  associated  with  the  revised  UWWTD).  A  further 
EUR 50 million  (each)  is  necessary  for  drinking-water-

2019, 
/publication/4d5f8355-bcad-11e9-9d01-01aa75ed71a1. 

https://op.europa.eu/en/publication-detail/-

(198)  Waste management and circular economy expenditure tracking in 
the  EU  funds,  EIB  projects  and  in  the  national  expenditure 
(Eurostat).  Datasets:  EPEA  accounts  (env_epi)  and  circular 
economy private investments (cei_cie012). 

(199)  See  European  Commission,  ‘Estimating  investment  needs  and 
financing capacities for water-related investment in EU Member 
2020, 
28 May 
States’, 
https://commission.europa.eu/news/estimating-investment-
needs-and-financing-capacities-water-related-investment-eu-
member-states-2020-05-28_en;  and  OECD,  Financing  Water 
Supply, Sanitation and flood Protection: Challenges in EU Member 
States  and  policy  options,  OECD  Publishing,  Paris,  2020, 
https://www.oecd-ilibrary.org/environment/financing-water-
supply-sanitation-and-flood-protection_6893cdac-en. 

Denmark  44 

investments  and 
related 
management of water (199). 

Current investments 

for 

the  protection  and 

Water  investments  in  Denmark  are  estimated  to  be 
around EUR 1.1 billion per year (in 2022 prices) in 2021–
2027.  Of  this,  EUR 1.06 billion  supports  wastewater 
management,  EUR 30 million  drinking  water  and  around 
EUR 15 million  per  year  for  both  other  aspects  of  the 
Water  Framework  Directive  (water  management  and 
water protection). 

Of  the  total  financing,  1.5 %  is  provided  by  the  EU  MFF 
(EMFAF, Horizon Europe), while 98.5 % of water financing 
comes from national sources (200). 

The gap 

To  meet  the  various  environmental  targets  under  the 
Water  Framework  Directive  and  the  Floods  Directive, 
Denmark’s water investment gap reaches EUR 269 million 
per year (0.07 % of GDP), with over half related to waste 
(EUR 209 million  per  year).  Drinking  water 
water 
measures  require  an  additional  EUR 14 million  per  year 
and the other aspects of the Water Framework Directive 
around EUR 33 million per year over the existing levels of 
financing. 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 0.7 billion per year (in 2022 prices) in 
Denmark 
includes  the  following 
financing needs: 

in  2021–2027.  This 

•  Denmark’s  PAF (201)  concerning  the  Natura  2000 
areas:  this  cost  is  not  known,  as  Denmark  did  not 
submit a PAF; 
additional BDS costs (202): EUR 482 million per year; 
sustainable 
EUR 177 million per year. 

management 

costs (203): 

• 
• 

soil 

(200)  Water investment levels are estimated through tracking EU funds, 
EIB projects and national expenditure (EPEA accounts, Eurostat). 
(201)  European Commission, ‘Financing Natura 2000 – Prioritised action 
website, 

European 

frameworks’, 
https://environment.ec.europa.eu/topics/nature-and-
biodiversity/natura-2000/financing-natura-2000_en. 

Commission 

(202)  See European Commission: Directorate-General for Environment, 
Biodiversity  Financing  and  Tracking –  Final  report,  Publications 
2022, 
Office 
https://op.europa.eu/en/publication-detail/-
/publication/793eb6ec-dbd6-11ec-a534-
01aa75ed71a1/language-en. 

European  Union, 

Luxembourg, 

the 

of 

(203)  See Proposal for a directive of the European Parliament and of the 
Council  on  soil  monitoring  and  resilience  (Soil  Monitoring  Law) 
COM(2023) 416 
2023, 
https://environment.ec.europa.eu/publications/proposal-
directive-soil-monitoring-and-resilience_en. 

5 July 

final 

of 

2025 Environmental Implementation Review – Denmark 

 
 
Current investments 

Public financial management 

Denmark  45 

The current level of biodiversity financing is estimated to 
be EUR 0.9 billion per year (in 2022 prices) in 2021–2027. 
94 % of this is considered direct financing to biodiversity 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

0.1 % of the total financing is estimated to come from EU 
cohesion  policy  and  19 %  from  CAP.  The  EU  MFF 
altogether  accounts  for  23.5 %  of  the  financing  and  the 
rest, 76.5 %, comes from national sources (204). 

Denmark has programmed a relatively high share (19.8 %) 
of  its  CAP  budget  to  be  spent  on  measures  supporting 
biodiversity 
in  2021–2027.  However,  the  share  of 
cohesion policy funding dedicated to biodiversity  (2.6 %) 
(disregarding ESF+) is below the EU average, and no RRF 
funding  is  envisaged  to  support  biodiversity  in  Denmark 
(see Figure 35). 

Figure 35: 2021–2027 contributions to biodiversity from 
main  EU  instruments  per  Member  State  (%  of  policy 
total) 

NB: ESF+, European Social Fund Plus. 

The gap 

To  meet  the  environmental  objectives  concerning  the 
protection and restoration of biodiversity and ecosystems 
and  other  relevant  cross-cutting  measures,  Denmark’s 
financing resources are estimated to be proportionate to 
the  financing  needs,  without  a  major  investment  gap, 
according to the currently available data. 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools  to 
achieve climate and environmental goals. Some Member 
States,  including  Denmark,  already  use  green  budgeting 
tools  for  identifying  and  tracking  green  expenditures 
and/or revenues (205). Green budgeting practices provide 
increased transparency on the environmental implications 
of budgetary policies. 

The  Commission  has  developed  a  non-mandatory  green 
budgeting  reference  framework  that  brings  together 
methodologies  for  assessing  the  impacts  of  budgets  on 
climate and environmental goals (206).  

To help Member States develop national green budgeting 
and  thereby  improve  policy  coherence  and  support  the 
green  transition,  the  Commission  facilitated  a  technical 
support instrument (TSI) project on green budgeting from 
2021 to 2024 (207). Denmark participated, refining ideas on 
budgetary tagging at national level. 

Denmark has also been selected for the next round of TSI 
projects  on  green  budgeting,  starting  in  2025,  where 
support  for  elaborating  Denmark’s  tagging  methodology 
will be provided. 

Beyond green budgeting, to improve policy outcomes, the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (208)  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

formed  the 

Total environmental taxes amounted to EUR 9.2 billion in 
Denmark  in  2022,  representing  2.4 %  of  its  GDP  (EU 
average:  2.0 %).  Energy  taxes 
largest 
component of environmental taxes, accounting for 1.4 % 
of  GDP,  which  is  lower  than  the  EU  average  of  1.6 %. 
Transport taxes, at 0.9 % of GDP, were well above the EU 
average (0.4 %), as were taxes on pollution and resources, 
at  0.14 %  (EU  average  0.08 %).  In  2022,  environmental 
taxes  in  Denmark  accounted  for  5.8 %  of  total  revenues 

(204)  Based  on 

biodiversity 

tracking 

in 

the 

EU 

budget 

(206)  European  Commission, 

(https://circabc.europa.eu/ui/group/3f466d71-92a7-49eb-9c63-
6cb0fadf29dc/library/8e44293a-d97f-496d-8769-50365780acde), 
and national expenditure into biodiversity from the Classification 
of the Functions of Government accounts. 

(205)  European  Commission,  Green  Budgeting  in  the  EU.  Key  Insights 
from the 2023 European Commission Survey of Green Budgeting 
Practices, 
https://economy-
finance.ec.europa.eu/economic-and-fiscal-governance/national-
fiscal-frameworks-eu-member-states/green-budgeting-
eu_en#:~:text=European%20Commission%20Green%20Budgetin
g%20Survey%C2%A0. 

2023, 

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

reference 
finance.ec.europa.eu/economic-and-fiscal-governance/green-
budgeting-eu_en. 

(207)  https://reform-support.ec.europa.eu/what-we-do/revenue-

administration-and-public-financial-management/supporting-
implementation-green-budgeting-practices-eu_en. 

(208)  Commission notice – Technical guidance on the climate proofing 
of infrastructure in the period 2021–2027 (OJ C 373, 16.09.2021, 
p. 1), https://op.europa.eu/en/publication-detail/-
/publication/23a24b21-16d0-11ec-b4fe-
01aa75ed71a1/language-en. 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
from taxes and social security contributions (above the EU 
average of 5.0 %) (209). 

issuance 
the 
(EUR 9.3 billion) (212). 

in  2023  amounted  to  USD 10.1 billion 

Denmark  46 

Figure 36: Environmental taxes per Member State, 2022 

The EU Green Deal emphasises the role of well-designed 
tax  reforms  (e.g.  shifts  from  taxing  labour  to  taxing 
pollution) to boost economic growth and resilience and to 
foster  a  fairer  society  and  a  just  transition  through  the 
right price signals. The Green Deal promotes the ‘polluter-
pays  principle’,  which  makes  polluters  bear  the  costs  to 
prevent, control and remedy pollution. 

According to a 2024 study (210), Denmark applies various 
environmental taxes: (i) taxes on emissions to water and 
air,  solid  waste  disposal  (landfilling  fee)  and  ozone-
depleting  substances;  (ii)  product  charges  on  vehicles, 
pesticides, fertilisers, batteries, plastics, paints, tyres and 
non-deposit containers; and (iii) user charges on hunting, 
fishing, water abstraction and waste volumes. Significant 
amount of revenues are raised from air pollution taxes and 
also from taxes on water pollution and waste generation 
in Denmark. 

Green bonds and sustainable bonds 

In  2023,  the  total  value  of  the  green  bonds  issued  by 
Member States  was USD 245 billion (EUR 227 billion), up 
from USD 234 billion (EUR 198 billion) in 2021 (211). 

During  2021–2023  combined,  Denmark  issued  green 
bonds  worth  USD 29.1 billion  (EUR 24.6 billion).  Of  this, 

During  2014–2023,  83 %  of  the  green  bonds  issued  by 
European  countries  (excluding  supranational  entities) 
served objectives in energy, buildings or transport, while 
5 % supported objectives in water, 5.1 % related to land 
use  (with  links  to  nature  and  ecosystems)  and  3.8 % 
applied  to  waste  management.  By  2023,  the  combined 
share of energy, buildings and transport had decreased to 
73 %, the share of waste management and land use had 
increased (to 5.9 % and 8.4 %, respectively) and the share 
of water had remained around 5 %. 

In  2021–2023,  31.7 %  of  the  European  green  bonds 
(excluding  those  issued  by  supranational  bodies)  was 
issued  by  financial  corporates,  29.1 %  by  sovereign 
governments  and  23.1 %  by  non-financial  corporates. 
8.3 % of the issuances was linked to government-backed 
entities, 6.4 % to developments banks and 1.4 % to local 
governments. 

Figure 37: Value of green bonds issued per Member State 
(billion EUR), 2021, 2022 and 2023 

Data source: Climatebonds.net, with some additional data from national 
sources (e.g. Croatia, Slovenia). 

Environmentally harmful subsidies 

Addressing  and  phasing  out  environmentally  harmful 
subsidies,  in  particular  fossil  fuel  subsidies  (FFS),  is  a 
further  step  towards  achieving  the  eighth  environment 

(209)  Eurostat, ‘Environmental taxes accounts’, env_eta. 
(210)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
Annex 1-2, 
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

(211)  Climate  bonds  initiative  (https://www.climatebonds.net/).  NB. 
Additionally (and not included in this), national sources indicated 
EUR 544.8 million issuance for Croatia, in 2022-2023, and a slightly 
higher  amount  for  Slovenia  (+0.27  billion)  during  2021-2023  in 
total. 
Ibidem 

(212) 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
 
the  enabling 
action  programme  objectives  and 
conditions (213). FFS are costly for public budgets and make 
it difficult to achieve European Green Deal objectives. In 
many cases, these subsidies also counteract incentives for 
green investments. 

The overall downward trend of FFS mentioned in past EIRs 
was disrupted from 2022 due to the European response to 
the 2021 energy crisis and subsequent increase in energy 
prices. 

As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 109 billion in 2023 from EUR 57 billion in 
2020. From 2021 to 2023, there was a marked increase in 
annual FFS of 72 % in the EU (214). 

For the majority of the Member States (16), the year 2022 
saw  a  peak  in  the  amount  of  overall  FFS.  A  decline  was 
then observed in 2023 (215). In particular, FFS for coal and 
lignite, natural gas and oil increased in 2022 and a strong 
increase was observed for natural gas subsidies. 

In Denmark, energy subsidies followed a decreasing trend 
between 2015 and 2021, with some recovery in 2022 and 
2023.  Within  this,  FFS  were  stable  in  2015–2019  (at 
around  EUR 0.6 billion  per  year),  but  decreased  after 
2019, dropping to EUR 0.3 billion in 2023. 

As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to less than 0.1 % in Denmark and also in Sweden (the EU 
average was 0.8 %) (216). 

Further details of the situation in Denmark are shown in 
Figure 38. 

(213)  Article 3(h) and 3(v) of the eighth environment action programme. 
(214)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
COM(2025), 

European 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en. 

Union, 

Denmark  47 

Figure 38:  Energy  subsidies  by  energy  carrier  (billion 
EUR), 2015–2023 

NB: RES, renewable energy source. 

Source: analysis of Directorate-General Energy 
Although, based on the data available, the share of private 
environmental  financing  in  Denmark  is  high  (over  80 %) 
and this can provide a useful example for other Member 
States on using the involvement of private financing more 
effectively,  Denmark 
still  has  an  environmental 
investment gap overall. The gap reaches around 0.4 % of 
Denmark’s GDP, around half of which relates to pollution 
prevention  and  control.  Furthermore,  Denmark  did  not 
submit  a  PAF  concerning  the  costs  of  the  Natura  2000 
network and related green infrastructure. 

2025 priority action 

In  light  of  the  overall  environmental  investment  gap 
observed,  the  following  priority  action  is  specified  for 
Denmark. 

•  Use more national funding (for instance by increasing 
taxes  in  favour  of  the  environment  and  reducing 
environmentally  harmful  subsidies),  EU  funding  and 
private funding to help close the investment gap. 

(215)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

(216)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
COM(2025), 

Union, 

European 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en. 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
 
 
 
6. Environmental governance 

Denmark  48 

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they rely on the three ‘pillars’ of the Aarhus Convention: 
(i)  access  to  information,  (ii)  public  participation  in 
decision-making and (iii) access to justice in environmental 
matters.  It  is  of  crucial  importance  to  public  authorities, 
the public and businesses that environmental information 
shared  efficiently  and  effectively (217).  Public 
is 
participation  allows  authorities  to  make  decisions  that 
take public concerns into account. Access to justice is a set 
of  guarantees  that  allows  citizens  and  NGOs  to  use 
national courts to protect the environment, safeguard the 
citizens  and  ensure  accountability  of 
rights  of 
authorities (218).  It 
legal 
includes  the  right  to  bring 
challenges (‘legal standing’) (219). 

Environmental information 

This  section  focuses  on  the  implementation  of  the 
Infrastructure  for  Spatial  Information  in  the  European 
Community (Inspire) Directive. The Inspire Directive aims 
to set up a European spatial-data infrastructure for sharing 
environmental  spatial 
information  between  public 
authorities across Europe. It is expected that this will help 
policymaking  across  boundaries  and  facilitate  public 
access  to  this  information.  Geographic  information  is 
needed  for  good  governance  at  all  levels  and  should  be 
readily and transparently available. 

Denmark’s  performance  in  implementing  the  Inspire 
Directive  has  been  reviewed  based  on  its  2023  country 
fiche (220) (see Table 3). In 2022, the European Commission 
identified  a  priority  action  on  the  need  to  make  spatial 
data  more  widely  accessible  and  prioritise 
the 
environmental  datasets (221).  Despite  some  progress  on 
the accessibility of spatial data, more efforts are needed.  

(217)  The 

Aarhus 

Convention 

(https://unece.org/environment-
policy/public-participation/aarhus-convention/text),  the  Access 
to  Environmental  Information  Directive  (Directive  2003/4/EC) 
(https://eur-lex.europa.eu/legal-
Inspire 
content/EN/TXT/?uri=CELEX:32003L0004) 
Directive  (Directive  2007/2/EC)  (https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32007L0002) together create a legal 
foundation for the sharing of environmental information between 
public authorities and with the public. 

and 

the 

(218)  These  guarantees  are  explained  in  the  European  Commission’s 
2017  notice  on  access  to  justice  in  environmental  matters 
(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:52017XC0818(02))  and  a  related 

Table 3: Denmark dashboard on implementation of the 
Inspire Directive, 2016–2023 

2016  2023 

Legend 

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

addressed 

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

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

efforts 

Effective  coordination  and 
data sharing 

Ensure 
effective 
coordination  

sharing 

Data 
without 
obstacle  

Inspire 
indicators 

■  ■ 

■  ■ 

performance 

(i)  Conformity 
of metadata  

■  ■ 

(ii)  Conformity 
of 
spatial 
datasets 

(iii) 
Accessibility  of 
spatial datasets 
through 
view 
and  download 
services 

(iv)  Conformity 
of 
network 
services 

■  ■ 

■  ■ 

■  ■ 

Source:  European  Commission,  ‘Denmark’,  Inspire  Knowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/denmark_en. 

Public participation 

Public involvement  at both the planning and the  project 
phase  maximises  transparency  and  social  acceptance  of 
programmes  and  projects.  Consultation  with  the  public 
(including  NGOs)  and  environmental,  local  and  regional 
authorities  is  a  key  feature  of  an  effective  impact 
assessment procedure. Such consultation also provides an 

2018 citizen’s guide (https://op.europa.eu/en/publication-detail/-
/publication/2b362f0a-bfe4-11e8-99ee-01aa75ed71a1/language-
en/format-PDF). 

(219)  This  EIR  focuses  on  the  means  used  by  Member  States  to 
guarantee  rights  of  access  to  justice  and  legal  standing  and  to 
overcome other major barriers to bringing cases on environmental 
protection. 

(220)  European  Commission, 

‘Denmark’, 

Inspire  Knowledge  Base, 

https://knowledge-base.inspire.ec.europa.eu/denmark_en. 
(221)  The  European  Commission provides  a  list  of  high-value  spatial 
datasets 
(https://github.com/INSPIRE-MIF/need-driven-data-
prioritisation/blob/main/documents/eReporting_PriorityDataList
_V2.1_final_20201008.xlsx). 

Environmental Implementation Review 2025 – Denmark 

 
 
 
 
Denmark  49 

slower  than  the  EU  average.  This  is  mainly  due  to  the 
scoping phase, which is slower than the EU average, and 
the EIA report, which is considerably slower than the EU 
average.  Effective  use  of  EU  procedures  can  positively 
influence  the  timely  approval  of  activities  underpinning 
the  decarbonisation  of  the  economy  on  the  way  to  net 
zero by 2050. 

A new report  is not  yet  available on the application and 
effectiveness of the SEA Directive in the EU. Nevertheless, 
a  support  study has been published with information by 
Member State (228). 

Planning  authorities  responsible  for  implementing  EIAs 
may  be  at  the  national,  municipality  or  local  level, 
depending  on  the  nature  of  the  project.  The  planning 
authority in question must publish the public consultation 
on  its  own  website,  and  the  process  may  be  conducted 
using the national portal Høringsportalen (229). The long-
term ambition is to make Høringsportalen the single point 
of  entry  for  all  public  consultations 
in  Denmark, 
irrespective  of  the  competent  authority  (government, 
national  authorities,  municipal  councils,  etc.).  Currently, 
the  use  of  the  portal  is  only  mandatory  for  state 
authorities 
in  all  EIA  and  SEA  procedures,  and  for 
municipalities and local authorities in a limited number of 
cases. The wide range of administrations responsible for 
EIA  and  SEA  procedures  results  in  a  lack  of  data  at  the 
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 
to 
incorrect 
transposition of the directive (230). 

infringement  procedure 

about 

an 

opportunity for public authorities and project promoters 
to  engage  with  the  public  actively  and  meaningfully  by 
making information on the likely significant effects widely 
available. If carried out with due diligence and taking into 
consideration  useful  public  input,  this  process  leads  to 
better-informed decision-making and can promote public 
acceptance.  Making 
increases 
stakeholder  involvement,  thus  lessening  resistance  and 
preventing (or minimising) litigation. On the other hand, it 
is paramount that the procedure is effective. 

information  available 

This  section  examines  how  public 
involvement  and 
transparency are ensured under two instruments, namely 
the Environmental Impact Assessment (EIA) Directive (222) 
and  the  Strategic  Environmental  Assessment 
(SEA) 
Directive (223). 

EU law provides for a flexible framework concerning EIAs. 
The aim of this framework is to ensure the application of 
the  necessary  environmental  safeguards,  while  enabling 
speedy  approval  of  projects.  The  Commission  has 
contributed to simplifying and accelerating permitting for 
renewable energy projects and continues to support the 
Member States in this regard (224). Denmark  has already 
taken  steps  for  renewable  energy  projects.  A  national 
energy  crisis  taskforce  (NEKST)  (225)  is  responsible  for 
identifying  and  removing  the  existing  barriers  for  these 
projects. This reform is part of the REPowerEU component 
in the Danish RRP (226). 

The average speed in the EU for issuing permits involving 
an  EIA  procedure 
is  20.6 months,  with  a  minimum 
duration  of  11.4 months  and  a  maximum  duration  of 
75.7 months (227).  The  duration  of  each  step  in  an  EIA 
report,  public 
process 
consultation, reasoned conclusion, development consent) 
varies considerably between Member States and projects. 
The  available  data  cover  all  the  steps  of  the  EIA  for 
Denmark and it shows that permit issuing in Denmark is 

scoping,  EIA 

(screening, 

(222)  Directive  2011/92/EU  of  the  European  Parliament  and  of  the 
Council of 13 December 2011 on the assessment of the effects of 
certain public and private projects on the environment (OJ L 26, 
28.1.2012, 
https://eur-lex.europa.eu/legal-
p. 1), 
content/EN/TXT/?uri=CELEX%3A32011L0092. 

(223)  Directive  2001/42/EC  of  the  European  Parliament  and  of  the 
Council of 27 June 2001 on the assessment of the effects of certain 
plans and programmes on the environment (OJ L 197, 21.7.2001, 
p. 30), 
https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32001L0042. 

(224)  Commission Staff Working Document  (SWD/2022/0149 final), 18 
May 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52022SC0149&qid=1653034229
953). 

2022, 

(225)  Danish  Ministry  of  Climate,  Energy  and  Utilities,  NEKST  -  den 
nationale  energikrisestab,  https://www.kefm.dk/klima/nekst-
den-nationale-energikrisestab. 

(226)  European Commission, Denmark’s recovery and resilience plan  - 
European  Commission.,  https://commission.europa.eu/business-
economy-euro/economic-recovery/recovery-and-resilience-
facility/country-pages/denmarks-recovery-and-resilience-
plan_en. 

Impact  Assessment 

(227)  European  Commission:  Directorate-General  for  Environment, 
Collection of information and data on the implementation of the 
(EIA)  Directive 
revised  Environmental 
(2011/92/EU) as amended by 2014/52/EU), Publications Office of 
the  European  Union,  Luxembourg,  2024,  Tables 5  and  6, 
https://op.europa.eu/en/publication-detail/-
/publication/8349a857-2936-11ef-9290-01aa75ed71a1/. 
(228)  European  Commission:  Directorate-General  for  Environment, 
Lundberg, P., McNeill, A., McGuinn, J., Cantarelli, A. et al., Study 
supporting  the  preparation  of  the  report  on  the  application  and 
effectiveness  of  the  SEA  Directive  (Directive  2001/42/EC)  –  Final 
study,  Publications  Office  of  the  European  Union,  2025, 
https://data.europa.eu/doi/10.2779/1615072 

(229)  https://hoeringsportalen.dk/. 
(230) 

(https://ec.europa.eu/atwork/applying-eu-

INFR(2019)2221 
law/infringements-
proceedings/infringement_decisions/?lang_code=EN&typeOfSea
rch=byDecision&active_only=0&noncom=0&r_dossier=INFR(202
2)2081&decision_date_from=&decision_date_to=&submit=Searc
h&langCode=EN&version=v1&refId=INFR(2019)2221&page=1&si
ze=10&order=ascending&sortColumns=refId). 

2025 Environmental Implementation Review – Denmark 

 
 
Access to justice 

Directive. 

Denmark  50 

Access to justice, guaranteed by Article 19(1) of the Treaty 
on  European  Union  and  Article 47  of  the  EU  Charter  of 
Fundamental Rights, is a fundamental right and part of the 
democratic process. It is vital to ensure the full application 
of EU law in all Member States and the legal protection of 
the  rights  of  individuals,  including  in  environmental 
matters.  Access  to  justice  is  essential  to  enable  judicial 
review of the decisions of public authorities and to allow 
the  correction  of  any  wrongdoing  committed  by  these 
authorities. 

This  section  provides  a  snapshot  of  the  state  of  play  of 
access to courts by the public, particularly when it comes 
to challenging plans, or the non-adoption of plans, under 
EU law, in the areas of water, waste, air quality and noise, 
irrespective of the form of the legal act (i.e. regulatory act 
or administrative decision). 

Individuals  and 
legal  persons, 
challenge environmental administrative decisions. 

including  NGOs,  may 

The  Danish  Act  on  Environmental  Assessment  applies  a 
very broad scope and definition covering any type of plan 
or programme, including informal plans or programmes. 
The public has no possibility to initiate an administrative 
review when it comes to regulatory decisions. 

In 2022, Denmark received priority actions to (i) improve 
access to courts by the public concerned when it comes to 
challenging  administrative  or  regulatory  decisions  and 
omission, in particular in relation to water, nature and air 
quality; and (ii) consider collating and publishing data from 
the  Høringsportalen  (national  hearings  portal)  on  public 
participation. 

2025 priority actions 

•  Make  spatial  data  more  widely  accessible  and 
prioritise environmental datasets in implementing the 
Inspire  Directive,  especially  those  identified  as  high-
value spatial datasets for implementing environmental 
legislation. (231). 

•  Ensure  that  relevant  information  on  EIA  and  SEA 
procedures 
(including  on  public  participation 
opportunities and on publication of final decisions) is 
electronically accessible in a timely manner, through at 
least  a  central  portal  or  easily  accessible  points  of 
access, at the appropriate administrative level. 

•  Ensure  correct  transposition  of  the  revised  EIA 

(231)  European Commission,  List of high value spatial data sets,  need-

driven-data-
prioritisation/documents/eReporting_PriorityDataList_V2.1_final
INSPIRE-MIF/need-driven-data-
· 
_20201008.xlsx  at  main 
prioritisation · GitHub 

(232)  The concept is explained in detail in the European Commission’s 
2018  communication  on  EU  actions  to  improve  environmental 

Compliance assurance 

Environmental  compliance  assurance  covers  all  work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air and nature, to manage waste (232) and to remedy any 
environmental  damage.  It  includes  measures  such  as  (i) 
compliance  promotion,  (ii)  compliance  monitoring  (i.e. 
inspections  and  other  checks),  (iii)  enforcement,  that  is, 
steps taken to stop breaches and impose sanctions, and 
(iv) ensuring damage prevention and remediation in line 
with the polluter-pays principle. 

Compliance promotion, monitoring and enforcement 

Non-compliance  with  environmental  obligations  may 
occur for different reasons, including poor understanding 
or  lack  of  acceptance  of  the  rules,  opportunism  or  even 
criminality.  Compliance  promotion  activities  help  duty-
holders to comply by providing information, guidance and 
other  support.  This  is  particularly  important  in  areas 
where new and complex legislation is put in place. 

When  inspections  and  other  control  activities  identify 
problems,  a  range  of  responses  may  be  appropriate, 
including 
the  use  of  administrative  and  criminal 
enforcement tools. 

The  priority  actions  identified  in  the  two  previous  EIRs 
were to (i) improve the availability of practical information 
for farmers on compliance with the Nature Directives and 
(ii)  improve  the  publicly  available  information  on  the 
follow-up  of  complaints  and  environmental  inspections, 
including  through  the  publication  of  regular  summary 
data. Concerning compliance promotion, monitoring and 
criminal  and  administrative  enforcement,  the  2022 
priority  actions  are  not  assessed  here  due  to  a  lack  of 
systematic  information.  Similarly,  the  Commission  is  not 
aware of whether information is easily available online at 
the national level for farmers regarding compliance with 
the Nitrates and Nature Directives, and hence the related 
2022 priority action is not assessed. 

The new EU Environmental Crime Directive 

The EU has recently strengthened its legal framework on 
tackling  the  most  serious  breaches  of  environmental 
obligations,  notably  by  the  adoption  of  the  new 

compliance  and  governance  (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52018DC0010)  and  the  related 
Commission 
(https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010). 

document 

working 

staff 

2025 Environmental Implementation Review – Denmark 

 
 
Environmental  Crime  Directive  (ECD)  (Directive  (EU) 
2024/1203) (233) and new sectoral legislation with stronger 
provisions  on  compliance  monitoring,  enforcement  and 
penalties. Issues important for the transposition and the 
implementation  of  the  relevant  new  instruments  are 
highlighted below; however, in accordance with Articles 1 
and  2  of  Protocol  No 22  on  the  position  of  Denmark 
annexed  to  the  Treaty  on  European  Union  and  to  the 
Treaty  on  the  Functioning  of  the  European  Union, 
Denmark  is  not  adopting  the  EU  criminal  legislative 
instruments and is not bound by them or subject to their 
application. 

The  new  ECD  replaced  the  2008  ECD  and  introduced 
several  new  offence  categories,  such  as  unlawful  ship 
recycling,  unlawful  water  abstraction,  and  serious 
breaches  of  EU 
legislation  on  chemicals,  mercury, 
fluorinated GHG and IAS of EU concern. It also covered the 
establishment  of  qualified  offences,  subject  to  more 
severe penalties where one of the offences defined in the 
directive  leads  to  serious  widespread  and  substantial 
damage  or  destruction  of  the  environment.  Concrete 
provisions on the types and levels of penalties for natural 
and  legal  persons  who  commit  an  offence  were  also 
introduced.  Other  provisions  will  help  considerably  to 
improve  the  effectiveness  in  combating  environmental 
crime  of  all  actors  along  the  enforcement  chain.  These 
include  obligations  to  ensure  adequate  resources  and 
investigative  tools,  specialised  regular  training  and  the 
establishment  of  cooperation  mechanisms  within  and 
between Member States as well as national strategies on 
combating environmental crime. 

coordination, 

Member  States,  but  not  Denmark,  are  required  to 
transpose the new ECD into national law by 21 May 2026 
and  to  take  additional  measures  to  more  effectively 
in  particular  through 
combat  environmental  crime, 
training, 
strategic 
approaches.  The  Commission  will  provide  support, 
including  by  facilitating  the  identification  and  sharing  of 
good practices. Member States are expected to ensure the 
necessary  resources  and  specialised  skills  required  and 
they are invited to encourage their authorities to support 
and cooperate with the recognised EU-level networks of 
environmental enforcement practitioners, such as the EU 

cooperation  and 

(233)  Directive  2024/1203/EU  on  the  protection  of  the  environment 
(https://eur-

criminal 

through 
law 
lex.europa.eu/eli/dir/2024/1203/oj/eng). 

(234)  https://www.impel.eu/en. 
(235) 

LIFE+SATEC 
(https://webgate.ec.europa.eu/life/publicWebsite/project/LIFE2
0-PRE-ES-000001/fight-against-environmental-crime-at-a-
strategic-level-through-the-strengthening-of-envicrimenet-
network-of-experts-in-environmental-criminal-investigations). 

project 

(236)  https://www.environmentalprosecutors.eu. 
(237)  https://www.eufje.org/index.php?lang=en. 
(238)  Directive 2004/35/EC on environmental liability with regard to the 
prevention and remedying of environmental damage (https://eur-

Denmark  51 

Network  for  the  Implementation  and  Enforcement  of 
Environmental Law (234), EnviCrimeNet (235), the European 
Network of Prosecutors for the Environment (236) and the 
EU Forum of Judges for the Environment (237). 

Although  Denmark  opted  out  of  the  new  ECD,  the 
directive  from  2008  continues  to  apply  to  Denmark;  in 
addition, 
Law 
the  European  Union  Agency 
Enforcement Cooperation and European Union Agency for 
Criminal Justice Cooperation mechanisms for cooperation 
on cross-border cases should be used more systematically 
for  environmental  offences,  and  cooperation  with  the 
aforementioned  EU-level  networks  of  environmental 
enforcement practitioners should be strengthened. 

for 

Environmental Liability Directive 

The  Environmental  Liability  Directive  (ELD)  (238)  aims  to 
ensure that environmental damage is remediated in kind 
at the expense of those who have caused it, in line with 
the polluter-pays principle. It helps to halt the net loss in 
biodiversity,  as  well  as  reducing  the  number  of 
contaminated  sites  and  protecting  the  environmental 
quality of groundwater and surface waters. The ELD is a 
cross-cutting 
for  better 
tool  and  a  key  enabler 
implementation of EU environmental law. 

The  ELD  addresses  cases  of  significant  environmental 
damage  to  protected  species  and  natural  habitats,  and, 
when caused by operators carrying out certain potentially 
hazardous  activities,  also  damages  to  water  and  to  soil. 
The  Commission  has  the  legal  obligation  to  periodically 
evaluate  the  ELD.  The  ELD  has  undergone  the  second 
evaluation (239), which will be finalised in 2025, and which 
was  supported  by  an  external  study (240),  containing, 
among  other  things,  evidence,  views,  reports  and  other 
relevant information gathered from different stakeholder 
groups, including Member States. 

indicators 

One  of  the  most  relevant 
in  assessing 
implementation  and  enforcement  of  the  ELD  is  the 
number  of  environmental  damage  cases  handled  under 
the  ELD,  especially  when  this  number  is  compared  with 
the  previous  reporting  period.  Fewer  ELD  cases  were 
reported in the second reporting period (2013–2022) than 
in  the  first  one  (2007–2013).  However,  the  downward 

lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02004L0035-20190626). 
(239)  Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025.  

(240)  European Commission: Directorate-General for Environment and 
Fogleman,  V.,  Study 
in  support  of  the  evaluation  of  the 
Environmental  Liability  Directive  and  its  implementation –  Final 
report,  Publications  Office  of  the  European  Union,  Luxembourg, 
2024, 
https://op.europa.eu/en/publication-detail/-
/publication/006d90e5-980a-11ef-a130-
01aa75ed71a1/language-en. 

2025 Environmental Implementation Review – Denmark 

 
 
tendency  in  the  number  of  ELD  occurrences  and  their 
overall low number do not necessarily mean that the ELD 
has  achieved  its  objectives,  as  it  needs  to  be  compared 
with the overall number of environmental damage cases, 
some  of  which  may  have  been  handled under  the  other 
liability instruments. 

national rules relating to the implementation of the ELD 
and  present  recommendations  for  strengthening  their 
application  and  efficiency, 
inter  alia, 
recommendations  for  a  national  scheme  on  mandatory 
financial  security  for  ELD  liabilities.  The  committee  is 
expected to deliver its report by the end of 2025. 

including, 

Denmark  52 

The ELD has not always been effective in ensuring that the 
polluter  pays,  because  the  liable  operators  often  lack 
financial  capacity  to  carry  out  remediation  measures. 
While the ELD does not provide for a mandatory financial 
security  system,  it  explicitly  calls  for  Member  States  to 
financial  security 
encourage 
instruments  and  markets,  with  the  aim  of  enabling 
operators  to  use  financial  guarantees  to  cover  their 
responsibilities under this directive. 

the  development  of 

From  1 May  2013  to  31 December  2021,  Denmark 
reported  only  one  occurrence  of  environmental  damage 
under the ELD (water damage). No environmental damage 
under  the  ELD  was  reported  in  the  previous  reporting 
period.  For  comparison,  in  Denmark,  there  were  3 114 
environmental 
of 
municipalities  that  are  also  the  primary  ELD  authorities 
have identified such cases) between 1 July 2008 (when the 
ELD was transposed into Danish law) and 15 August 2011. 
The municipalities screened 1 187 of those occurrences to 
determine whether national ELD legislation applied. 

occurrences 

damage 

(81 % 

Denmark has not introduced mandatory financial security 
for  ELD  liabilities.  Environmental  insurance  policies  for 
remediating  all  types  of  on-site  and  off-site  pollution, 
including  primary,  complementary  and  compensatory 
remediation under the ELD, are widely available. Various 
policies  cover  both  gradual  and  sudden  accidental 
pollution, while others cover only sudden and accidental 
pollution.  Environmental  extensions  to  general  liability 
policies  often  cover  remediation  of  off-site  land/soil 
pollution resulting from sudden and accidental incidents 
on an insured site and some also cover remediation of on-
site  pollution.  However,  these  extensions  typically  have 
low  sublimits  and  do  not  cover  complementary  or 
compensatory  remediation  under  the  ELD.  Additionally, 
environmental  extensions  to  property  policies  are 
available, covering on-site land/soil pollution from sudden 
and accidental incidents. However, the demand for all the 
abovementioned instruments is low. 

In  December  2024,  the  Danish  Minister  of  Environment 
and Gender Equality appointed an external committee of 
national 
university 
professors,  governmental  employees  etc.)  to  review  the 

(practitioners/lawyers, 

experts 

(241)  See 

the  European  Commission  web  page  on  Compact 
(https://reform-support.ec.europa.eu/public-administration-and-
governance-coordination/enhancing-european-administrative-
space-compact_en). 

(242)  See 

the  European  Commission  web  page  on 

the  TSI 

(https://commission.europa.eu/funding-tenders/find-

Two previous EIRs identified a priority action on improving 
the information provided on ELD cases, including data on 
costs.  There  is  no  information  available  regarding  the 
progress made by Denmark. 

2025 priority action 

• 

Encourage the use of training programmes provided 
by  the  Commission  (or  developed  at  the  national 
level)  covering  the  ELD  and  its  interactions  with  the 
other national liability related instruments, to ensure 
more  efficient  ELD  implementation,  improve  the 
expertise  of  the  competent  authorities  and  raise 
awareness among all stakeholder groups. 

EU-supported environmental capacity building 

The Commission’s 2023 Compact (241) initiative to enhance 
the administrative space identifies the capacity to lead the 
green transition as one of three key pillars, along with the 
public  administration  skills  agenda  and  the  capacity  for 
Europe’s Digital Decade. Compact also recognises the role 
of  the  EIR  reporting  tool  in  improving  environmental 
governance. The two main capacity-building opportunities 
for 
the  European 
Commission  are  the  TSI (242)  and  the  TAIEX-EIR  PEER  2 
PEER tool (243). The technical assistance available through 
the cohesion policy is subject to shared management and 
is not dealt with in this subsection. 

the  environment  provided  by 

The Commission’s technical support instrument 

The  TSI  provides  Member  States  with  tailor-made 
technical expertise on the design and implementation of 
reforms.  The  support  is  demand  driven  and  does  not 
require national co-financing. 

The Commission’s TSI had annual calls in 2021, 2022, 2023, 
2024  and  2025.  The  following  environment-related 
projects have been selected for Denmark: 

•  Digitalizing  Monitoring  of  East  Atlantic  Flyway, 
Ministry  of  the  Environment  and  Food  and  the 
Environmental  Protection  Agency 
(2022),  multi-
country project with Germany and the Netherlands. 

funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en). 

(243)  See the European Commission web page on the TAIEX-EIR PEER 2 
(https://environment.ec.europa.eu/law-and-

PEER 
governance/environmental-implementation-review/peer-2-
peer_en). TAIEX: Technical Assistance and Information Exchange. 

tool 

2025 Environmental Implementation Review – Denmark 

 
 
•  Transition  of  the  Danish  industry  towards  a  circular 
and resilient economy and a workforce with green and 
digital skills, Danish Business Authority (2023). 

• 

• 

•  One-stop-shop and regulatory sandboxes for the green 
transition  in  Denmark,  Danish  Business  Authority 
(2024). 
Support for the Preparation of Social Climate Plans for 
Denmark,  Danish  Ministry  of  Climate,  Energy  and 
Utilities (2024). 
Integrated 
informs 
adaptive  management  of  coastal  wetlands,  Danish 
Ministry  of  Green  Transition,  Agency  for  Green 
Transition  and  Aquatic  Environment  –  Denmark 
(2025). 

environmental  monitoring 

Denmark  53 

environmental 
States (244). 

legislation  and  policy 

in  all  Member 

Workshops involving Denmark are as follows: 

•  Climate adaptation and blue infrastructure (30 May - 1 

June 2022). 

•  Circular Economy (in the Irish Midlands) (4-6 October 

2022). 

•  Future  challenges  for  air  protection  (24  November 
2022) in collaboration with the Czech EU presidency. 
•  Making  space  for  biodiversity:  regional  action  to 
mainstream  biodiversity  and  empower  stakeholders 
(21-23 March 2023). 

•  Biodiversity, nature conservation and large predators 

(4-6 June 2024). 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

•  Measures  to  reduce  air  pollution  in  transport  and 

The Commission launched the TAIEX-EIR PEER 2 PEER tool 
in 2017. It aims to facilitate peer-to-peer learning among 
Member  States’  environmental  authorities  through 
workshops  (single  or  multi-country),  expert  missions 
(where  a  delegation  of  experts  travels  to  the  requesting 
institution) and study visits (where a delegation from the 
requesting institution travels to a host country). Flagship 
multi-country  workshops  are  those  requested  by  the 
European  Commission  to  present  new  and  upcoming 

residential energy (11-13 June 2024). 

•  Online  platforms:  EU  Batteries,  Packaging  and 
Packaging Waste Regulation (28-29 October 2024). 

Denmark  was  involved  in  an  expert  mission  on  the  air 
emissions  inventory  and  assessment  of  the  impact  of 
policies and measures on emissions (15–17 May 2023). It 
did not host any study visits from mid-May 2022 to the end 
of October 2024. 

(244) 

flagship  multi-country  workshops    in  the  reporting  period  are: 
Recast  Drinking    Water  Directive  (3  April  2025);  Environmental 
compliance  and  governance  (18  March  2025);  Planning  of 
Renewable  Energy  Projects  (20  February  2025);  Air  Quality: 
Implementation  of  the  revised  Air  Quality  Directive  (16  January 
2025); Industrial safety: awareness raising of emerging risks linked 
with climate change and decarbonation (12 December 2024); Air 
quality: 
further 
implementation  of  the  NEC  Directive  to 
mainstream  air  and  broader  pollution  reduction  in  agricultural 
policy  (25  September  2024);  Industrial  emissions  transposition 
and implementation of the revised Directive (12 September 2024); 
Noise progress towards meeting Member States’ noise limit values 
and  EU  reduction  targets  (5  June  2024);  Best  practice  use  of 

environmental  footprint  methods  on  the  EU  market  (30  May 
2024);  Sustainable  finance  (9  November  2023);  Textile  waste 
separate collection, treatment and markets (3 October 2023); EU 
environmental  funding  and  support  (13  June  2023);  Advisory 
service for businesses to go circular (24 April 2023); Digital product 
passport implementation (6 December 2022); Public involvement 
in  planning  and  approval  of  renewable  energy  projects  (17 
November 2022); Environmental compliance and governance (14 
November  2022);  Biowaste  management  (19-20  September 
2022); Renewable energy projects: permitting granting processes  
(13 June 2022); Industrial safety (12 December 2024). N.B. the first 
flagship workshop on Zero Pollution for Air, Water and Soil, took 
place 9 February 2022. 

2025 Environmental Implementation Review – Denmark 

 
 
 
 
 
 
Denmark  54 

Annex 

2025 priority actions 

Circular economy and waste management 
Transitioning to a circular economy 

•  Adopt measures to increase the circular material use rate. 

Waste management 

•  Further shift reusable and recyclable waste away from incineration, including through economic instruments. 
• 
• 
• 

Improve municipal waste preparation for reuse and recycling. 
Increase the collection and recycling rate of waste electronic and electric equipment (WEEE). 
Invest in waste prevention measures to reduce the total amount of waste generated. 

Biodiversity and natural capital 
Nature protection and restoration – Natura 2000 
•  Finalise the establishment of site-specific conservation objectives and measures for all Natura 2000 sites (including 

by adopting their management plans) and ensure their effective implementation. 

Recovery of species 
•  Continue supporting the integration of biodiversity actions into other policies, e.g. energy, agriculture, fisheries, 
forestry,  urban  and  infrastructure  planning  and  sustainable  tourism,  and  promote  communication  between 
stakeholders. 

•  Reinforce action  for habitats and species in unfavourable conservation status, for example through restoration 

measures, increased connectivity, better policy coordination and integration, and increased funding. 

Recovery of ecosystems 

Agricultural ecosystems 
• 

Implement eco-schemes and agri-environmental measures and practices to address the environmental needs of 
Denmark. 

Wetlands/peatlands 
• 

Implement  peatland  conservation  and  restoration  measures  and  include  such  measures  and  objectives  in  the 
national restoration plans. 

Forest ecosystems 
• 

Improve conservation status of forests by promoting sustainable forest management and ensuring compliance with 
the Habitats Directive before granting/renewing permits for forest logging. 

Marine ecosystems 
•  Report its updates on the state of its marine waters, its targets and its determinations of GES which are expected 
to include any threshold values for the descriptors in the MSFD that may have been established in cooperation with 
other Member States at the EU or regional level. 

Prevention and management of invasive alien species 
•  Step up implementation of the IAS Regulation, including with regard to enforcement and capacity of inspection 

authorities. 

Zero pollution 
Clean air 

•  As part of the NAPCP, take action towards reducing emissions of air pollutants. 
•  Ensure full compliance with the current AAQD standards, also in light of future stricter requirements under the 

revised AAQD. 

Industrial emissions 

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Denmark  55 

•  Engage  with  industry  and  environmental  NGOs  to  ensure  proper  contribution  to  and  implementation  of  BAT 

conclusions and ensure timely update of permits following publication of BAT conclusions. 

•  Ensure effective public participation and access to justice in relation with the IED. 

Major industrial accidents prevention – Seveso 
•  Strengthen compliance with requirements on safety measures to prevent major accidents and ensure appropriate 
preparedness and response in relation to UTEs, in particular as regards reviewing, testing and updating of EEPs, at 
intervals of no more than three years. 

•  Ensure access to transparent and clear information towards citizens on risks and behaviour in case of accidents. 

•  Complete and implement action plans on noise management. 

Noise 

Water quality and management 

Water Framework Directive 
• 

Improve  river  continuity  and  ecological  flows,  boosting  efforts  on  nature-based  solutions  to  reduce 
hydromorphological pressures. 

Improve the classification of water bodies and strengthen monitoring systems. 

•  Reduce pollution from nutrients, chemicals, metals and saline discharges. 
•  Better justify exemptions to the achievement of good status. 
• 
•  Develop more robust programmes of measures, tackle obstacles identified in the implementation of measures and 
ensure adequate financing for implementation, including through better use of the cost recovery and polluter pays 
principle. 
Floods Directive 
•  FRMPs should provide details on how the FHRMs were used in the choice of measures and how to consider pluvial 

flooding. 

•  Better  explain  the  choice  and  implementation  of  flood  prevention  and  protection  measures  (prioritisation, 

monitoring, costs of measures). 

Drinking Water Directive 
•  Take actions to ensure full compliance with the Drinking Water Directive. 
Nitrates Directive 
•  Tackle  nutrients  pollution,  especially  nitrates  from  agriculture  through  the  implementation  of  the  Nitrates 

Directive. 

Chemicals 
•  Upgrade the administrative capacities in implementation and enforcement towards a policy of zero tolerance for 

• 

• 

• 

non-compliance. 
Increase involvement in the activities of the Forum for Exchange of Information on Enforcement of the European 
Chemicals Agency, including in the coordinated enforcement projects, called REFs. 
Increase  customs  controls  and  controls  of  products  sold  online  with  regard  to  compliance  with  chemicals 
legislations. 

Climate action 
Implement all polices and measures that are needed to achieve targets laid down in the Effort Sharing Regulation 
(ESR) and the Land Use and Land-Use-Change and Forestry (LULUCF) Regulation. More detailed priority actions are 
set out in the assessment of the final National Energy and Climate Plan (NECP). 

Financing 
•  Use  more  national  funding  (for  instance  by  increasing  taxes  in  favour  of  the  environment  and  reducing 

environmentally harmful subsidies), EU funding and private funding to help close the investment gap. 

Environmental governance 
Information, public participation and access to justice 
•  Make  spatial  data  more  widely  accessible  and  prioritise  environmental  datasets  in  implementing  the  Inspire 
Directive, especially those identified as high-value spatial datasets for implementing environmental legislation. 

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Denmark  56 

•  Ensure that relevant information on EIA and SEA procedures (including on public participation opportunities and 
on publication of final decisions) is electronically accessible in a timely manner, through at least a central portal or 
easily accessible points of access, at the appropriate administrative level. 

•  Ensure correct transposition of the revised EIA Directive. 

Compliance assurance 
•  Encourage  the  use  of  training  programmes  provided  by  the  Commission  (or  developed  at  the  national  level) 
covering the ELD and its interactions with the other national liability related instruments, to ensure more efficient 
ELD  implementation,  improve  the  expertise  of  the  competent  authorities  and  raise  awareness  among  all 
stakeholder groups. 

2025 Environmental Implementation Review – Denmark