DENMARK Trends and Developments Contributed by: Flemming Elbæk, Helle Ina Elmer, Mads Lund and August Reinhold, HaugaardBraad
HaugaardBraad Skibbrogade 3, 3 9000 Aalborg Denmark Tel: +45 98 77 50 30 Email: kontakt@haugaardbraad.dk Web: www.haugaardbraad.dk
Introduction Environmental law in Denmark is ever-evolving. Driven by a mix of national and EU priorities and legislation, the Danish environmental law framework is increas- ingly complex and diffuse. In recent years, there has been heightened focus on water quality, chemicals (especially PFAS) and permitting for the energy tran- sition. In Denmark, we are seeing more prescriptive environmental standards, closer scrutiny in permit- ting and EIA practice and sharper enforcement on green claims and consumer transparency. New fiscal measures – notably the landmark agreement to price agricultural emissions from 2030 – signal that climate policy is shifting from incentives toward binding obli- gations with real cost implications. Appeal boards are also applying tighter scrutiny to Habitats Directive Annex IV species protection and to the Water Frame- work Directive, and these issues are increasingly determinative in screenings and permit conditions. In parallel, industrial permitting is tightening: the Indus- trial Emissions Directive (IED) was amended in 2024 (Directive (EU) 2024/1785), expanding scope (battery production, more intensive pig/poultry units, selected mining), integrating climate protection into BAT, and adding new obligations that run through 2030–2035. What follows distils the key developments shaping Danish environmental law in 2025: PFAS regulation, water policy, nature protection, the energy transition, industrial installations, environmental liability, agricul- ture, circular economy and product policy, and green marketing and consumer enforcement. PFAS Regulation PFAS remains the subject of sustained political and public attention. We are seeing continued enforcement
around very low drinking-water thresholds, intensified monitoring regimes and visible clean-up programmes at legacy hotspots. The debate is not just technical – cost allocation and responsibility for historic contami- nation are increasingly contentious and have become politically sensitive. During 2025, the Danish authori- ties tightened pesticide approvals where degradation pathways generate persistent PFAS, and Denmark continues to support EU-level restrictions (including the firefighting-foam phase-out already in force and the broader “universal” PFAS restriction currently under evaluation at EU level). In 2025, the Danish Environmental Protection Agency banned/withdrew 33 PFAS-related pesticide products, citing unaccep- table groundwater contamination risk. Practically, this means more product withdrawals, more soil and groundwater investigations and greater expectations for operators to present remediation plans when PFAS appear in data. Water Policy In Denmark, the Water Framework Directive (Direc- tive 2000/60/EC) is increasingly present and relevant in permitting, planning and enforcement. In April 2025, the Danish government announced a nitrogen- reduction package for 16 fjords and coastal waters to meet water-quality objectives by the end of 2027, accompanied by stricter wastewater requirements on utilities. In 2025, the Danish Parliament enacted a law on the supply of technical water ( Lov 2025-06-20 nr 700 om forsyning med teknisk vand ), mandating a separate, commercially based utility stream intended to relieve pressure on drinking-water resources and to support
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