DENMARK Trends and Developments Contributed by: Flemming Elbæk, Helle Ina Elmer, Mads Lund and August Reinhold, HaugaardBraad
Conclusion Looking ahead to the next 12–24 months, the centre of gravity shifts from implementation to enforcement. Expect the recast Urban Wastewater Treatment Direc- tive (Directive (EU) 2024/3019) to lock in extended producer responsibility for micropollutants and drive new cost-sharing models. The Ambient Air Quality Directive (Directive (EU) 2024/2881) will drive tighter local plans affecting transport and permitting. On EU product policy, delegated acts under the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40) and the Ecodesign for Sustainable Prod- ucts Regulation (Regulation (EU) 2024/1781) will force SKU-level redesigns and lay the groundwork for Digital Product Passports. The EU Deforestation Regulation (Regulation (EU) 2023/1115) will move from onboard- ing to inspections. Transposition of the Industrial Emis- sions Directive as amended (Directive (EU) 2024/1785) will widen permit scope, raise sanction exposure and start the transition to electronic permitting. Offshore wind industry will continue to recalibrate, while carbon capture utilisation and storage licensing broadens. In both areas, appeals will continue to stress-test wild- life baselines, cumulative-effects analysis and “no deterioration/no adverse effects” reasoning. Add in enforcement under the Battery Regulation (Regulation (EU) 2023/1542), the Waste Shipment Regulation’s new digital processes (Regulation (EU) 2024/1157), the Carbon Border Adjustment Mechanism moving from reporting to surrender (Regulation (EU) 2023/956) and early obligations under the Methane Regulation (Regulation (EU) 2024/1787). The practical playbook is unchanged: build better datasets, document choices, align contracts with cost-sharing and sanctions risk, and assume scrutiny.
tiles, furniture), so Danish manufacturers and import- ers in those sectors should prepare early. The Battery Regulation (Regulation (EU) 2023/1542) brings circularity, safety and due-diligence duties across all battery types. Denmark’s new statutory order on batteries took effect on 18 August 2025, aligning national enforcement with EU rules on col- lection, treatment, recycling, producer responsibility and safety/labelling. This matters for BESS projects, mobility and electronics, including producer registra- tion and contracting requirements for collection sites. The revised Waste Shipment Regulation (Regula- tion (EU) 2024/1157) tightens controls on extra-EU exports, accelerates digital notification/traceability and enhances enforcement co-operation. It is expect- ed to cause higher compliance burdens for shippers and brokers. In Denmark, the Danish Environmental Protection Agency is the competent authority for enforcing the Waste Shipment Regulation and has published a Q&A on the new timelines and the incom- ing EU-wide digital system. The EU Deforestation Regulation (Regulation (EU) 2023/1115) is moving from paper to practice. For in- scope commodities (cattle, cocoa, coffee, oil palm, rubber, soy, wood), 2025 is the first sustained year of Danish implementation for larger operators, with checks focused on due-diligence statements, geolo- cation and risk assessment. Smaller operators follow under staggered dates.
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