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Danish Shipping

Danish Shipping is the Danish shipowners' association representing the interests of the maritime industry.

Lobbying Activity

Meeting with Martin Engell-Rossen (Cabinet of Commissioner Dan Jørgensen)

10 Dec 2025 · EU in the new global context

Meeting with Sigrid Friis (Member of the European Parliament)

25 Nov 2025 · Low carbon fuel, ETS and CBAM

Danish Shipping Urges Lighter Compliance Burden in Foreign Subsidies Rules

18 Nov 2025
Topic — Review of 2022 EU regulation on foreign subsidies distorting the internal market.
Message — The organization requests simplified thresholds, higher de minimis levels, and exemptions for recurring transactions. They emphasize that regulatory frameworks must not unduly burden European companies operating globally, and urge targeted risk-based approaches that distinguish legitimate international support from harmful distortive subsidies.123
Why — This would reduce compliance costs for shipping companies with complex global operations.456
Impact — European competitors in markets where Danish shipping companies receive foreign subsidies.7
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Danish Shipping urges dedicated maritime funding in EU budget

12 Nov 2025
Topic — EU's next long-term budget framework for competitiveness and industrial policy.
Message — The organization requests a targeted maritime window under the Competitiveness Fund to finance alternative fuels, energy efficiency technologies, and port infrastructure. They want simplified access to EU funding and support for maritime SMEs and innovation pipelines.123
Why — This would accelerate decarbonization while safeguarding the international competitiveness of European shipping companies.45
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Meeting with Tilly Metz (Member of the European Parliament, Rapporteur) and Humane World for Animals Europe and VIER PFOTEN International

12 Nov 2025 · Animal transport

Meeting with Niels Flemming Hansen (Member of the European Parliament)

5 Nov 2025 · CCS-workshop

Meeting with Marianne Vind (Member of the European Parliament)

17 Oct 2025 · Transport

Meeting with Rasmus Nordqvist (Member of the European Parliament)

13 Oct 2025 · Introduction meeting

Danish Shipping opposes any changes to passenger transport VAT rules

8 Oct 2025
Topic — EU review of VAT rules for travel agents and passenger transport sectors.
Message — The organization requests that the current VAT system for passenger transport remains unchanged. They argue the existing framework is efficient and fair, and that any modification would create unnecessary administrative burdens and market distortions.12
Why — This would preserve administrative efficiency and avoid new compliance costs for shipping operators.3
Impact — Member states lose potential tax revenue from eliminating the Article 148 exemption.4
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Response to EU Drugs Strategy and European Action Plan Against Drug Trafficking

24 Sept 2025

Danish Shipping supports the EU Maritime Security Strategy (EUMSS) and the continuous efforts of the EUMSS Working Party to revise the strategys action plan. Together with the public-private partnership of the European Ports Alliance and the EU roadmap to fight drug trafficking and organised crime, the EU is on the right track to address the growing issue of illicit drug trafficking in the maritime domain. Danish Shipping finds it pivotal to raise awareness among EU Member States of the scale and complexity of maritime drug trafficking. The European Ports Alliance has unequivocally demonstrated its crucial role and undeniable impact. The shared best practise of Alliance highlights the need for enhanced cooperation between public authorities and private industry and the general support of the industry regarding the EUs ongoing efforts to step up maritime security under the EUMSS framework. Danish Shippings concrete recommendations for the revised action plan: The long tail of tackling organised crime. The European Union Drugs Agency (EUDA) and the World Customs Organization reported in June 2025 that seaports that are currently not members of the European Ports Alliance are significant targets for maritime drug trafficking indicating the potential importance of expanding the cooperation and knowledge sharing. 30+ ports participate in the European Ports Alliance, but the best practise of the alliance should be shared with much more and at least the 320+ seaports of the EU's trans-European transport network (TEN-T). A solution could be national public-private partnership Member State platforms to secure closer cooperation and better data sharing between ports, industry and authorities to effectively tackle the problem of illicit drugs. Protect employees and deter infiltration by development of consistent security standards and guidelines. Firstly, by securing ports and terminals against threats by introducing common standards for mandatory background screenings for key port staff in major container and ro-ro ports across the EU, conducted by police or competent national authorities. Secondly, by developing guidance and legal certainty on the use of biometric access in ports for certain high security facilities. Promote a single point of contact model between ports and enforcement bodies. Drawing on best practices such as the model in the Netherlands, which combines customs, fiscal investigation, seaport police, and prosecution authorities in a structured partnership. This should be combined with strengthened operational cooperation between industry and authorities through structured data exchange, joint risk profiling, and regular assessments to improve detection and prevention. Strengthened police cooperation with third-party countries. Ideally, drugs and other contraband would not reach European shores and ports. The EU should support third countries, for example in Latin America, in enhancing their port security. Closer police cooperation between Europol and countries known to be major points of origin for drugs, including transit ports before arriving to EU, could also play an important role against drug trafficking. The upcoming EU Ports Strategy should include the above recommendations together with the valuable experience and best practices developed through the European Ports Alliance together with effective measures against drug smuggling as contraband smuggling remains a persistent threat to European supply chains and public safety. Read more in Danish Shipping's Policy Paper on contraband trafficking.
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Meeting with Torsten Klimke (Head of Unit Mobility and Transport) and A.P. Møller - Mærsk A/S

24 Sept 2025 · Discussion on strategic ports aspects

Danish Shipping urges EU to back global maritime carbon pricing

11 Sept 2025
Topic — The consultation outlines the EU's global climate and energy strategy for 2025-2029.
Message — The organization calls for a single international regulatory framework for shipping. They also advocate for binding renewable energy commitments in EU trade agreements.123
Why — A global carbon price prevents a fragmented market and ensures international shipping competitiveness.4
Impact — Global trade partners could face restricted market access due to legally binding commitments.5
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Meeting with Niels Flemming Hansen (Member of the European Parliament)

5 Sept 2025 · Shipping

Danish Shipping calls for EU to fund maritime green transition

3 Sept 2025
Topic — The initiative establishes a strategic framework for energy transitions in aviation and waterborne transport.
Message — Danish Shipping calls for a massive scale-up of green fuels and mandatory production targets. They advocate earmarking EU ETS revenues for decarbonization to close the fuel price gap. They propose using public entities to guarantee fuel contracts and minimize private market risk.123
Why — Ring-fenced funding and public guarantees would reduce the high cost of adopting green fuels.4
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Danish Shipping demands investment tools to reach 2040 climate targets

1 Sept 2025
Topic — The initiative amends the European Climate Law to include the 2040 target.
Message — Danish Shipping calls for swift deployment of maritime allowances and recognition of onboard carbon capture. They advocate for investment plans that de-risk green fuel production and infrastructure.12
Why — Financial support and regulatory recognition would lower costs and provide market certainty for shipowners.3
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Meeting with Anders Vistisen (Member of the European Parliament)

13 Aug 2025 · Danish Shipping

Danish Shipping Urges Green Investments and Open Port Competition

17 Jul 2025
Topic — The EU Ports Strategy addresses security, competitiveness, and energy transition within maritime hubs.
Message — The organization calls for maintaining maritime state aid guidelines and avoiding protectionist clauses. They recommend mandatory background screenings for port staff and faster permitting for infrastructure projects.123
Why — Avoiding protectionism allows shipping companies to source cheaper vessels from more efficient global shipbuilders.45
Impact — European shipbuilders lose out on domestic market protections and mandatory local sourcing requirements.6
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Response to EU industrial maritime strategy

17 Jul 2025

Danish Shipping welcomes the opportunity to contribute to the European Commissions consultation on the EU Industrial Maritime Strategy. Danish shipping companies are among the global frontrunners in decarbonisation, digitalisation, and maritime innovation, and we are strongly committed to supporting a competitive and sustainable European maritime industry. Danish Shipping fully support the Commissions ambition to strengthen Europes maritime sector as a strategic industrial ecosystem. However, achieving this requires a policy framework that ensures international competitiveness, drives the uptake of green fuels and technologies, enables efficient and secure infrastructure and the offshore segment, and secures robust and resilient supply chains. In this response, we outline key priorities and recommendations that we believe should form part of a comprehensive and forward-looking maritime industrial strategy for the EU. We support the objectives of the strategy and emphasise: 1. A global level playing field for shipping: EU should maintain the guidelines on state aid to maritime transport to ensure stability and predictability for shipping companies. As a global industry, shipping must remain internationally competitive. Protectionism and 'Made in Europe' clauses should therefore be avoided. The competitiveness of intra-EU/short sea shipping should be addressed in the strategy by enhancing the competitiveness and market access across the EU for all maritime services, i.e. national tenders, seafarer access, and harmonisation of VAT, customs, and harmonised administrative procedures between ports; 2. EU-wide investment in green fuels, digitalisation, and infrastructure: The supply of green fuels is still far below demand, and the cost gap with fossil fuels remains a major barrier. Increased funding is needed through targeted support, and EU ETS revenues should be reinvested in maritime green transition projects to minimise this gap. An EU offshore wind strategy should cover the full value chain - from production to maritime logistics. Permitting must be accelerated for projects involving offshore service vessels, and tax and crew rules simplified to ease cross-border operations. The EU should also develop an internal market for CO2 by harmonising rules for maritime transport, storage, and handling of captured carbon; 3. Integrated, IMO-aligned climate policies: Once the IMO Net-Zero Framework agreement is adopted in October 2025, EU measures like the ETS must complement - not conflict with - global regulation and guidelines. Policy design should allow flexibility to integrate future IMO decisions and avoid regulatory fragmentation; 4. Maritime security and supply chain resilience: Shipping is vital to global trade and must be protected as critical infrastructure. EU-wide surveillance and contingency planning are needed to address threats from piracy to hybrid risks in areas like the Baltic Sea. The strategy should also strengthen supply chain resilience amid growing geopolitical tensions along key maritime routes. Protectionist approaches to shipbuilding impose unnecessary burdens on European shipping companies, undermining the competitiveness of European maritime transport. It is important to note that shipbuilding varies greatly depending on the vessel type - for instance, constructing cruise ships is very different from building container ships. It should remain voluntary for Member States to pursue national initiatives in the shipbuilding sector - just as several countries are already doing today. For the full answer to this consultation, we refer to the attached document.
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Danish Shipping urges alignment of EU carbon rules for ships

8 Jul 2025
Topic — The European Commission is reviewing the emissions trading system for maritime transport.
Message — The organization calls for a unified framework to avoid double regulation and administrative burdens. They propose earmarking revenues for green fuel subsidies and expanding the system's scope to include smaller vessels.123
Why — Harmonized rules and earmarked funding would reduce compliance costs and subsidize fuel transitions.45
Impact — Smaller vessel operators would face new costs, and national budgets would lose revenue.67
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Danish Shipping urges EU to prioritize maritime CO2 transport

10 Jun 2025
Topic — The EU initiative aims to accelerate industrial decarbonisation and boost competitiveness.
Message — Establish a common internal market for CO2 transport to eliminate regulatory barriers and bilateral agreements. Move CO2 transport from roads to sea to reduce costs like noise and road wear. Set clear storage targets for 2040 to provide long-term investment certainty.123
Why — This would foster economic growth through new maritime activities and specialized CO2 shipping vessels.4
Impact — Road transport operators would see reduced demand as carbon management shifts toward sea transport.5
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Response to Foreign Subsidies Guidelines

2 Apr 2025

Danish Shipping would like to thank the authorities for the opportunity to provide feedback to this consultation, in relation to the upcoming Commission issuing of guidelines in January 2026. General remarks: Danish Shipping would first and foremost like to emphasize, that we are firm supporters of a European Union which manages to balance the need for support of EU based businesses in their endeavors on international markets with the need to protect the integrity of the European Single Market. For Danish Shipping it will be of the utmost importance, that any guidelines for the FSR does not end up restricting the competitiveness of EU-based businesses that engage in international or global operations. The upcoming guidelines must not end up presenting global operators with additional burdens, whether they be financial or administrative. It is also important that the FSR guidelines do not provide disincentives for European operators in their international growth. This applies especially to those actors that are in sectors which are still subject to gov-ernment support e.g. renewable energy. But also, on a more general level. More importantly, it is essential that any guidelines linked to the FSR seeks to have as targeted an impact as possible. Again stressing the understandable desire to maintain the integrity of the Single Market and thus protect the competitiveness of EU based businesses it is equally important not to economically punish thriving EU based busi-nesses that operate on a global scale. For instance: EU based companies, operating internationally, that either directly receive or in-directly benefit from foreign subsidies/financial con-tributions should not be penalized when also operating in the EU. Especially companies operating in sectors, e.g. renewable energy, where state aid is a steady component of the pricing mechanisms in an often immature sector. Additional clarity on financial contributions: Danish Shipping believes that it will be important to introduce a more narrow and targeted guideline for the term financial contributions. In the current regulation, it appears that one of the most encompassing tasks will the gathering and accounting of financial contributions received globally over a three-year period. This will undoubtedly be the case for many EU based businesses with international/global activities. For that reason, it will be imperative that the Commission develops a guideline for the compliance work related to financial contributions otherwise the amount of work needed to fulfill these tasks will be enormous. Important not to introduce unnecessary bureaucracy when reporting on financial contributions: The administrative burden for EU based businesses is seen as significant, when accounting for contributions received over a three-year period. When considering the FSR guidelines, Danish Shipping would like to en-courage the Commission to take the above into consideration. The Commission must not introduce unnecessary bureaucracy and adminis-trative burdens, which could hit EU based companies with considerable cost. In this respect, Danish Shipping urges the Commission to further clarify and limit the task for EU based businesses within the framework of the draft implementing regulation. Danish Shipping would be more than happy to elaborate on any of the above-mentioned remarks and we are at the disposal of the Commission should you have any questions in this regard.
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Meeting with Andrea Gavinelli (Head of Unit Health and Food Safety) and Royal Association of Netherlands' Shipowners and Verein der Europäischen Bürgerwissenschaften e.V. / European Citizen Science Association

1 Apr 2025 · Commission proposal on the protection of animals during transport

Meeting with César Luena (Member of the European Parliament, Rapporteur)

27 Feb 2025 · Pellets Regulation

Meeting with Niels Flemming Hansen (Member of the European Parliament)

11 Feb 2025 · strategiske fokus for skibsfarten i EU

Meeting with Stine Bosse (Member of the European Parliament) and A.P. Møller - Mærsk A/S

5 Feb 2025 · European ocean policy

Meeting with Asger Christensen (Member of the European Parliament, Shadow rapporteur)

30 Jan 2025 · Animal Transport

Meeting with Sigrid Friis (Member of the European Parliament)

14 Nov 2024 · COP29

Meeting with Morten Løkkegaard (Member of the European Parliament)

16 Oct 2024 · EU legislation impacting the shipping sector in the upcoming period

Meeting with Henrik Dahl (Member of the European Parliament)

14 Oct 2024 · Internal Market

Meeting with Sigrid Friis (Member of the European Parliament)

14 Oct 2024 · EU regulations, industrial strategy, and environmental and animal welfare policies.

Meeting with Stine Bosse (Member of the European Parliament)

2 Oct 2024 · European maritime policy

Meeting with Asger Christensen (Member of the European Parliament)

6 Sept 2024 · Priorities for new mandate

Response to Monitoring and reporting of greenhouse gas emissions from offshore ships and zero-rating of sustainable fuels

2 Sept 2024

Danish Shipping welcomes the draft delegated act on the inclusion of offshore vessels in the EU MRV, as it will be of utmost importance for the decarbonisation and environmental sustainability of the maritime industry. We agree that the current MRV framework need to be modified to address the unique operational characteristics of this segment of the industry. The suggested list of vessel types does not cover the full spectrum of vessels operating within the offshore sector, e.g. cable-laying vessels dredgers and vessels preforming hydrographic surveys are not included. Danish Shipping suggest that the identification of offshore vessels is based on the vessels operational activity and not the specific type of vessel as it will be difficult to ensure that all vessel types are included in a positive list. Alternatively, a negative list could be used. The delegated act could define offshore ships as all vessels not currently covered by the MRV but engaged in offshore operations and then clearly define the ship types that are exempt from regulation. This approach would ensure a more inclusive and comprehensive regulatory framework, capturing all relevant vessels unless they are specifically exempted. Regarding the definition of port call we would like to suggest that not only taking onboard or discharging crew and passengers will trigger a port call but also taking onboard or discharging of so called Industrial Personnel (as defined in the IMO IP Code) as this operation may take place without passengers or crew are exchanged.
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Response to Electronic version of the VAT exemption certificate

22 Jul 2024

All initiatives to align VAT and excise rules and enhance digitalisation are welcomed by Danish Shipping. Danish Shipping fully supports the Directive to standardise, align, and harmonise VAT and excise rules and regulations for supplies to qualifying bodies.
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Response to Methods and criteria of accreditation of verifiers under Article 14(5) of the FuelEU Maritime Regulation

24 Apr 2024

We do not have comments to the procedures for accreditation of verifiers.
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Response to Definition of standard monitoring plans under Article 8(4) of the FuelEU Maritime Regulation

24 Apr 2024

In the template for standard monitoring plans section B.7 both WASP and WAPS are used as abbreviations and in B.8 also use WASP.
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Response to Rules for verification activities under Article 13(5) of the FuelEU Maritime Regulation

24 Apr 2024

We do not have comments to the template for the annexes to FuelEU report.
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Meeting with Bergur Løkke Rasmussen (Member of the European Parliament) and INEOS AG

5 Mar 2024 · Carbon Capture and Storage

Danish Shipping Urges Targeted Subsidies for Maritime Green Fuels

1 Mar 2024
Topic — The initiative addresses design elements for renewable energy auctions to boost EU wind power competitiveness.
Message — The group requests specific auction categories and 'Contracts for Difference' to subsidize ship operators. They argue current auctions do not guarantee green fuels at commercially viable prices.12
Why — This would lower financial risks and ensure stable fuel supplies for their fleets.34
Impact — Lower-value cargo segments may lose out if subsidies favor high-value shipping containers.5
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Meeting with Bergur Løkke Rasmussen (Member of the European Parliament)

21 Feb 2024 · Upcoming election

Meeting with Marianne Vind (Member of the European Parliament)

21 Feb 2024 · Maritime transportation

Meeting with Morten Løkkegaard (Member of the European Parliament)

20 Feb 2024 · Danish Shipping

Meeting with Marianne Vind (Member of the European Parliament)

8 Feb 2024 · Animal Welfare

Response to Evaluation of the implementation of the EU Drugs Strategy and of the EU Drugs Action Plan 2021-2025

16 Jan 2024

As Danish Shipping represents member companies operating in global maritime shipping, we strongly support EUs efforts in addressing the challenges created by drugs trafficking. However, due to the complex issue of these challenges, it is important to coordinate across EUs various initiatives. EU Drugs Strategy 2021-2025 should complement, and not duplicate, initiatives such as the EU Roadmap to fight Drug Trafficking and Organised Crime. From a maritime shipping perspective, especially the following two strategic priorities from the strategy are important: 2.1. Counter the smuggling of drugs and drug precursors in and out of the EU by using established legitimate trade channels. 2.2. Increase monitoring of border crossings that are not part of established trade channels to more effectively prevent illicit or undeclared crossings of the EU external borders. It is a joint responsibility for all actors in the supply chain to work together in addressing and combatting drug smuggling and organised crime. However, authorities have a special responsibility to take the lead in this fight, as they have some tools at their disposal that private companies do not, such as intelligence sharing and cross border cooperation between the Member States and internationally, and collaboration between EU agencies regarding customs and boarder control, police, and anti-corruption measures. Danish Shipping and its members will welcome the chance to support this effort, as the increasing illegal drugs trafficking constitutes an ever-present risk, not least to the employees both abord the ship and on land.
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Danish Shipping urges flexibility to avoid maritime administrative burdens

10 Jan 2024
Topic — The European Commission is reviewing package travel rules to ensure consumer protection.
Message — Danish Shipping recommends flexibility in quality and reporting systems to avoid high costs. They caution against new maritime regulations that overlap with existing passenger laws.12
Why — This would protect maritime companies from significant new administrative and economic costs.3
Impact — Consumers lose the benefit of a standardized format for compensation and reimbursement.4
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Danish Shipping Urges Clarity on Multimodal Passenger Rights Rules

10 Jan 2024
Topic — The Commission is reviewing passenger rights to improve protection during multimodal travel disruptions.
Message — Clarify the scope of sea journeys covered to prevent legal overlaps. Ensure safety exceptions for mobility-impaired passengers align with current maritime regulations.12
Why — This would avoid unfair liability for other carriers' errors and reduce administrative costs.34
Impact — Passengers may lose guaranteed alternative travel options during weather-related ferry cancellations.5
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Danish Shipping pushes for stricter livestock vessel classification rules

9 Jan 2024
Topic — Revision of EU rules on animal welfare during transport to improve standards and competition.
Message — They recommend all livestock vessels be certified by elite classification societies to ensure high safety standards. They argue home countries must be allowed to inspect their own ships regardless of departure locations. Additionally, they suggest reducing mandatory fodder reserves to prevent waste on shorter trips.123
Why — These rules protect Danish shipowners from being undercut by cheaper, lower-standard international competitors.4
Impact — International ship operators with poor maintenance records lose the ability to compete in EU markets.5
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Response to Revision of Combined Transport Directive

21 Dec 2023

Danish Shipping expresses gratitude to DG MOVE and the European Commission for the opportunity to provide comments on the revision of sustainable transport - revision of Combined Transport Directive. Overall, Danish Shipping urges the EU to continue to be ambitious in ensuring better coordination between modes of transport and an increased use of combined transport solutions. The Commission's proposal is a step in the right direction when it comes to working towards achieving climate neutrality, given short-sea shipping's role as a central and sustainable part of multimodal transport solutions. Regarding this, Danish Shipping requests DG MOVE to work towards ensuring that the proposal remains ambitious and includes specific goals and actions for increased short-sea shipping. Additionally, Danish Shipping wishes for the good strategic initiatives from the Commission to be continued and developed into concrete objectives, requiring the implementation of "Flag-ship 4" under 'the Sustainable and Smart Mobility Strategy' to be ensured, and that the green infrastructure, including facilities for sustainable fuels, is improved. Furthermore, EU's innovation fund should be considered as a possible catalyst for this development. As providers of green logistics solutions, the members of Danish Shipping are aware of the challenges posed by intermodal transport. Increasing integration of various transport solutions, including short-sea shipping, is essential to achieve the goals under the socalled "Flagship 4" and, more generally, to accelerate the objectives of the 'European Green Deal.' It should be emphasized that with the completion of the FuelEU Maritime file and the inclusion of shipping under the EU ETS regime, short-sea shipping will only become a greener transport alternative. Short-sea shipping not only contributes significantly to reducing greenhouse gas emissions but also alleviates congestion issues on roads. Danish Shipping urges swift and resolute measures to meet the goals of "Flagship 4." Danish Shipping believes that amending Directive 92/106/EEC on combined transport (CTD) is an important measure to promote sustainable transport. The goal of promoting initiatives in sustainable transport that can reduce social external costs by 40 percent represents a significant change, replacing the outdated distance based system. Furthermore, Danish Shipping considers it crucial that technical development is reflected upon, as green infrastructure ought to be strengthened to achieve the climate goals agreed upon by the EU for maritime transport. Access to alternative fuels, onshore power supply, and TEN-T can be considered as possible targeted projects for short-sea shipping, and earmarked funds can be beneficially sourced from ETS funds for short-sea shipping and formulated in the EU's innovation fund. With the initiative to reduce the price of combined transport by 10 percent within seven years, the use of more environmental friendly transport alternatives such as short-sea shipping will increase. Road transport will function more as a short-distance solution, while more sustainable forms of transport will handle long-distance transport. This change will result in a direct reduction of emissions, contribute to easing traffic congestion, strengthen resilience, and improve safety measures for everyone on European roads. The proposal focuses particularly on member states' implementation of measures ensuring the above. In this light, Danish Shipping hopes that the relevant DGs and the Commission ensures the most agile, transparent, and implementable solutions so that multimodal transport solutions, including short-sea shipping, become even more competitive than they are today.
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Meeting with Asger Christensen (Member of the European Parliament) and Landbrug Fødevarer - Danish Agriculture and Food Council and

8 Dec 2023 · Agriculture/Transport

Meeting with Niels Fuglsang (Member of the European Parliament)

6 Nov 2023 · Debat om Grøn Omstilling

Meeting with Marianne Vind (Member of the European Parliament)

31 Oct 2023 · Maritime transport

Meeting with Marianne Vind (Member of the European Parliament)

13 Sept 2023 · Maritime transportation

Danish Shipping urges EU-wide maritime CO2 transport single market

31 Aug 2023
Topic — A consultation on the role of carbon capture technologies in decarbonising the EU economy.
Message — Danish Shipping advocates for a single market for maritime CO2 transport to support sectors difficult to decarbonise. They request expanding the EU ETS to reward negative emissions with tradeable allowances.12
Why — The industry would secure a dominant role in the emerging global carbon transport market.3
Impact — National governments may lose regulatory control as EU standards replace resource-demanding bilateral agreements.4
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Danish Shipping Demands Earmarked Funding for Maritime Fuel Projects

7 Aug 2023
Topic — This consultation reviews rules for the Innovation Fund including competitive bidding and maritime sector support.
Message — The organization wants the EU to explicitly earmark funds for the maritime sector and fuel production. They also suggest prioritizing early-stage technologies over those that are already close to being commercially viable.123
Why — Targeted funding would help shipowners cover the high costs of complying with upcoming fuel regulations.4
Impact — Companies focused on vessel retrofitting or near-commercial technologies lose access to these specific subsidies.56
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Response to European Critical Raw Materials Act

30 Jun 2023

Danish Shippings three most important issues regarding the Critical Raw Materials Act are: Upscaling of renewable energy Availability of sustainable maritime fuels Continued global, open trade Danish Shipping is positive about the security of raw materials e.g., to support the production of renewable energy in the EU, and that EU in this regard considers the uncertainty and dependency that Europes in-dustry will face. Sufficient critical raw materials are crucial for the green transition. Espe-cially with regards to the production of hydrogen and electrolysis for Power-to-X. This will be of great benefit to the shipping sector, since large scale production of renewable energy is a prerequisite for the green transition of the industry through access to new, green fuels. A necessity in this regard is the increase in hydrogen production capacity and the accessibility of renewable energy capacity around the world. Here, as regarding the area of raw materials, Danish Shipping would like to see the Commission include the production capacity of hydrogen and access to green fuels as a core part of the discussion with future and current trade partners. Danish Shipping thinks that EU should in line with the CRMA highly focus on diversification of import. EU will never be able to support its own demand and will therefore be dependent on imports. Here, it is our opinion that EU should increasingly incorporate deals on raw materials in cooperation with international trade partners. International trade is es-sential to support global production and ensure a secure and diverse supply chain of critical raw materials. Danish Shipping is happy to answer any questions or remarks that should arise, so please feel free to reach out. Kind regards, Thomas Sylvest Danish Shipping +45 40497886 ths@danishshipping.dk
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Danish Shipping calls for CO2 transport and green fuel support

27 Jun 2023
Topic — This consultation addresses the Net Zero Industry Act to strengthen European green technology manufacturing.
Message — The organization requests that the EU address CO2 transport bottlenecks by recognizing the essential role of shipping. They also seek clarified financial terms for storage and global partnerships for green fuel production.123
Why — Accelerated permitting and global fuel access would secure the industry's green transition and export earnings.45
Impact — European storage operators face financial ruin if terms and market conditions for CO2 storage remain unclear.6
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Danish Shipping urges EU to set 90% climate target

23 Jun 2023
Topic — The Commission is establishing an intermediate 2040 climate target for reaching net-zero.
Message — Danish Shipping urges the EU to set a target of 80-90% absolute reduction by 2040. They also request supportive policy frameworks and financial aid from the Innovation Fund.12
Why — Ambitious targets create the investment certainty required to produce expensive renewable shipping fuels.3
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Meeting with Niels Fuglsang (Member of the European Parliament)

31 May 2023 · Transport af dyr

Meeting with Asger Christensen (Member of the European Parliament)

31 May 2023 · Animal transport

Danish Shipping Opposes Reclassifying Key Feedstocks to Protect Investments

22 Dec 2022
Topic — This consultation seeks to update the list of sustainable feedstocks for biofuel production.
Message — The organization requests that brown grease remains listed as an advanced feedstock. They also highlight the need for transparent certification to provide certainty for fuel-producers.12
Why — Consistent rules would de-risk investments and provide certainty for the maritime energy transition.3
Impact — Early investors in specific biofuel technologies would be penalized by changing feedstock categories.4
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur)

28 Sept 2022 · FuelEU maritime

Response to Evaluation of the Ship Recycling Regulation

30 Jun 2022

Danish Shipping would like to thank the EU Commission for the possibility to provide feedback on the experience with the EU Ship Recycling Regulation and below we have provided answers to most of the questions. Please see attached file.
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Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur)

13 Jun 2022 · FuelEU maritime

Meeting with Caroline Nagtegaal (Member of the European Parliament, Shadow rapporteur) and KIC InnoEnergy SE and

5 Jan 2022 · AFIR

Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

14 Oct 2021 · Meeting on FuelEU maritime.

Response to EU Action Plan against migrant smuggling (2021-2025)

29 Mar 2021

Until the issue with migrant smuggling has been solved, it should be remembered, that we will continue to see migrants using routes crossing the Mediterranean. Often the crossings are attempted in unseaworthy boats. If the migrants then end up in distress at sea it can become a challenge for merchant vessels in the area. The merchant vessels have a legal and moral obligation to come to the rescue of any persons in distress at sea. However, the merchant vessels and their crews do not have the necessary equipment (extra food, blankets and medicines etc.) nor expertise to handle large rescue operations with many people often in a high state of profound distress. If a merchant vessel participates in a rescue operation, it is important that the authorities quickly inform the vessel about a place of safety to disembark the rescued persons. Furthermore, it must be the authorities' task to ensure adequate search and rescue resources in the Mediterranean.
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Meeting with Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager)

26 Feb 2021 · New regulations on environment & climate (including relevant State aid guidelines as well as regulation)

Response to Updating the EU Emissions Trading System

26 Nov 2020

Please find the attached response by Danish Shipping to the consultation on the Inception Impact Assessment on the EU ETS.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Please see the attached comments from Danish Shipping.
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Response to FuelEU Maritime

24 Apr 2020

Please find attached feedback from Danish Shipping.
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Response to 2030 Climate Target Plan

15 Apr 2020

Please find attached the feedback from Danish Shipping.
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Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

22 Jan 2020 · shipping, Green Deal and other subjects related to it

Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans) and European Community Shipowners' Associations

22 Nov 2019 · Sustainability, climate and maritime issues

Response to Revision of the Shipping MRV Regulation

26 Mar 2019

Please find the attached feedback. Yours sincerely Alexander von Wildenrath Løvgreen awl@danishshipping.dk +32 496 81 56 78
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Response to Evaluation of the Alternative Fuels Infrastructure Directive

11 Mar 2019

Danish Shipping welcome the opportunity to contribute to the evaluation roadmap of the 2014 Alternative Fuels Infrastructure Directive. In April 2018, the UN’s International Maritime Organization, IMO, adopted an Initial strategy on reduction of Green House Gas emissions from ships which establishes several very ambitious CO2 reduction targets. The Green House Gas emissions from international shipping is to peak as soon as possible and the total annual GHG emissions is to be reduced by at least 50% by 2050 compared to 2008 and IMO aims to phase them out as soon as possible in this century. It will only be possible to achieve the ambitions envisioned by IMO’s GHG Strategy with fundamental changes in vessel fuels and propulsion systems. This includes deployment of infrastructure for alternative fuels i.e. bunkering and recharging facilities at berth in the EU as well. Substantial and sustained research and development effort are paramount for the development of such new fuels, infrastructure and propulsion systems. We thus encourage the facilitation of research at all levels, and not least the prioritization and allocation of EU Funds for research with-in this area. We agree that the overall market for alternative fuels infrastructure still is at its early stages. Additionally, at this point no single alternative fuel or propulsion system (LNG, methanol, batteries, hybrid etc) is likely to be preferred by shipowners in the future. Many alternative fuels have issues that need to be addressed e.g. methane slip for LNG. Different fuels will probably be implemented in different segments of the shipping sector. Today ferries between Denmark and Sweden in Oresund and between Denmark and Germany in the Baltic Sea operate exclusively or partly on battery stored energy. The use of batteries as an energy carrier (alone or as part of a hybrid propulsion system) is likely to increase in primarily short sea shipping. Ocean going vessels need to bunker fuel to supply several weeks of operation and will have to deploy other alternative fuels. On this note Danish Shipping encourages the Commission to invite stakeholders from the shipping sector to provide input to the evaluation of the Alternative Fuels Infrastructure Directive and to participate in workshops and other activities as part of the upcoming public consultation.
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