Danish Ports
Member login

Consultation response

Danske Havnes høringssvar til Kommissionens forslag til en handlingsplan for dronesikkerhed og anti-dronesikkerhed

Danske Havne takker for muligheden for at afgive bemærkninger til Kommissionens handlingsplan for dronesikkerhed og anti-dronesikkerhed. Danske Havne understreger, at overvågning, detektion og operative modforanstaltninger mod droneaktiviteter i det maritime domæne fortsat bør være et myndighedsansvar. Danske havne spiller en vigtig rolle i Danmarks og EU’s samlede kritiske infrastruktur. I lyset af den geopolitiske udvikling […]

Høringssvar vedrørende udkast til forslag til lov om ændring af beredskabsloven (Styrkelse af det operative beredskab og beredskabsplanlægning m.v.)

Danske Havne takker for muligheden for at afgive høringssvar til udkast til forslag til lov om ændring af beredskabsloven. Danske Havne repræsenterer de danske erhvervshavne, som spiller en central rolle for forsyningssikkerhed, international handel, energi, militær mobilitet og transport. Havne udgør derfor kritisk infrastruktur, og vil i mange tilfælde være blandt de første steder, hvor […]

Safe coexistence – Strategy for civil drones in Danish airspace

Danske Havne would like to thank you for the opportunity to comment on the draft Strategy for Civil Drones in Danish Airspace. Danske Havne is the trade association for Danish commercial ports, which play a central role in security of supply, export/import, and the green transition. Ports are critical infrastructure and operating environments with close interaction between ship traffic and land transport. Danish Ports sees […]

Consultation response to proposed amendments to the Corporation Tax Act, the Bankruptcy Tax Act, and the Tax Assessment Act (Repeal of tax exemption for certain ports) – ref. no. 2023-7800

On November 21, 2025, the Ministry of Taxation sent the above-mentioned draft (hereinafter referred to as "the proposal") to Danske Havne (Danish Ports) with a request for comments. The purpose of the proposal is to repeal the current rules on tax exemption for Danish ports as a result of the European Commission's state aid investigation into the tax treatment of ports, which in several EU countries – including Denmark – were either tax-exempt [...]

Consultation response on military mobility

Danish Ports' response to the EU proposal on establishing a framework for measures to facilitate the transport of equipment, goods, and personnel for military purposes across the Union. Danske Havne would like to thank you for the opportunity to comment on the EU proposal to strengthen military mobility in the EU. Danske Havne would like the following summary to be included in the Basic and […]

Danish ports' consultation response regarding proposed amendments to the Planning Act

Danske Havne acknowledges the opportunity to comment on the draft amendment to the Planning Act. Several of the proposed amendments may be directly relevant to commercial ports and their opportunities for operation and development. Danske Havne fully agrees with the proposal's ambition to make it easier for companies to adapt and develop their businesses, [...]

Response to the European Commission's communication on a sustainable transport investment plan (STIP)

Danske Havne would like to thank you for the opportunity to comment on the Commission's investment plan for sustainable transport. We share the ambition to accelerate the production and use of green fuels in maritime and aviation transport. However, in order to achieve these goals, Member States must ensure a broad and geographically balanced distribution of revenues from the EU ETS. This includes delegating funds to commercial ports, which […]

Consultation on the draft executive order on the designation of competent authorities, digital communication, and disclosure of information pursuant to the CER Act (L 140)

Danske Havne would like to thank you for the opportunity to submit a consultation response to the draft executive order on the designation of competent authorities, digital communication, and the disclosure of information under the CER Act. We would particularly like to highlight a challenge that arises from the ports' cadastral responsibility. Ports often lease land to very different types of businesses, and at the same port there may be […]

Consultation response to revised notices on crew requirements for smaller vessels

Danske Havne would like to thank you for the opportunity to comment on the renewed consultation on the executive orders on crew requirements for smaller vessels. Danske Havne acknowledges the intention to improve safety and the working environment for people working on board smaller commercial vessels, including pilot boats. It is important that the regulations support a high level of safety for the benefit of both crews, pilots […]

Consultation on the Commission's proposal for CEF III

Thank you for the opportunity to submit a consultation response. Danske Havne considers it crucial that significant funds are allocated to the European port sector in the CEF. An ESPO study from 2024 shows that the investment needs of Europe's port management bodies amount to EUR 80 billion in the period 2024-2034. The port sector is very capital-intensive and has a large investment need. We therefore welcome the […]