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Consultation Responses

Public Consultation on the Commission's Proposal for CEF III

September 9, 2025

Thank you for the opportunity to submit comments on the consultation.

Danish Ports considers it crucial that significant funds be allocated to the European port sector under the CEF. A 2024 ESPO study shows that the investment needs of Europe’s port management bodies amount to EUR 80 billion for the period 2024–2034. The port sector is highly capital-intensive and has substantial investment needs. We therefore welcome the fact that, in its proposal for CEF III, the Commission is both increasing the budget and prioritizing the transportation sector.

Ports’ investment needs reflect their many roles, in which traditional tasks are combined with new functions. Basic port infrastructure remains crucial to ports’ development, but this is complemented by major investments in sustainability and the energy transition. The green transition in ports often requires extensive infrastructure adaptations—such as adapting quay facilities for offshore wind or CO₂ transport, as well as establishing pipeline infrastructure. In addition, there are dual-use investments necessary to strengthen Europe’s military preparedness.

It is important to note that many of these investments—particularly those related to the green transition and resilience—have high societal value but often yield only a low, slow, or uncertain return. Therefore, port authorities can rarely undertake them on a purely commercial basis. Robust and adequate funding, including through the CEF, is therefore essential.

At the same time, it is essential that the application process for the CEF be made simpler and less administratively burdensome. Currently, the process is perceived as complex and resource-intensive, which can act as a barrier. A more streamlined and user-friendly process will ensure that more ports can apply for and implement projects, which will support the overall goals of green and safe transportation in Europe.

Against this backdrop, Danske Havne supports the Commission’s proposal for CEF III and welcomes the strengthened framework for investments in ports and transportation infrastructure. At the same time, we urge that the port sector’s central role in Europe’s green and security-related development continue to be given high priority in the final implementation of CEF III.

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