Audible response

Consultation response to the 4 secondary legislative acts for port reception facilities directives

Danish Ports would like to thank you for the opportunity to submit consultation responses to the 4 secondary legal acts to the directives for port reception facilities.

General remarks

Danish Ports welcomes the fact that waste should not end up in the sea, but should be delivered to the ports.

Overall, the position of Danish Ports is that it is generally important that all legal acts are designed as simply as possible, so that it does not entail a large administrative burden for ports and authorities to comply with the legal acts.

The 4 legal acts.

Art. 7.4 on establishing the methods for calculating the sufficient dedicated storage capacity (relevant, inter alia, for the implementation of exemptions from waste delivery)

Art. 8.5 on reduction of fees for ships (a “green ship scheme”)

Art. 8.7 on guidelines for collecting monitoring data on the extent and quantity of passively fished waste

Art. 11.2 on guidelines for the selection of ships for inspection ('Union risk-based selection mechanism')

In relation to Art. 7.4, Danish Ports may fear that ships may bring very large quantities of waste to selected ports – waste tourism. These will typically be ports where it is easy and convenient to deliver the waste. This can mean very large additional costs for the ports in question. It is therefore important that it is simple to check whether the ships have sufficient storage capacity. It could, for example, be via Safe Sea Net that this could be made clear. Authorities and ports can then possibly check the information in Safe Sea Net if there is suspicion of data fraud.

The calculations should also include the number of people on board, as this has a major impact on some of the amounts of waste produced on the ship.

In relation to Art. 8.5 (We have not yet seen a concept paper), Danish Ports believes that reducing fees for ships (a "green ship scheme") should be based on a simple system that is manageable - also for small ports - it could be, for example, a green ship scheme - marking via Safe Sea net.

Art. 8.7 on guidelines for collecting monitoring data on the extent and quantity of passively fished waste.

We have not yet seen a concept paper, but Danish Ports can state that the vast majority of Danish Fishing Ports already receive fished waste free of charge. They also hand over some of the fished waste for recycling to, for example, Plastix. Danish Ports believes that the system should be as simple as possible.

Danish Ports would like to welcome the preparation of a study into the origin of the waste, the amount of waste fished out and how it can best be recycled, but not at the expense of the ports. It is the ports that clean up for other parties.   

Sincerely yours

Kasper Ullum

Environmental consultant

Danish Ports