Marine Ingredients Denmark urges clarity on climate audit verification, exemptions and energy access in Danish Energy Agency’s draft rules
Marine Ingredients Denmark (MID) has urged the Danish Energy Agency to clarify rules on mandatory energy and climate audits for companies, warning that a lack of certainty could create unnecessary burdens for businesses already meeting international standards.
In a consultation response to the draft regulation on energy management systems and audits, MID highlighted the role of Denmark’s fishmeal and fish oil producers, who are among the world leaders in the sector.
The industry processes species such as sprat, sandeel and blue whiting, as well as increasing volumes of by-products from food fisheries, contributing to the circular economy. In 2024, Danish marine ingredients exports were valued at around DKK 6 billion, accounting for 22 percent of total national fish exports.
According to MID, the industry already complies with international energy and environmental certification schemes, ensuring sustainability and environmental responsibility. The draft regulation, however, was criticised for providing less clarity around verification of climate audits than for energy audits.
While certification schemes are accepted as proof of compliance for energy audits, it remains unclear if recognised standards such as ISO 14001 can serve the same role for climate audits.
MID stated: “For companies to plan effectively, the regulation should specify which certification systems can verify climate audits, just as it does for energy audits. This could be addressed in Section 10 or 11 by allowing recognised environmental management standards to count as verification.”
The group also raised concerns about provisions relating to exemptions. Section 5 of the draft regulation allows companies covered by Best Available Techniques (BAT) conclusions under environmental approvals to be exempt from parts of the energy audit requirement. MID pointed out that many future environmental permits will cover entire companies under BAT conclusions, and it is not clear whether such exemptions also apply to climate audits.
“We propose that the regulation clarifies whether BAT conclusions can provide an exemption from both energy and climate audits. If not, the practical usefulness of this exemption will be very limited,” the submission noted.
While supporting the identification of carbon reduction opportunities, MID stressed that rapid and substantial investment in infrastructure would be needed to enable the industry’s green transition. The group emphasised that, despite being ahead of its European competitors on environmental standards, the Danish sector cannot finance the necessary shift alone without improved access to renewable energy sources such as electricity and biogas.
Marine Ingredients Denmark concluded that greater predictability and supportive infrastructure were essential if the fishmeal and fish oil industry is to continue contributing to Denmark’s blue economy while meeting new environmental obligations.
