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MOVE D.3, Ports & Inland Navigation
Directorate-General for Mobility and Transport
European Commission
15 July 2024
MINISTER FOR INDUSTRY,
BUSINESS AND FINANCIAL
AFFAIRS
Danish response to the European Commission’s public consultation
on smart and flexible EU crewing rules in inland waterway transport
Denmark welcomes the public consultation on a legislative initiative on
smart and flexible EU crewing rules in inland waterway transport.
In Denmark, lakes and rivers are not part of the supply and transportation
network. The EU's inland waterways regulations, derived from the Rhine
Convention, were designed for large European rivers and canals. Denmark
is exempt from these regulations due to its lack of significant rivers and
canals, and its coastal regions' direct connection to open seas. Conse-
quently, maritime rules apply throughout Denmark, whether on sea, lakes
or canals, ensuring equally safe conditions.
Denmark's exemption from the EU's inland waterways rules has been con-
sistent since the first discussions, as evidenced in various EU documents,
including the European Parliament and Council Decision No. 1692/96/EC
and Directive (EU) 2016/1629. These documents explicitly state that there
are no inland waterways in Denmark. Consequently, Denmark has not im-
plemented the EU regulations on inland waterways, nor does Denmark ap-
prove vessels for navigation on inland waterways or issue certificates for
use on inland waterways.
Therefore, Denmark does not believe that countries like Denmark without
inland waterways should be covered by crewing rules in inland waterway
transport.
Yours sincerely,
MINISTRY OF INDUSTRY,
BUSINESS AND FINANCIAL
AFFAIRS
Slotsholmsgade 10-12
1216 Copenhagen K
Denmark
Tlf.
+45 33 92 33 50
Fax.
+45 33 12 37 78
CVR-nr. 10092485
EAN nr. 5798000026001
www.em.dk
Morten Bødskov