Denmark’s Nature Conservation Association (Danmarks Naturfredningsforening) has filed a detailed complaint against the Danish Environmental Protection Agency’s revised discharge order for FMC Agricultural Solutions A/S – better known as Cheminova.
The complaint was sent to the Environmental and Food Appeals Board on 20 January 2026 and targets metal discharges into the North Sea near Thyborøn on the west coast of Denmark.
Danmarks Naturfredningsforening argues that the order allows continued releases of several heavy metals above environmental quality standards at the outlet, relying instead on mixing zones in the sea. According to the association, these risks further pollute and breach Danish and EU water rules.
Claims of weak BAT documentation
Danmarks Naturfredningsforening says the agency has not proven that Best Available Techniques (BAT) are used for each metal close to the pollution sources.
Seven metals are allowed in mixing zones without clear proof of source-level treatment. The Association calls the BAT assessment “too general” and not supported by data for each substance.
Dispute over data and mixing zones
The complaint states that background levels of metals in water, sediment and marine life are based on distant monitoring stations, up to 175 km away.
Danmarks Naturfredningsforening argues these are not representative of the discharge area. It also challenges the use of unofficial 5% and 1% tolerance margins above legal limits for arsenic in water and sediment.
Call for stricter mercury limits
Mercury is a key issue. Danmarks Naturfredningsforening notes that it is an EU-prioritised hazardous substance and is not used in current production. Danmarks Naturfredningsforening therefore calls for a target of near-zero mercury discharge, similar to rules applied at the Høfde 42 clean-up project.
The appeals board is now asked to overturn or tighten the order.