Licensing procedure for the relocation of dredged material to the German Exclusive Economic Zone (EEZ): navigating the regulatory zoo
Type:
Presented during:
CEDA Dredging Days 2026
Authors:
H. Roeper, K. Wolfstein, M. Kindermann, L. Zalden and B. Hochfeld
Abstract
In June 2022, the Hamburg Port Authority (HPA) submitted an application to the Federal Maritime and Hydrographic Agency (BSH) for the relocation of dredged material from the Port of Hamburg into the German Exclusive Economic Zone (EEZ). The application comprises an average of 1.5 million tonnes dry substance annually over a 10-year period, under the German law on the disposal of substances in the high seas (Hohe-See-Einbringungsgesetz). In the licensing procedure HPA experiences competing demands, reflecting a complex combination of legal, ecological, and political aspects. Within the consultation process 18 institutional statements have raised over 600 critical comments and concerns, some conflicting fundamentally with the objective of the project, such as the separation of fine fractions prior to relocation and their disposal or use on land. Further concerns relate to alternative disposal techniques, anchoring safety, long-term site usability, or ordnance clearance. Also, an extensive oyster reef must be created as real compensation, to support the reintroduction of the European oyster (Ostrea edulis) - which never has been done before in relation to maintenance dredging activities. Beyond the national framework, European and international policy significantly increases the complexity. The Marine Strategy Framework Directive requires strict compliance with good environmental status, while increasingly low environmental quality standards (EQS) must be considered. In addition, the recognition of OSPAR commitments further constrains acceptable practices and demands alignment with regional marine protection objectives. This presentation will show the current state of the licensing procedure, highlight the main legal, technical, and environmental challenges, and discuss the implications of conflicting regulatory demands. The case will provide broader lessons for ports and dredging authorities across Europe at the intersection of technical feasibility, environmental protection, and legal certainty - today's regulatory zoo.