What is producer responsibility for packaging?
Producer responsibility for packaging means that companies that manufacture, import or market packaging or packaged products have a legal and financial responsibility for how packaging is handled when it becomes waste.
This means that manufacturers must ensure that packaging is collected, recycled or disposed of in an environmentally sound manner.
The purpose of producer responsibility is to promote recycling and recycling, reduce the amount of waste and minimise the environmental impact of packaging.
This responsibility also includes requirements for registration, reporting and documentation so that the authorities can verify compliance with the rules.
What does the legislation entail?
The legislation on producer responsibility for packaging in Denmark is established by the packaging ordinance - The Order on certain requirements for packaging and extended producer responsibility.
This Executive Order builds on the EU Directive on Packaging and Packaging Waste (Directive 94/62/EC), which aims to harmonise regulations across member countries and ensure a more sustainable handling of packaging across the EU.
The EU Directive has now been replaced by a Regulation (Regulation (EU) 2025/40), meaning that all EU countries are now required to implement the rules directly into their national law.
The ordinance imposes requirements on both the design, material selection and handling of packaging, and it imposes expanded responsibility on manufacturers to ensure that packaging brought to market meets environmental standards and contributes to recycling and waste reduction.
In doing so, the legislation is both a result of national priorities and part of a common European effort to protect the environment and promote the circular economy.
Who is covered by producer responsibility?
The producer responsibility for packaging applies to all companies that put packaging or packaged products into circulation on the Danish market.
Accessibility is defined as the supply of, for example, an empty or filled packaging for distribution, consumption or use on the Danish market.
Producers
Companies that make available packaging or packaged products marketed in Denmark have producer responsibility. They must ensure that the packaging complies with environmental requirements and report relevant information.
Examples of manufacturers:
- Companies that manufacture cardboard boxes for food
- Packaging companies developing special packaging for electronics
Importers
Importers who bring packaging or packaged goods from abroad to the Danish market are covered by producer responsibility. They must ensure that the imported packaging complies with Danish regulations.
Examples of importers:
- Companies importing cosmetics in packaging from abroad
- Wholesalers introducing food packaged in plastic or glass
- Distributors importing electronics with associated packaging
Distributors
Distributors who bring packaging or packaged products into circulation on the Danish market also have producer responsibility. They must ensure proper handling and reporting.
Examples of distributors:
- Wholesale companies that resell packaged goods to retail
- Logistics companies that distribute packaged products to stores
- Distribution centers that handle packaged goods for multiple brands
Companies that fill products in packaging
Operators who package or fill products in packaging before they are sold or distributed are subject to producer responsibility. They are responsible for ensuring that the packaging meets the requirements.
Examples of companies that fill products in packaging:
- Food manufacturers packing snacks in bags
- Breweries that fill beer into bottles or cans
- Cosmetics companies that fill creams into containers
Remote sales companies (dropshipping)
Webshops and other companies that sell packaged products directly to Danish consumers from abroad also have producer responsibility. They must ensure that the packaging complies with Danish regulations.
Examples of distance selling companies:
- International webshops that send goods to Danish customers (e.g. a German company)
- Foreign subscription boxes with packaged products for Denmark
- E-commerce platforms that deliver packaged goods to Danish consumers
How to comply with the legislation?
To comply with the legislation on producer responsibility for packaging, companies must ensure that their packaging meets established environmental requirements, including restrictions on harmful substances and proper labelling.
It is also a requirement that the company be a member of a collective scheme that handles the collection and treatment of packaging waste on behalf of producers.
The company must register in the digital producer register, report packaging volumes annually and keep necessary documentation for a minimum of five years.
In addition, evidence of compliance must be presented at the request of the authorities, and information on packaging handling must be constantly updated.
By following these requirements, companies contribute to a more sustainable and responsible handling of packaging waste in Denmark.
Why is producer responsibility important?
Producer responsibility is crucial because it ensures that companies take responsibility for the entire lifecycle of their packaging — from production to disposal or recycling.
By imposing extended responsibility on manufacturers, they are motivated to design more environmentally friendly packaging, reduce waste and promote recycling and recycling.
This helps reduce environmental impact, saves resources and supports the transition to a more circular economy. At the same time, producer responsibility creates a fairer system where those who put packaging on the market also contribute to the cost of handling the waste.
In doing so, it becomes not just a social responsibility, but a shared responsibility, where all parts of the value chain work together for a more sustainable future.
How is producer responsibility implemented?
The implementation of producer responsibility for packaging is done through a series of statutory processes in which manufacturers, importers and distributors register in the Digital Manufacturer Register (DPA) and report annually the quantity and type of packaging they bring to market.
They must ensure that the packaging complies with environmental requirements and limit values for harmful substances, as well as provide evidence of this on request.
Producers also assume financial and practical responsibility for the collection, handling and recycling of packaging waste, supporting a more sustainable and circular economy.
What happens if you don't follow the rules?
If you, as a manufacturer, importer or distributor, fail to comply with the rules on producer responsibility for packaging, it can have serious consequences. Failure to register, report or documentation may result in injunctions, fines or, in the worst case, a ban on marketing packaging on the Danish market.
The Danish Environmental Protection Agency and Danish Producer Responsibility have the power to check compliance and may require further documentation or investigations.
Violations can also damage the company's reputation and lead to a loss of trust among customers and business partners. It is therefore crucial to ensure that all requirements and reporting deadlines are met so that the company avoids penalties and contributes to a more sustainable packaging management.
