Legal disclosures
What we put in the open as a producer responsibility organisation.
Emballage Indberetning is a producer responsibility organisation approved by the Danish Energy Agency across all six areas: packaging, electronics, batteries, vehicles, single-use plastic and fishing gear. We handle producer responsibility on behalf of our members, so their products and packaging are reported, collected and genuinely recycled according to the rules.
We see openness as a precondition for credible producer responsibility. So we do not stop at publishing what the law requires, we make it as clear and accessible as we can. Among other things we keep our prices public for everyone and not just for members, so any producer can see what the scheme costs before joining. This page holds the information we publish as a producer responsibility organisation.
Ownership
Emballage Indberetning ApS is a Danish limited company, company registration number 45304418. It is owned by Kondrup Holding ApS (CVR no. 39130297) with 51 % and Frederik Kiel Holding ApS (CVR no. 41338873) with 49 %.
Registered producers
An overview of the producers registered with Emballage Indberetning is available in the Producer Register held by DPA (Danish Producer Responsibility).
We are working on making the full overview of registered producers available directly on this page. It is coming soon.
Indicative financial contributions
Producers pay an environmental contribution for the volumes they make available on the Danish market. The contribution is normally set one year at a time and depends on the producer responsibility area and the individual category.
At Emballage Indberetning prices are public for everyone, not only for members. Every member is billed from the same public rate card: a subscription per area plus an environmental contribution. Membership is open to all producers regardless of size, sector or nationality, and all members are subject to the same published terms.
The environmental contribution is eco-modulated. The price depends on the material or the product, so what is easier to recycle generally costs less. This is a legal requirement meant to encourage greener choices. On top of the modulation, the total contribution depends on the volume made available on the market, so each producer pays in proportion to its market share.
For packaging, red packaging pays a surcharge of 35% on top of the base price, which is distributed as a bonus to green in the same material, and green and yellow always pay at least 20% of the base price. For electronics, vehicles and fishing gear, 20% is added for the poorest group. See the details under eco-modulation.
Below you can see which areas we charge an environmental contribution on, and what the contribution is modulated by. The actual rates are on the prices page.
| Area | Contribution to the scheme | Modulated by |
|---|---|---|
| Packaging | Yes, per kg | Material, household/business and eco-modulation (green, yellow, red) |
| Batteries | Yes, per kg | Battery type and environmental properties |
| Electronics | Yes, per kg | Product category and eco-modulation (green/red) |
| Vehicles | Yes, per vehicle | Eco-modulation: green or red group (Annex 6) |
| Single-use plastic | No, only the statutory authority fee | – |
| Fishing gear | No, only the statutory authority fee | – |
| Reusable packaging | No. Membership and authority fees, no contribution per kg | – |
For single-use plastic and fishing gear, producers pay only the statutory authority fee and not a separate environmental contribution to the scheme.
Selecting waste management operators
Emballage Indberetning does not own trucks or facilities. We work with professional operators in the market to transport, sort and genuinely recycle the waste. Whatever the area, we select operators on objective, substantive and non-discriminatory criteria, never at random. We are a private company and not covered by the Danish public procurement act, but we run the selection openly and transparently.
In packaging, where we handle the waste collected by the municipalities, operators are selected through a formal tender preceded by market dialogue. Every participant is treated equally: same material, same answers, same deadlines. Bids are assessed on the best ratio of price to quality against criteria and weightings stated in advance.
We set non-negotiable minimum requirements for operators, including environmental approval for the activity, registration in the Danish Waste Register for transport services, liability insurance, documented experience, compliance with the POPs Regulation and REACH for plastics, and documentation of genuine recycling under section 78 of the Danish packaging order.
For batteries, electronics and the other areas, where volumes are still smaller, we do not always run a formal tender. Instead we contract directly with established, approved waste operators, but the selection follows the same objective and substantive considerations: required approvals and registrations, documented experience, capacity and operational reliability, high genuine recycling, plus resilience, financial security and price. As volumes grow in each area, we move to formal tenders on the same model as packaging.
See the full tender process and criteria weightings
Actual recycling
Section 78 of the Danish packaging order requires a high level of actual recycling of the packaging waste we handle, with minimum percentages per material. We take over the municipally collected packaging waste from 1 January 2027, when DPA's allocation takes effect. From then on we will publish here the current recycling percentage per waste fraction, calculated using the method set out in the order. Until then there are no volumes to report.
Questions
If you have questions about the information on this page or about our selection procedure, you are welcome to contact us.
Legal basis and updates
The information on this page is published under section 89 of the Danish packaging order and the equivalent requirements in the other producer responsibility areas. We update the page on an ongoing basis as circumstances change, and we are happy to make further documentation available to the authorities on request.