FAQs on Extended Producer Responsibility for Packaging

💡 General

What is manufacturer responsibility for packaging?

Producer responsibility for packaging means that companies are legally and financially responsible for handling the packaging they put into circulation when it turns into waste.

When does the legislation come into force?

Producer responsibility for packaging came into force on January 1st 2025.

What is the name of the legislation for packaging?

In Denmark, the rules are implemented in The Packaging Ordinance (BEK No. 323 of 20/03/2025)that lays out requirements for producers, importers and sellers.

What is the purpose of the legislation?

The aim is to ensure that companies take responsibility for the environmental impact of their packaging and promote recycling and recycling. Municipalities are no longer in charge -- it now passes to collective schemes and is funded through fees to businesses.

Who are the public authorities behind producer responsibility?

Environmental Protection Agency (Miljøstyrelsen) lays down the framework and regulations.

‍Danish Producer Responsibility (DPA) maintains a register of producers and is responsible for the control of the authorities.

👀 Who's affected?

Who is covered by the rules?

All companies that bring packaging or packaged products into circulation in Denmark, regardless of size or nationality.

Producers are covered by producer responsibility if they manufacture packaging or packaged products that are put into circulation on the Danish market. This also applies if the packaging is produced under its own name or trademark.

Importers are covered by producer responsibility if they bring packaging or packaged products from abroad into the Danish market — whether it is their own products or resale.

Sellers, including distributors and distance selling companies are also covered if they bring packaged products into circulation on the Danish market. This applies to both physical stores and online shops, also from abroad.

Are small businesses covered?

Yes, all companies, regardless of size, are covered by producer responsibility if they make packaging available on the Danish market.

What does the trifle limit of 8 tons per year mean?

If a company makes available less than 8,000 kg of packaging per year, it can only make an overall report without specifying the quantity by material.

However, the company still has to be registered and pay environmental contributions.

What about micro-businesses?

Yes, micro-businesses are not automatically exempt. A microenterprise has fewer than 10 employees and an annual turnover of less than DKK 15 million.

If a microenterprise manufactures packaging in its own name from a Danish subcontractor, the supplier is responsible for the producer.

However, if the micro-enterprise imports or sells packaging and/or packaged products, it bears the responsibility itself.

Should foreign companies be registered?

All companies bringing packaging or packaged products into circulation in Denmark.

📦 Producer responsibility

When do I need to register with DPA?

You must register no later than 14 days before you start marketing packaged products in Denmark. The registration is valid only after the registration fee has been paid and you have received the proof.

Is it required to be a member of a collective scheme?

By 14 January 2025, all companies covered by the extended manufacturer responsibility for packaging rifles must be attached to a collective scheme that fulfils their obligations. Reporting and payment must be made through the scheme. It is not allowed to do it yourself.

How do I report packaging quantities?

It is done through the collective scheme you are enrolled in. If you have less than 8 tonnes per year, you can report in aggregate. Over 8 tonnes requires reporting by material types such as cardboard, plastic, glass, etc.

What is an authorized representative?

An authorised representative is a person or company appointed to perform the obligations of a producer under producer responsibility in Denmark. This could be, for example, Packaging Reporting ApS.

Companies established in another EU Member State or in a third country become producer responsible when selling to an end user in Denmark and must therefore have an authorised representative.

Appointment is made by a written agreement, in which the representative agrees to assume responsibility for the obligations of the producer.

What is packaging?

Packaging is not just a cardboard box or a plastic bag. For example, bestpr a wine bottle typically of:
- Glass bottle (glass)
- Cork stopper (biomaterial or plastic)
- Metal seal (aluminum)
- The paper label (paper)

All of this counts as packaging and must be factored in.

What is the difference between manufacturer responsibility for packaging and single-use plastic products?

Manufacturer responsibility for packaging covers all types of packaging, while producer responsibility for single-use plastic products specifically addresses products made from plastics that are designed for single use.

Packaging may well be covered by both producer responsibility on packaging and producer responsibility on single-use plastic products.

🚨 Consequences

What happens if I don't register?

If you do not register with the Danish Producer Responsibility (DPA), you are considered a so-called Free-rider.

What is a free-rider?

A Free-rider is an undertaking subject to producer responsibility but not registered in the DPA producer register. This means it avoids paying environmental contributions and fails to report packaging volumes.

Why are free-riders a problem?

Free-riders undermine the system. They escape the costs paid by law-abiding companies, thus creating unequal competition.

How do you report a free rider?

Dansk Produsentsvar (DPA) offers a notification function where companies or individuals can report on possible free-riders you find it here to.

How do I avoid being considered a free-rider?

You need to make sure:
- That your company is registered in the register of the DPA
- That you are affiliated with a collective scheme
- That you report packaging quantities in a timely manner
- That you pay applicable fees

🔒 Fees

Are there fees associated with registration and reporting?

Yes, there are fees associated with registration and reporting, which cover the administration of the producer responsibility scheme.

There is a fee for the collective scheme and a fee for the Danish Producer Responsibility (DPA).

You can read more hereto.

What is an environmentally graded contribution?

An environmentally graded contribution is an economic structure designed to provide an incentive for companies to produce or produce packaging that is recyclable or recyclable.

How are environmental graded contributions determined?

The state sets the environmental graded contributions, as well as the design requirements underlying the grading. The criteria are based on a model prepared by the Environmental Protection Agency, and a final announcement setting out the criteria is expected to be published after consultation.

What criteria will be weighted in the graduation?

It is expected that the graduation will focus on:

- Minimization of material in packaging.
- The recyclability of the packaging.
- The amount of recycled material in the packaging.
- the presence of hazardous substances in the packaging.

🏡 Collective scheme

What is a collective scheme?

A collective scheme is an approved organisation that carries out the statutory obligations of producers under producer responsibility.

What does the collective scheme do concretely?

The collective scheme provides, inter alia, for:
- Reporting of packaging volumes on your behalf
- Calculation and collection of fees
- Ensuring proper sorting and recycling
- Compliance with legal requirements and documentation to authorities

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