Free riders
Companies that make products available on the market without being registered. Most of them are not doing it on purpose. Here is what it means, and how you get sorted quickly.
You can be a free rider without knowing it
A free rider is a company that has producer responsibility but does not meet it. It makes products available on the Danish market without being registered in the Danish producer register (Producentregistret) at DPA (Dansk Producentansvar) and without paying for the waste the products end up as. The bill lands instead with the companies that follow the rules.
Very few do it deliberately. The rules have been rolled out one product area at a time, and many only realise late that importing, an own brand or an online shop makes them a producer. But ignorance does not exempt you from the responsibility. See who is covered.
Same product, same responsibility. The free rider is the one who does not meet it, deliberately or not.
Typical unintentional free riders
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The online shop that imports goods and does not know that the importer counts as the producer.
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The company that only thinks about the product and forgets the packaging around it.
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The foreign seller reaching Danish consumers through distance selling.
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The own-brand company where the supplier "probably takes care of it".
What is at stake
Without registration you face three risks, and they grow the longer you wait.
Fines
Missing registration, reporting or payment can be punished with a fine under the ministerial order for that product area.
Sales stop
Without registration you effectively cannot lawfully place your products on the Danish market.
Back-dated bill
The responsibility does not disappear over time. The longer you wait, the more there is to clean up retrospectively.
Back-dated bill
Registration
must be sorted
Reporting
the missing volumes
Environmental contribution
for what is missing
Total
grows over time
The responsibility does not disappear because it was discovered late. It has to be cleaned up retrospectively.
The Danish Energy Agency (ENS) supervises whether producers are registered and report correctly, and DPA's register makes it visible who is missing. Competitors can also report free riders. They are the ones paying the bill when others do not. See who does what.
Legal basis. The duty to register and report, and the penalty provisions, are set out in the ministerial orders for each product area. See the individual product area for what applies to you.
From free rider to registered in a few days
If you discover that the rules apply to you, the most important thing is to act now. We have got many companies safely sorted, and we do not judge. No notice period and no set-up fee, see what membership costs.
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1
Work out your product areas
We go through your products and find the product areas you are covered by. The quiz gives you a quick indication.
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2
We register you in the Danish producer register
We help you all the way through the registration, including the fiddly MitID approval, and sort out the retrospective side together with you.
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3
You are covered going forward
You supply your figures, we validate and report on to DPA on your behalf, with reminders before every deadline.
Worried that you are a free rider?
Then let us find out. Book a call and we will go through your situation discreetly and get you sorted quickly. No wagging fingers.
