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Extended producer responsibility for packaging

If you place packaging on the Danish market, you are responsible for making sure it is handled correctly when it becomes waste. We make the rules understandable and possible to meet.

Packaging on the Danish market

What you must comply with for Packaging

Producer responsibility covers many different obligations. We have gathered the nine most common, so you can quickly see which ones apply to packaging.

Full requirementPartial requirementNot required

Registration in the Danish producer register

Register in the producer register (with DPA) no later than 14 days before you first make products available on the market.

Full requirement

PRO required

Single-use packaging must go into a PRO. Reusable packaging is voluntary.

Full requirement How the PRO works

Relief for smaller companies

Below 8 tonnes you can report total weight only.

Eco-modulation

The contribution is modulated according to the packaging's design and recyclability.

Full requirement See eco-modulation

Ongoing reporting to the PRO

Report volumes on an ongoing basis, monthly from 8 tonnes, otherwise quarterly.

Full requirement

Annual statement to DPA

Report the year's volumes to DPA by 1 June at the latest.

Full requirement

Financial guarantee

Only where municipal packaging waste has been allocated to you. Your PRO provides it for you.

Partial requirement

Collection and treatment

You cannot go it alone. The PRO handles collection and treatment for you.

Not required

Self-monitoring

Carry out documented self-monitoring at least once a year. The PRO can do it for you.

Full requirement

Everything that goes around the product

Think of a bottle of wine. The product is only the wine itself, the liquid. Everything around it is packaging. The bottle, the capsule, the cork and the paper label.

It works the same way for every product. Packaging is the outer layer that protects and carries the goods, and that becomes waste once the product is unpacked. That applies whatever the material, from sales packaging to the transport packaging around the pallet.

See the material categories you report in
Wine bottle, where the glass is packaging
Cork and capsule
Paper label on the bottle

Are you the producer?

You are the producer the first time you place packaging on the Danish market. Here are four typical examples, but reality holds many more.

Factory in Denmark

You manufacture goods here and pack them for sale.

Import from abroad

You bring packaged goods into Denmark.

Online shop and distance selling

You send parcels to Danish consumers, including from abroad.

Own brand

You have the goods packed by someone else and sell them under your own name.

Recognise even one? Then you are the producer.

There are many more situations, and some sit in a grey area. If you are unsure, we work it out together.

Small volume, less work. Still an obligation.

The de minimis threshold is about volume. It decides how detailed your annual report has to be, not whether you are covered. If you make packaging available on the market, you have to report however little it is.

Read more about the de minimis threshold

Note. A low volume does not exempt you.

Whatever the volume, you have to be registered in the Danish producer register, report every year and pay the environmental contribution. The only thing the volume changes is how detailed the report is.

Under 8 tonnes

Keep it simple. You report the total weight for all packaging. Detailed reporting is optional.

From 8 tonnes

Detailed reporting is required. You split the volume across the individual materials: cardboard, paper, plastic, glass, ferrous metals, aluminium, beverage and food cartons, wood and the remaining categories.

A small company is not the same as an exempt company

There is no exemption from producer responsibility for being a small company or a micro company. Whether you have producer responsibility is decided not by your size, but by your role (manufacturer, importer, seller) and by how your packaging reaches the market.

Whatever your size, you therefore have to be registered in the Danish producer register, be part of a PRO for single-use packaging, and report every year. If you are unsure what applies to your situation, get in touch.

Annual report and ongoing environmental contribution

For packaging there is always an annual report to DPA. On top of that you report the environmental contribution on an ongoing basis, and how often depends on your volume.

Q1environmental contribution to the PRO. From 8 tonnes per year you report monthly.
Q2
Q3
Q4
By 1 JuneThe annual report to DPA. We gather your volumes for the previous year and report on your behalf.

You supply your volumes to us. We keep track of every deadline, so you always meet them on time.

The easier to recycle, the lower the contribution

Every material has a base price. On top of that comes eco-modulation. If the packaging is hard to recycle, the contribution goes up. If it is easy, you pay less.

You have to apply eco-modulation to your packaging from 8 tonnes per year. Below that threshold it is voluntary.

Understand eco-modulation

Contribution per material

Red packaging pays a surcharge on top of the base rate, and the money goes as a bonus to green in the same material. The proportions are indicative.

Paper
Cardboard
Glass
Metal
Plastic
Cartons
Wood
Base rate Yellow eco-modulation Red eco-modulation

Do you have responsibility in several product areas?

One product can trigger several producer responsibilities at once. A cordless drill is packaging, batteries and electronics all at once. We cover every product area, with one subscription per area and one combined bill.

Questions about packaging

The questions we get most often from companies new to producer responsibility for packaging.

Yes, if you make single-use packaging available on the market. Then membership of a PRO is required by law. For reusable packaging it is voluntary. We take on the burden and the reporting to DPA on your behalf.
The de minimis threshold is 8,000 kg of packaging made available on the market per year. Below the threshold a single combined report is enough. Above it you have to report in detail by material category. You have to be registered and report whatever the volume.
There is an annual report to DPA by 1 June for the previous calendar year, and we handle that for you. On top of that you report the environmental contribution on an ongoing basis, monthly from 8 tonnes per year and quarterly if you are below. We keep track of the deadlines.
The environmental contribution covers the actual handling of the waste and depends on the material and the eco-modulation. The regulatory fees to DPA and the Danish Energy Agency are administrative fees and are charged separately. They are two different things.
No. Bottles and cans covered by the deposit system fall under that system and are regulated separately. Reusable packaging falls under the same ministerial order as packaging, but with voluntary membership of a PRO.
No. For single-use packaging you do not have to collect or treat the waste yourself. The PRO makes sure it is collected and recycled, and it is funded by the environmental contribution. Reusable packaging is the exception: there you take the packaging back yourself and pay for treating it. You supply your volumes, and we take care of the rest.

Compensation request

Requesting compensation for commercial packaging waste? Use the form to submit your request.

Let us carry the burden for your packaging

No notice period, no set-up fee, and one contact for all your product areas. Call or write, and we will work out what applies to you.

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