De minimis threshold
The de minimis threshold does not decide whether you are covered, but how you report your packaging. The threshold is 8 tonnes of packaging made available per year under the Danish packaging order, and it is counted separately for single-use packaging and reusable packaging.
Small volumes, less work, but still an obligation
The de minimis threshold is purely a packaging rule and does not decide whether you are covered, but how you must report your packaging. The threshold is 8 tonnes of packaging made available on the market per year under the Danish packaging order.
Whatever your volumes, you must be registered in the producer register (at DPA), be part of a producer responsibility organisation (PRO) for single-use packaging, report every year (the deadline is 1 June, and we handle that for you) and pay the environmental contribution. The threshold only changes how detailed your reporting is, and therefore what you pay.
If you come across the figure 10 tonnes, it is not a mistake. The EU packaging regulation sets a threshold of 10 tonnes, and that is the one that applies in the other EU countries. In Denmark the threshold is 8 tonnes until DPA says otherwise, and it is the Danish threshold your reporting here has to follow.
Below 8 tonnes per year: one combined weight
From 8 tonnes: split across materials
Two ways to report
Below 8 tonnes you can choose between combined and detailed reporting. From 8 tonnes, detailed is a requirement. The difference lies in what you declare and what you pay.
| Combined (simplified) | Detailed | |
|---|---|---|
| Who can use it | Only companies below 8 tonnes per year | Voluntary below 8 tonnes, a requirement from 8 tonnes |
| What you declare | The total weight of your packaging, split between household and business | The weight split across the individual materials (cardboard, paper, plastic, glass, metal, cartons, wood) |
| What you pay | One combined price per kg for household and one for business, set as an average across materials | The price per kg for each material, typically lower than the combined price |
| Eco-modulation | Does not apply | Applies, green pays less than red |
| Membership | Standard | Detailed membership (+DKK 999 per year) |
Why many choose detailed, even below the threshold
Because the combined price is an average, you can often pay less by reporting in detail, if the bulk of your packaging weight sits in the cheap materials, for example cardboard and paper.
Detailed reporting requires a detailed membership (+DKK 999 per year), which gives access to detailed reporting and the lower material rates. See the prices.
Example with 7,000 kg of household packaging
- Combined reporting, 7,000 kg × DKK 3.79 per kg (combined household rate)
- DKK 26,530
- Detailed, if it is cardboard for example, 7,000 kg × DKK 1.60 per kg (cardboard, household, green)
- DKK 11,200
The rates are 2026 figures excl. VAT. If you have a lot of cardboard or paper, you can save a significant amount by going detailed.
If you cross the threshold
If you cross 8 tonnes during the year, you must upgrade to a detailed membership to get access to detailed reporting.
From 8 tonnes, detailed reporting is a requirement, and eco-modulation applies to your contribution.
The volume grows over the year
Above the threshold: detailed
Not sure where you stand?
Or whether going detailed pays off best? Book a short call and we will work it out together.
