Frequently asked questions about packaging

New to producer responsibility for packaging? Start here

The key concepts in extended producer responsibility for packaging, explained simply.

If you are the first to place packaging on the Danish market, you are responsible for making sure it is handled correctly when it ends up as waste. In practice that means you must be registered, report your volumes and pay for the handling. We take the administrative burden off you.

Packaging is everything around the product that ends up as waste once the item is unpacked. Think of a bottle of wine. The product is only the liquid, while the bottle, the capsule, the cork and the paper label are all packaging. This applies whatever the material, from sales packaging to the transport packaging around the pallet.

Extended producer responsibility for packaging took effect on 1 January 2025. From that point companies carry the responsibility for their own packaging waste, where the municipalities used to handle it.

Two bodies, and you should not mix them up. The Danish Energy Agency (ENS) administers and enforces the rules, supervises compliance and is the appeals body. Dansk Producentansvar (DPA) operates the Danish producer register, administers the allocation of municipally collected waste and charges the regulatory fees, and DPA decides where producer responsibility sits. We are in ongoing dialogue with both on your behalf.

A producer responsibility organisation is a private organisation, approved by the Danish Energy Agency, that takes over producers' statutory responsibility for the waste. Internationally it is called a PRO (Producer Responsibility Organisation). Emballage Indberetning is the largest in Denmark measured on members.

You supply your volumes, and we take the rest. We validate the data, handle the financial responsibility, make sure the waste is collected and recycled, and take care of the reporting on to DPA. You do not have to collect or treat any waste yourselves.

Do the rules apply to you?

Find out whether your company is covered by producer responsibility for packaging.

You are covered the first time you place packaging or packaged products on the Danish market. That applies whatever your size and nationality. If you are unsure, we will work it out together.

Yes. If you bring packaged goods into Denmark, you are a producer under the rules, exactly as if you had made them yourselves. Importing never exempts you, not even small companies.

Yes. If you send parcels to Danish consumers, including from abroad, you are placing packaging on the Danish market and you are covered. That applies both to the product's own packaging and to the packaging you ship the item in.

If you sell under your own name, you are the producer, even if someone else packed the item. The responsibility follows whoever first makes the item available on the market under their own brand.

Yes. All companies are covered, whatever their size, if they place packaging on the Danish market. A small volume only changes how detailed your reporting must be, not whether you are covered.

No. There is no exemption from producer responsibility for being a micro-enterprise. Whether you have producer responsibility is decided by your role and by how your packaging reaches the market, not by your size. If you are unsure, get in touch with us.

Yes. If you make packaging available on the Danish market without being established in Denmark, you must register in the Danish producer register. If you are established in another EU country, the rules require an authorised representative for extended producer responsibility (EPR representative) in Denmark, and that is a role we provide free of charge. If you are established outside the EU, you can register yourselves or use us as your representative.

The responsibility only covers packaging you place on the Danish market. Packaging around goods you sell exclusively out of Denmark is generally not covered. If your sales are a mix of Danish sales and exports, we will help you work out the right share.

How much do you make available on the market?

The de minimis threshold of 8 tonnes and what your packaging volume means for reporting.

The de minimis threshold is 8 tonnes (8,000 kg) of packaging made available on the market per year. It decides how detailed your annual report must be, but not whether you are covered. If you make packaging available on the market, you must report, however little it is.

Below 8 tonnes you can make do with declaring the total weight of all your packaging. From 8 tonnes you must report in detail, split across the individual materials: cardboard, paper, plastic, glass, ferrous metals, aluminium, beverage and food cartons, wood and the remaining categories. Detailed reporting also triggers eco-modulation.

You work out how many kg of packaging you placed on the Danish market during the year, split by material if you are above the threshold. Many take the figures from purchase invoices, product data or supplier information. We help you with the method, so you get it right.

You do not need everything in place from day one. We help you make an informed estimate based on what you know about your goods and packaging, and to tighten it up over time. The main thing is to get started.

When do things have to happen?

Registration in the Danish producer register and the deadlines for reporting packaging.

You must register in the Danish producer register (Producentregistret, at DPA) no later than 14 days before you start making packaged products available on the Danish market. If you are already under way, you must be registered as soon as possible. We will take you through the registration.

There is an annual report to DPA before 1 June covering the previous calendar year. On top of that you report the environmental contribution on an ongoing basis. We keep track of every deadline, so you always meet them on time.

It follows your volume. From 8 tonnes per year you report monthly. If you are below, you report quarterly.

You supply your volumes to us, and we report on to DPA on your behalf. We validate the figures first, so they are correct when they reach the authorities.

Do not worry about the deadlines. Keeping track of them for you is exactly what we do, so you do not have to remember them yourselves. If you are behind, we will help you catch up.

What does it cost?

Membership, the environmental contribution and regulatory fees for producer responsibility for packaging.

Membership for packaging costs from DKK 795 per year (excl. VAT) on a 3-year agreement, DKK 895 on 2 years and DKK 995 on 1 year. From 8 tonnes per year you have to report in detail, and there is a supplement of DKK 999 per year. On top of the membership come your environmental contribution and the authorities' fees.

There is no notice period with us, and no set-up fee. If you stop, the termination takes effect immediately, and we then send no invoices for the rest of the period and do not hold you to continued reporting. Several other PROs have, by comparison, a notice period of up to 12 months or a minimum of one year's commitment.

The environmental contribution covers the actual handling of the waste and is paid per kg based on your reported volumes. It depends on the material, on whether the packaging is for household or business, and on the eco-modulation. So it is not a fixed amount, it follows what you make available on the market.

The environmental contribution covers the handling of the waste itself. The regulatory fees to DPA and the Danish Energy Agency are administration fees and are invoiced separately. They are two different things, and we show you both clearly.

Eco-modulation means the environmental contribution is adjusted according to how easy the packaging is to recycle. If it is hard to recycle, the contribution goes up. If it is easy, you pay less. You must eco-modulate from 8 tonnes per year. Below the threshold it is voluntary.

The state sets the design criteria and the method: red packaging carries a malus of 35% on top of the base rate, and the money is used as a bonus for green packaging in the same material, where green and yellow always pay at least 20% of the base rate. The rates per kilo are our own. Each PRO sets its own rates, and that is why prices vary between PROs. The design criteria look at material composition, density, colour and sortability, barriers, adhesives and printing inks, and content of recycled material.

Yes. Since we have no commitment period, you can switch to us as soon as your current agreement allows it. Several PROs have at least a year's commitment period or notice period, so check your terms. We will help you with the switch itself.

What counts, and what gets confused

Deposit-refund, reusable packaging, packaging tax and single-use plastic against packaging.

No. Bottles and cans covered by the deposit-refund system fall under that system and are regulated separately. You should not report those to us as packaging.

For single-use packaging, membership of a PRO is required by law. For reusable packaging it is voluntary. Reusable packaging falls under the same ministerial order, but you decide yourselves whether to sign it up.

Two completely separate sets of rules. Producer responsibility is about the waste after the item and funds collection and recycling. Packaging tax is an excise duty on the item itself and is paid to the Danish Tax Agency (Skattestyrelsen). The same bottle can trigger both, but they are two bills to two authorities. We handle producer responsibility, and tax questions you settle with your own accountant or the Danish Tax Agency.

Producer responsibility for packaging covers all types of packaging whatever the material. Producer responsibility for single-use plastic covers specific single-use plastic products, for example cups and beakers. A product can be covered by both. We cover both, with one subscription per product area and one combined invoice.

No. For single-use packaging you do not have to collect or treat the waste yourselves. The PRO makes sure it is collected and recycled, funded by the environmental contribution. Reusable packaging is the exception: there you take the packaging back yourselves and pay for treating it. You supply your volumes, and we take care of the rest.

Free riders and consequences

What it means to be a free rider, and how to avoid it.

If you are covered without being registered in the Danish producer register, you count as a free rider. That is not a place you want to be, because you are outside the system and risk being approached by the authorities. The simplest thing is to get started, and we will help you with that.

A free rider is a company that is covered by producer responsibility but is not registered in the Danish producer register. They avoid the costs that law-abiding companies pay.

Free riders undermine the system. They avoid costs that law-abiding companies carry, and they create unequal competition. That is why there is both supervision and the option to report them.

Yes. DPA has a reporting function where companies and private individuals can report suspected free riders. DPA also carries out its own official supervision.

Make sure of four things. That you are registered in the Danish producer register, signed up to a PRO, reporting on time and paying your contribution. If you become a member with us, we help you with all of it, so you are on the right side.

Frequently asked questions about producer responsibility for packaging