Legislation
Producer responsibility for packaging rests on two sets of rules, one Danish and one European. Here is what they are, what is covered where, and where to find them.
Two sets of rules, one responsibility
The Danish Packaging Order is the Danish ministerial order that sets out the practical obligations. The Packaging Regulation PPWR applies directly across the EU without Danish implementation and covers both the requirements for the packaging itself and the producer responsibility for it.
The two sets of rules do not replace each other. Danish producer responsibility continues alongside PPWR, with registration, reporting and the environmental contribution as before. How the EU and Denmark fit together.
The regulation is the frame and applies across the EU. The order fills in the Danish part.
The Danish Packaging Order (BEK no. 1146 of 29 September 2025)
The Danish ministerial order that sets out the practical obligations, that is registration, reporting, membership of a producer responsibility organisation (PRO), eco-modulation, the de minimis threshold and self-monitoring.
The Packaging Regulation PPWR (EU) 2025/40
The EU regulation on packaging and packaging waste, which applies directly across the EU from 12 August 2026, covering substance requirements, labelling, recyclability and the EU declaration of conformity.
What is covered where
PPWR regulates two things: the requirements for the packaging itself (substance requirements, labelling, recyclability, declaration of conformity) and producer responsibility for the packaging (who counts as the producer, the producer register, extended producer responsibility and the authorised representative for extended producer responsibility). The Danish packaging order sets out how producer responsibility is administered in Denmark: registration in the Danish producer register, reporting deadlines, the de minimis threshold, eco-modulation and self-monitoring. Where the two disagree on a specific Danish question, it is Danish law and the authorities' administration you have to follow.
| Topic | Set of rules | What it means for you |
|---|---|---|
| Registration in the producer register | The Danish Packaging Order | You are registered in the Danish producer register before you first make packaging available on the Danish market. We help you all the way through. |
| Annual reporting of volumes | The Danish Packaging Order | You report your volumes every year, and we report on to DPA on your behalf. |
| Producer responsibility organisation (PRO) | The Danish Packaging Order | Single-use packaging must be handled through a PRO. |
| Eco-modulation | The Danish Packaging Order | The contribution depends on how easy the packaging is to recycle. |
| De minimis threshold of 8 tonnes | The Danish Packaging Order | Below 8 tonnes you can report combined, from 8 tonnes you must report in detail. |
| Self-monitoring | The Danish Packaging Order | You must be able to document the volumes you report. |
| Substance requirements and recyclability | PPWR | The packaging must meet requirements for content and design. |
| Labelling | PPWR | The packaging must be labelled according to common EU rules. |
| EU declaration of conformity | PPWR | The manufacturer signs to confirm that the packaging meets the requirements, backed by technical documentation. |
| Producer definition and authorised representative | PPWR | Who counts as a producer, and when a foreign company must appoint an authorised representative for extended producer responsibility (EPR representative) in Denmark. |
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