Extended producer responsibility for reusable packaging
If you place packaging designed to be used many times on the market, you have producer responsibility. The rules are different from single-use packaging.
About producer responsibility
Other product areas
What you must comply with for Reusable packaging
Producer responsibility covers many different obligations. We have gathered the nine most common, so you can quickly see which ones apply to reusable packaging.
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.
PRO required
Voluntary. You can meet the obligations yourselves or through a PRO.
Relief for smaller companies
Below 8 tonnes you can report total weight split between household and business.
Eco-modulation
No eco-modulation for reusable packaging.
Ongoing reporting to the PRO
Only if you are part of a PRO. Otherwise you report to DPA once a year only.
Annual statement to DPA
Report the year's volume to DPA by 1 June at the latest.
Financial guarantee
No financial guarantee for reusable packaging.
Collection and treatment
When the packaging becomes waste, you handle take-back and treatment yourselves, possibly through a PRO.
Self-monitoring
Self-monitoring covering registration, reporting and take-back.
Packaging used again and again
Reusable packaging is designed and made to be used many times for the same purpose. It is filled, emptied and filled again, rather than thrown away after one use.
That covers both the packaging goods are shipped out on, and the packaging that is returned and reused in a loop.
Reuse has to be documented
It is not enough that the packaging can be used again. It has to meet the EU regulation's requirements for reusable packaging, and there has to be a return system that actually takes it back. If you cannot document both, the packaging must be reported as single-use packaging. That is the most important distinction in this area, and we have a checklist you can use.
See the packaging types you report in
Are you the producer?
You are the producer the first time you place reusable packaging on the Danish market. Here are four typical examples, but reality holds many more.
You use pallets and crates
You ship goods out on reusable packaging in a loop.
Returnable bottles and kegs
You sell drinks in refillable packaging.
Imports from abroad
You bring goods into Denmark on reusable packaging.
Your own return system
You run your own system for return and reuse.
Recognise even one? Then you are the producer.
Membership is voluntary for reusable packaging, but the responsibility is still yours. If you do not choose a PRO, you have to handle take-back and treatment yourselves.
One annual statement to DPA
For reusable packaging there is always an annual statement to DPA. Ongoing reporting only happens if you are part of a PRO.
There is no eco-modulation for reusable packaging. Below 8 tonnes you can report total weight split between household and business.
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 reusable packaging
The questions we get most often from companies that are new to producer responsibility for reusable packaging.
Let us carry the burden for your reusable 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.
