What is extended producer responsibility?
Whoever first places a product on the Danish market carries the responsibility for the waste that the product and its packaging end up as. Here is what that means for you.
The responsibility follows the product, not the bin
The municipalities and consumers used to pay for handling the waste. With extended producer responsibility the bill moves to whoever first made the product available on the market. If you make goods available, you pay for them to be collected and recycled once they have been used.
The underlying principle is called polluter pays. The rules come from the EU and are rolled out one product area at a time in Danish law. The Danish Energy Agency (ENS) enforces them, and every producer is registered in the Danish producer register (Producentregistret), which DPA (Dansk Producentansvar) operates and where volumes are reported.
For packaging, the obligations are set out in the Danish packaging order (BEK no. 1146 of 29 September 2025), and from 12 August 2026 the EU packaging regulation PPWR (EU) 2025/40 applies directly alongside it. Each product area has its own Danish ministerial order with its own deadlines and rates. See the legislation for packaging
The responsibility hangs on the product, not on the bin. That is why the bill follows whoever makes it available on the market.
"Producer" is broader than it sounds
Under the rules, the producer is whoever first places the product on the Danish market. That covers more roles than classic manufacturing.
Producers
You manufacture products and sell them in Denmark.
Importers
You buy goods abroad and sell them on here in Denmark. Under the rules you are a producer.
Online shops and distance selling
You sell directly to Danish consumers, including from abroad. If you are established in another EU country, the rules require an authorised representative for extended producer responsibility (EPR representative) in Denmark. If you are established outside the EU, you can register yourselves today, except for batteries.
Own brand
You sell goods under your own name or trade mark, even if someone else manufactured them.
You can be in several of these roles at once, and each one makes you a producer. Companies covered shows the typical situations, and the quiz takes a couple of minutes.
Three obligations, whatever the product area
The details vary from one product area to the next, but the basic structure is the same. Here you can see what you handle yourselves, and what we take care of for you.
Emballage Indberetning
In several product areas, being part of a producer responsibility organisation (PRO) is required by law. In the others it is voluntary.
If you choose the individual route, collection, documentation and reporting all sit with you. How a PRO works
The environmental contribution follows the volumes you report, and the authorities' fees come on top. See the prices.
Three parties, one role each
Producer responsibility is run by three bodies. The one you deal with most is the PRO, which takes the work off your hands.
Companies that make products available on the market without being registered are called free riders. Most are not free riders on purpose, but not knowing does not release you from the responsibility. See what that means, and how to put it right.
The Danish Energy Agency
Administers and enforces the rules, supervises compliance, and can issue orders and fines.
DPA (Dansk Producentansvar)
Runs the producer register. This is where companies are registered, and where volumes are reported.
The PRO
Takes over producers' legal responsibility. Validates the volumes, handles the financial responsibility, and reports on to DPA on the members' behalf.
You, the producer
You supply your volumes to us. Then you are covered, and we run the rest.
Producer responsibility is not a tax
Many people confuse extended producer responsibility with excise duties to the Danish Tax Agency (Skattestyrelsen). They are two separate sets of rules that often hit the same product. Producer responsibility is about the waste after the product, the duty is about the product itself. The same bottle can trigger both, but they are two bills to two authorities under two laws.
| Extended producer responsibility | Excise duty to the Danish Tax Agency | |
|---|---|---|
| Authority | DPA and the Danish Energy Agency | The Danish Tax Agency |
| Purpose | The producer finances collection and treatment of the waste | A duty on the product itself |
| Who pays | Whoever first places the product on the Danish market | Typically a registered warehouse keeper or consignee |
| How it is met | Registration in the Danish producer register, reporting and membership of a PRO | Registration with the Danish Tax Agency, duty returns and payment |
We are not tax or duty advisers. We explain the difference and point you in the right direction. Specific duty questions belong with your accountant or the Danish Tax Agency (Skattestyrelsen).
One principle, eight product areas
The rules are rolled out one product area at a time, each with its own legislation, its own deadlines and its own rates. We are the only PRO approved across all six producer responsibility areas.
Packaging, reusable packaging, single-use plastic, fishing gear, electronics, batteries and vehicles, with textiles to follow once the legislation takes effect. Find the product area that applies to your products.
What does this mean for you?
Book a call and we will translate the rules into your products, your volumes and your deadlines. 20 minutes, no obligation.
