Companies covered
The rules apply to many more companies than people think. Find your situation below and see whether you have producer responsibility.
If you are first, it is you
If you are the first to place a product or its packaging on the Danish market, you have producer responsibility as a starting point.
"Making available on the market" covers more than manufacturing. You make the item, import it, fill your products into packaging or sell it under your own brand. What matters is that the item has not been on the Danish market before you. How producer responsibility fits together.
Whoever makes the item available on the market first has the responsibility. Not whoever resells it.
Find your situation
You can easily be in several situations at once. Each of them makes you a producer.
You manufacture products or packaging
You make goods or packaging and sell them in Denmark, directly or through retailers.
You import goods
You buy goods in from abroad, with or without packaging around them, and sell them on here. Under the rules, the importer is the producer.
You pack your goods into packaging
You fill your products into bags, boxes, jars or cans and sell them on. The responsibility covers the packaging around the item.
You sell under your own brand
The item carries your name or trademark. That makes you the producer, even if someone else made it.
You sell through an online shop or distance selling to Danish consumers
Including from abroad. If you are established in another EU country and sell directly to Danish end users, 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, where a representative is required. We provide the role free of charge in both cases.
You unpack goods and throw the packaging away
You receive packaged goods, unpack them and pass the goods on without the packaging. Since 12 August 2026 that makes you the producer of the packaging you throw away.
One product can trigger several responsibilities
A cordless drill triggers three at once. Packaging (the box), batteries (the built-in battery) and electronics (the machine itself). So check all the product areas, not just the obvious one. The quiz gives you a quick indication in a couple of minutes.
The de minimis threshold decides how, not whether
The de minimis threshold is purely a packaging rule and does not decide whether you are covered, but how you must report your packaging. Below 8 tonnes per year you can make do with a simplified report.
Several other product areas have no de minimis threshold at all. For batteries and single-use plastic the obligation applies from the first unit.
Below 8 tonnes per year: one combined weight
From 8 tonnes: split across materials
Still unsure whether you are covered?
Book a call and we will go through your products together. 20 minutes, no obligation.
