Producer responsibility for packaging implies that manufacturers and importers are legally, financially and operationally responsible for handling the packaging they make available when it becomes waste. This follows the principle that the polluter pays.
The extended producer responsibility for packaging will come into force on 1 January 2025 across the EU.
In Denmark, producer responsibility for packaging is regulated by several ordinances, including “Ordinance on certain requirements for packaging, extended producer responsibility for packaging and other waste collected with packaging waste”.
Companies that manufacture, import or sell packaged products on the Danish market are covered by producer responsibility. This also includes companies that have packaging manufactured under their own name or trademark.
Are small businesses also covered by producer responsibility?
Yes, all companies, regardless of size, are covered by producer responsibility if they make packaging available on the Danish market.
The aim is to promote recycling and sustainable management of packaging waste by placing responsibility with manufacturers, which should reduce the environmental impact of packaging.
A collective scheme is an organisation that carries out, on behalf of producers, their obligations under producer responsibility, including collection, recycling and reporting.
From 1 January 2025, companies subject to producer responsibility for packaging are obliged to be members of one or more collective schemes capable of fulfilling their obligations.
Manufacturer responsibility for packaging covers all types of packaging, while producer responsibility for single-use plastic products specifically addresses products made from plastics that are designed for single use.
Yes, a package may well be covered by both producer responsibility on packaging and producer responsibility on single-use plastic products.
Failure to comply may result in penalties, including fines, and may damage the company's reputation.
Companies must register in the producer register with the Danish Producer Responsibility (DPA) and report the quantities of packaging they put on the market. An annual report must also be made to the Danish Producer Responsibility. At Emballage Indberetning ApS we take care of this.
Companies must register no later than one month after they start making packaging available.
Reporting is done annually through our platform, where companies indicate the quantities and types of packaging they have placed on the market. We then ensure proper reporting to the authorities in the appropriate format.
Yes, there are fees associated with registration and reporting, which cover the administration of the producer responsibility scheme. There is a fee for the collective scheme and a fee for the Danish Producer Responsibility (DPA). You can read more here.
The amount of the fee often depends on the quantities and types of packaging the company makes available.
Membership fee for our solution depends on the number of years you wish to be a member and whether or not you are covered by the extended reporting. You can see our prices here.
An authorised representative is a person or company appointed to perform the obligations of a producer under producer responsibility in Denmark. This could be, for example, Emballage Indberetning ApS.
Companies established in another EU Member State or in a third country become producer responsible when selling to an end user in Denmark and must therefore have an authorised representative.
Appointment is made by a written agreement, in which the representative agrees to assume responsibility for the obligations of the producer.
The administrative minimum limit means that companies that annually make less than 8 tonnes of packaging available on the Danish market can choose to report less information about their packaging. This reduces administrative burdens for these companies.
No, companies are not exempt from producer responsibility. They still have to:
An environmentally graded contribution is an economic structure designed to provide an incentive for companies to produce or produce packaging that is recyclable or recyclable.
The state sets the environmental graded contributions, as well as the design requirements underlying the grading. The criteria are based on a model prepared by the Environmental Protection Agency, and a final announcement setting out the criteria is expected to be published after consultation.
A free-rider is a company that is covered by the producer responsibility for packaging, but which is not registered in the regulatory register with the Danish Producer Responsibility (DPA).
Free-riders avoid paying the statutory contributions and meeting their obligations, creating an unequal competitive advantage and increasing the burden on companies that comply.
Dansk Produsentsvar (DPA) offers a notification function where companies or individuals can report on possible free-riders you find it here.
Following a notification, the DPA and relevant authorities will investigate the matter and take the necessary steps to ensure that the company fulfils producer responsibility.
Companies should ensure that they are properly registered with DPA and fulfil their obligations under producer responsibility, including reporting and payment of contributions.
Do you have any further questions? Finally, ask! You can contact us here.