Producer responsibility for packaging

What it means for your business

Producer responsibility for packaging

What it means for your business

What does producer responsibility for packaging mean for your business?

On July 1st 2025 the extended producer responsibility for packaging will enter into force in Denmark as one of the last countries in EU. From 1. April to 31. August 2024, you must register and report expected quantities that your company will bring on the market in 2024. We help you in all these steps.

Sign up for our free webinar

Product manager Lars Bruntse presents the various requirements and rules, deadlines, reporting details, and how ERP Denmark as collective scheme help and guide you.

Webinars in English:

18.4 at 10.00 am CET – Partake >
21.5 at 2.00 pm CET – Partake >

Webinarer på dansk:

18.4 2024 kl. 13.00 – Tilmeld >
1.5 2024 kl. 9.00 – Tilmeld >
21.5 2024 kl. 9.00 – Tilmeld >
12.6 2024 kl. 9.00 – Tilmeld >

The Purpose with the extended producer responsibility is to

Reduce the amount of packaging

ERP Batteries Recycling Icon

Increase real reuse and recycling of packaging materials

Force companies to re-design to more circular packaging

The companies will get full responsibility for the quantity (weight) of packaging they put on the market and the handling of it in all of its life cycle. It includes:

  • Administrative and legal responsibility (documentation requirements and labelling).
  • Economic responsibility (companies to finance costs for logistics, sorting, recycling, registration.
  • Practical/physical (sorting in material types).

We help you all the way!

The legislation for producer responsibility for packaging and the accompanying finances and practice for companies has not yet been finally settled. The first part of the local legislation was be issued in Q1 2024 and the second part in Q4 2024. You are obliged to register your company with DPA (Danish Producer Responsibility) and report expected quantities for full year 2024 from 1. April 2024 to 31. August 2024. In addition you must choose compliance scheme.

As a eco-modulated compliance fee will be introduced, depending on the ‘design for recycling’ of the packaging, a re-design process is also a process you should consider starting if your packaging can be optimised. Read more about the expected financial structure for your company in the FAQ section below.

By signing up for European Recycling Platform’s collective scheme for packaging we will ensure that you will become compliant in 2024 and kept informed and prepared for 2025. We guide you and help you in all aspects of registration and reporting in 2024 as well as preparing you for the 2025 reporting.

Contact us regarding the extended producer responsibility for packaging

With European Recycling Platform you are in safe hands:

  • Existing collective scheme in DK within WEEE and Batteries since 2002
  • Many years of experience with producer responsibility for packaging in other countries
  • Largest global network of experts under one roof in producer responsibility
  • One contact person across countries for all your producer responsibilities (WEEE, batteries, packaging)
  • Strong and solid owner (Landbell Group) with global coverage
  • Large scale, which ensures efficiency in administrative and practical waste treatment, where the recycling rate is high and as much product and packaging as possible is reused.
  • Cooperation exclusively with approved partners (logistics, reuse, recycling)

Make it easy and simple

As a collective scheme, European Recycling Platform (ERP) handles producer responsibility on your behalf, so you can concentrate on your core business.

Recycling Process

  1. Collection
  2. Separation
  3. Decoating (if coated)
  4. Melting
  5. Casting
  6. Manufacture

Recycling Process

  1. Collection
  2. Treatment (including sorting, cleaning and decontamination)
  3. Crushing and melting
  4. Manufacture

Recycling Process

  1. Collection
  2. Processing (including de-inking, cleaning and screening)
  3. Manufacture

Recycling Process

  1. Collection
  2. Compacting
  3. Melting
  4. Casting
  5. Rolling
  6. Manufacture

Recycling Process

  1. Collection
  2. Sorting and separation
  3. Shredding
  4. Treatment
  5. Manufacture

Recycling Process

  1. Collection
  2. Segregation
  3. Decontamination
  4. Production
  5. Final products

Simplification and efficiency. We have one point of contact across EMEA. The learnings from one market can be applied to other markets. It’s a benefit to have a common approach, a centralised point of contact which brings efficiency and cost savings.

Ramon Teixido
WW TBO Transformation Strategist, HP Inc.

FAQ

We continuously update our FAQ as local legislation and obligations are issued, decisions relevant to producer responsibility for packaging are made, and practice takes shape.

The definition of ‘Producer’ will be finally determined with the first part of the local legislation. The producer is not the company that produces the packaging, but the company that uses the packaging. The responsibility lies with the company that brings packaging to the Danish market if it is:

  • Producer (‘filler’) who brings packaging to the Danish market
  • Danish importer of packaged goods (first level distribution chain)
  • Wholesaler or re-packager
  • Foreign e-commerce store that sells directly to Danish consumers (requires authorized representative)

Approx. 41,000 companies are estimated to be covered by producer responsibility and have an obligation to register and report. Authorities are working with a threshold of 8 tons/year of packaging per year. Below this threshold, Producers can choose to report less detailed.

Sales packaging and transport packaging are covered:

  • Primary (sales packaging, following the unit)
  • Secondary (multi pack)
  • Tertiary (transport packaging as pallets, strips etc)

Material fractions that are covered are:

  • Cardboard
  • Paper
  • Plastic (will be sub-divided into 4 categories)
  • Glass
  • Aluminum
  • Metal
  • Wood
  • Food and beverage cartons

Yes, producer responsibility covers household packaging as well as commercial packaging. Both types must be reported.

Household packaging

  • The packaging ending up in consumers waste bins
  • Collected at households (expensive)
  • Waste packaging collected at recycling sites (genbrugspladser) is expected to become part of the scope later (cardboards in step one)

Commercial packaging

  • Packaging not reaching consumers and their waste bins
  • Typically packaging from incoming goods

Companies can be looking forward to having to:

  • Register at DPA from 1. April 2024.
  • From 1. April 2024 report information about specific packagings and expected volumes (weight) to be put on market in 2024.
    • It includes packaging materials, type and fraction, chemistry, size, weight etc. Have an overview of what must be reported in the following FAQ.
  • From 1. April 2024 choose collective scheme. You can pre-register your company with ERP Denmark here. Pre-registering is non-binding and for free.
  • Inform customers about how to sort the waste packaging (labelling, pictograms etc)

As a collective scheme, ERP helps with these tasks.

A distinction is made between total quantity in kg. over/below 8 tons/year:

Over 8 tons in total:     Detailed reporting by type
Below 8 tons:               Companies can choose to report less detailed

Material/Fraction Household vol. in kg Comm. Packaging in kg
Cardboard
Paper
Metal
Aluminium
Glass
Plastic*
Food and beverage cartons
Wood
Total

*) Plastic fractions sub-divided into 4 categories)

As the legislation is not in place, no final structure and size of the costs the company faces have been determined. With our knowledge from other producer responsibilities, we currently expect a threefold division:

  • General administrative fee.
  • Graduated environmental contribution fee based on an average (dkk pr. ton pr. type of packaging). Will be graduated up/down depending on the ‘environmental correctness’ of the packaging
  • Annual membership fee for the Collective Scheme (for legal, administrative and practical work)

This kind of contribution fee is introduced to force companies to think circular in their packaging design. The fee will be calculated in dkk pr. ton pr. type of packaging. Depending on the recyclability of the packaging it will be categorised in eg. High/Medium/Low. It can be transferred to ‘Low’ contribution if it is following a range of not yet decided criteria. Examples:

  • Less packaging volume
  • The packaging materials are separate or easy to disassemble in various fractions
  • Use of pure and environmentally friendly materials
  • Use of recycled materials
  • No use of hazardous chemistry (eg. mineral based printing)

Structure and size of this fee is still under preparation.

The collective schemes take care of producer responsibility on behalf of the producer/company. Eg. keeping reporting deadlines, administrative tasks, compliance to changing legislation and rules etc.

To be sure of meeting changing  requirements and obligations, registration and reporting etc. it is recommendable to join a collective scheme. Time used to take care of the legal, administrative and practical tasks individually can in practice be used better and probably also cheaper by letting a collective scheme take care of the responsibility on your behalf. It also allows you to focus on the company’s core tasks and reduces complexity in the company.

There is a difference in the profiles of the collective schemes. Is it important that the collective scheme is present internationally as one and the same group or only in Denmark? Is it essential that the collective scheme covers several product responsibilities such as WEEE, batteries and packaging? Consider which collective scheme will suit your needs the best.

You can sign up for ERP Denmark ApS’ collective scheme at any time.

For the upcoming producer responsibility for packaging, pre-register here (free and without obligation until the final scheme comes into force).

To register for producer responsibility for electronic and electrical waste and/or batteries, register here.

If you have any questions, you can always call us for further information. See contact persons here.