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Extended Producer Responsibility for Packaging (EPR)2026-04-20T13:08:24+02:00

Extended Producer Responsibility for Packaging (EPR)

What it means for your business

Producer responsibility for packaging

What it means for your business

ERP Denmark are on ongoing basis conducting webinars on EPR for packaging in Denmark, covering relevant topics and general updates.

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What does producer responsibility for packaging mean for your business?

On October 1st 2025 the extended producer responsibility for packaging entered into force in Denmark as one of the last countries in EU. As Producer (manufacturer, importer, distributor, trading company and foreign distance seller into DK) you have a range of obligations.

Did you miss the deadline? You can and must still register and become compliant and thereby remove the risk of getting fines for non-compliance. We help you in all these steps.

There are two requirements:

1. You must register with a collective scheme (e.g. ERP Denmark)

It is a requirement to be a member of a collective scheme! Press Registration on the red button above, and you will be guided through, easy and simple.

2. You must be registered in the DPA register

Once you have registered with us, we will send you the necessary material to fill out so that you can be registered with your quantities in the DPA-register. If you are a Danish company, we will ensure that you register and guide you on how to approve the registration in the DPA register with MitID Erhverv. If you are from abroad (from EU/EEA country) you must register yourself and choose ERP Denmark as your Authorised Representative in the process (requirement if your are establised in another EU or EEA country).
Of course, we will also advise you on which packaging you should/should not report.

October 1, 2025 is set as the effective date when the compliance fee per kilo starts.

Quarterly reporting is required for all EASY and CIRCULAR members, whereas GO members report on annual basis. The reporting is done in your collective scheme’s reporting portal, Circul8.

If you are below 8 tonnes, this reporting is simple. If you are above 8 tons, you must report per material type and whether the material is in the red/green level, depending on recyclability (environmental eco-modulation).

You are always welcome to contact us for questions and guidance.

The Purpose with the extended producer responsibility for packaging 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 with packaging reporting

The first part of the local legislation was issued in Q1 2024 and the second part in Q4 2024. Changes has been made several times since.

You are obliged to register your company with DPA (Danish Producer Responsibility) and report packaging quantities. In addition you must choose collective scheme.

By signing up for European Recycling Platform’s collective scheme for packaging we will ensure that you will become compliant and kept informed and prepared for upcoming reportings. We guide you and help you in all aspects of registration and reporting as well as preparing you in due time. We care about you being compliant.

Contact us regarding ERP’s Packaging Scheme

Eco-modulation of packaging – how it affects your costs

With the introduction of Eco-modulated fees, the waste-management fee per kilo of packaging will be adjusted according to how recyclable and environmentally sound the packaging is. In short: the better the design for recycling, the lower the fee – and vice versa.

Each packaging component is placed in an environmental tier: Red, Yellow or Green. If the packaging does not meet the design criteria, or if you cannot document compliance, it will be placed in the Red tier and subject to a surcharge (malus) on the waste-management fee – currently up to 35% extra per kilo. If the packaging meets the criteria and documentation is available, it can be placed in the Green tier and receive a financial bonus, funded by the collected malus contributions from red-tier packaging.

Environmental grading of packaging image

Examples of criteria for eco-modulated fees (design for recycling):

  • Reduced packaging volume per product (reduced material use, max. 40% empty space)
  • Materials that are clean or easily separable into single fractions (design for disassembly)
  • Use of materials that can be recycled within existing systems
  • Use of recycled content, e.g., post-consumer recycled plastics, where applicable
  • Avoidance of problematic substances, such as certain mineral-based printing inks

For businesses, eco-modulated fees mean that a circular packaging design is not only an environmental initiative but also a direct economic factor in the EPR costs (Extended Producer Responsibility). Switching to more recyclable and well-documented packaging solutions can reduce eco-modulated fees over time and thereby lower your company’s total EPR costs for packaging.

Documentation and internal control for eco-modulation

To place packaging in the Green or Yellow tier, you must provide documentation showing that the design criteria are met. If you cannot document this, the packaging must be reported in the Red tier.

Under the current rules, your company must:

  • Be able to present a declaration of conformity from the supplier confirming that the material meets the design criteria
  • Be able to provide technical documentation (data sheets, tests, etc.) within a reasonable timeframe during spot checks or authority inspections
  • Establish an internal control procedure describing how packaging quantities are calculated and how materials and environmental tiers are allocated

ERP Denmark provides templates for the declaration of conformity and a draft internal control procedure in the reporting portal, helping your business document its eco-modulation and prepare for possible inspections.

With European Recycling Platform you are in safe hands:

  • Existing collective scheme in DK within WEEE and Batteries since 2005
  • 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 possible (WEEE, batteries, packaging, SUP, fishing gear, textiles)
  • Local expertise in Nyborg, Denmark and 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)

Easy and simple packaging reporting

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.

EU’s Packaging and Packaging Waste Regulation (PPWR)

PPWR (Packaging and Packaging Waste Regulation) is the EU’s new rules for packaging and packaging waste.

Unlike previous directives, PPWR applies directly in all EU countries and covers the entire product life cycle of packaging, from design and choice of materials to use, reuse and waste management.

The regulation entered into force on 12 February 2025 and will start to apply from 12 August 2026, with different deadlines depending on the individual requirements.

PPWR (Packaging and Packaging Waste Regulation) is the EU’s new rules for packaging and packaging waste.

Unlike previous directives, PPWR applies directly in all EU countries and covers the entire product life cycle of packaging, from design and choice of materials to use, reuse and waste management.

The regulation entered into force on 12 February 2025 and will start to apply from 12 August 2026, with different deadlines depending on the individual requirements.

Eco-design requirements

PPWR sets common EU requirements for how packaging should be designed in the future. This means, among other things, that:

  • Packaging must be manufactured in such a way that the content of substances of concern is limited as much as possible
  • Packaging must be designed for effective recycling according to established EU criteria
  • Packaging must be minimized in weight and volume and not contain unnecessary elements
  • Companies must meet specific recycling targets for selected types of packaging
  • Plastic packaging must contain a minimum proportion of recycled plastic (post-consumer recycled material)
  • All packaging must be labelled with a common EU sorting label with information on material composition

 

The aim is to ensure more resource-efficient packaging and make sorting and recycling easier across the EU.

The PPWR also provides for common EU procedures for documenting producers’ commitments. Companies must be able to document that the packaging meets the requirements of the regulation through technical documentation and a declaration of conformity for each packaging placed on the market.

Parts of the regulation are implemented through delegated acts that will clarify the requirements. This is expected to lead to adjustments to the EPR over the coming years.
For companies, PPWR means new requirements for how packaging is designed, documented and brought to market. The regulation is closely linked to producer responsibility for packaging and will have an impact on both reporting, fees and the choice of packaging solutions in the future.

The full version of the regulation can be read here.

FAQ – often asked questions about producer responsibility for packaging

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.

1. What is producer responsibility – and why?

Extended producer responsibility (EPR) for packaging means that companies placing packaging on the Danish market are responsible for its end-of-life phase. This includes financing and organising the collection and treatment of packaging waste, as well as fulfilling obligations related to registration, reporting of quantities, and self-monitoring.

Producer responsibility has been introduced to ensure a more efficient management of packaging waste and to reduce the environmental impact of packaging. The aim is to increase reuse and recycling, reduce waste and promote more resource-efficient packaging design. At the same time, the financial costs are shifted from municipalities and citizens to the companies that put the packaging on the market.

The “polluter pays” principle means that the company generating the waste is responsible for the costs of its end-of-life management. In practice, this means that producers and importers finance the collection and treatment of packaging waste through producer responsibility schemes, rather than these costs being covered by taxes or municipal waste fees.

2. Which companies are covered?

A company is considered a producer when it is the first to make packaging or packaged products available on the Danish market. It includes both companies that manufacture packaging and companies that use packaging in connection with the sale of products, for example:

  • A Danish company that manufactures and sells packaging or packaged products in Denmark
  • A Danish importer that imports packaging or packaged products into Denmark for sale to end users
  • A Danish distributor or wholesaler that makes packaged products available for the first time in Denmark
  • Foreign companies that sell directly to Danish consumers or companies via distance selling

It depends on the packaging in question. You have producer responsibility in Denmark when your company is the first to make packaging or packaged products available on the Danish market. This will typically be the case for sales packaging if you import goods from Germany and sell them in Denmark.
For sales to other EU countries, producer responsibility will generally arise in the country where the packaging is first made available. In this case, registration and, where appropriate, the appointment of an authorised representative may be required in the country concerned, depending on the national rules.

A company is not considered a producer if it is not the first to make packaging or packaged products available on the Danish market. For example, if the company buys packaged products from a Danish supplier who already has producer responsibility.

A micro-enterprise is a company that employs less than 10 people and that has an annual turnover or a total annual balance sheet of not more than DKK 15m.
A company has producer responsibility if they import packaging from an EU country or from a third country and make it available in Denmark. A micro-enterprise also has producer responsibility if they manufacture packaging and make it available in Denmark.
Micro-enterprises do not have producer responsibility for packaging that has already been made available by a Danish supplier, even if the packaging is manufactured with the micro-enterprise’s own name or design.
Example: A micro-enterprise buys cardboard boxes with its own logo from a Danish manufacturer. Producer responsibility lies with the Danish producer, not with the micro-enterprise.

If you make less than 8 tonnes of packaging available annually on the Danish market, you can use a simplified reporting with less information and thus lower administrative burdens. However, you still have producer responsibility, the limit does not exempt you but only makes reporting simpler.
From 2027, the rules will change. You will be required to report within specific packaging categories, even for small quantities. However, if you place less than 10 tonnes on the market annually, simplified reporting within these categories will still be allowed.
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Yes. When you sell packaged products to other countries, you may be covered by producer responsibility in those countries and must comply with local regulations. The requirements vary from country to country, but as a starting point, companies often must register and report the quantities of packaging sold directly to consumers or other end-users.
ERP Denmark can help with an overview and management of producer responsibility abroad. Contact us for more information.

3. International companies and distance selling

Foreign companies assume producer responsibility in Denmark when they make packaging directly available on the Danish market, typically through distance selling. Distance selling refers to sales made directly to end users, both businesses and private individuals, where the packaging is unpacked and becomes waste at the recipient’s premises. In such cases, the foreign company must register and report the volumes of packaging that become waste in Denmark.

Example: A German webshop sells goods directly to Danish customers in packaging. The packaging is unpacked at the customers’ premises and becomes waste in Denmark. The webshop therefore has producer responsibility in Denmark.

If, on the other hand, a foreign manufacturer sells goods to a Danish distributor or retailer, who removes the packaging (e.g. transport packaging) and does not send it on to the market, the distributor is considered to be the end user. In this case, the foreign producer has producer responsibility for the packaging that becomes waste at the distributor.

If a producer is established in another EU or EEA country and makes packaging available on the Danish market, e.g. via distance selling or direct deliveries, the company must appoint an authorised representative in Denmark.
The representative acts as the company’s legal point of contact and is responsible for registration, reporting and compliance with producer responsibility, including registration in the Danish Producer Responsibility Producer Register (DPA).

Example: A German webshop that sells directly to Danish consumers assumes the producer responsibility in Denmark and must therefore appoint an authorised representative to handle the obligations.

ERP Denmark can offer this service as part of our solutions.

4. What should we as a company do?

As a company covered by producer responsibility, you are obliged to:

  • Register with DPA
  • Choose a collective scheme
  • Report information about specific packaging and quantities that are made available on the Danish market. This includes all packaging, which is generally divided into material fractions, main components, subcomponents, weight, etcA collective scheme brings together companies’ producer responsibility and is responsible for organising the collection, treatment and recycling of packaging waste on behalf of its members.

ERP Denmark helps with registration and reporting, ensures financing of waste management and keeps companies updated on rules and requirements so that producer responsibility is complied with correctly and efficiently.
Companies that make packaging or packaged products covered by producer responsibility available for the first time must register no later than 14 days before they begin marketing them on the Danish market. Registration takes place in the national producer responsibility register at Danish Producer Responsibility. Here you can find relevant information and complete your registration: Packaging – Danish Producer Responsibility

Yes, it is mandatory to be affiliated with a collective scheme when you make packaging, that is not reusable packaging, available for the first time. The scheme handles producer responsibility on your behalf, including registration, reporting, administration, and compliance with applicable regulations.
Collective schemes vary in their profiles, so you should consider factors such as international coverage, whether they manage multiple producer responsibility areas (e.g. WEEE, batteries, packaging), and their level of experience.
In contrast to non-reusable packaging, it is voluntary for companies making reusable packaging and single-use plastic products available for the first time to be registered with a collective scheme.
If a collective scheme terminates, the producer must register with a new collective scheme within 14 days.

Producers must carry out self-monitoring, which documents how the packaging quantities have been calculated and reported to Danish Producer Responsibility, as well as why any quantities are not covered. Self-monitoring is a legal requirement and must be described in a written procedure that is continuously followed and updated. The self-monitoring can be adapted to the company’s existing systems and must be able to be presented at official supervision.

ERP Denmark makes a template for self-monitoring procedure available to members via the reporting portal.

A self-monitoring procedure must describe how the company ensures the correct calculation and reporting of packaging quantities. This includes procedures for checking regulatory changes, documenting assumptions and calculation methods used, handling changes in packaging, carrying out random data checks, and maintaining relevant documentation related to eco-modulation grading.

5. Packaging

Packaging covers all types of materials and objects used to wrap, protect, transport and present products, e.g. cardboard boxes, plastic film, glass bottles, metal cans and cartons, from the manufacturer to the end user or consumer.
Products that are made for a different function, e.g. storage boxes or plastic containers for households, are generally not packaging. However, if they are used commercially to package and ship goods, they are considered packaging, and then producer responsibility arises for the company that uses them in that way.

The material fractions covered are cardboard, paper, soft plastic, hard plastic, hard PET, foam plastic, glass, aluminium, metal, wood, food and beverage cartons, textile, porcelain, cork, ceramics and others.
Textiles, porcelain, cork, ceramics, and other items must be reported, but are not subject to fee.

The packaging is divided into 4 categories, which can help to place where the producer responsibility should lie:

  • Primary/sales packaging that is always included with the product
  • Secondary/multi-pack packaging designed to group a specific number of sales units
  • Tertiary/transport packaging, which is used to facilitate the handling and transport of large quantities of products and to prevent damage during handling and transport.
  • Service packaging intended to be filled at the point of sale

  • • Generic packaging is packaging without company identification (i.e. trademark/branding)
  • Company-specific packaging is packaging that includes the company’s trademark or corporate identity, including via the packaging itself, labels, tapes or other markings that make the packaging company-specific.

For generic packaging purchased in Denmark, the producer responsibility lies with the packaging manufacturer or wholesaler.

For generic packaging purchased abroad, the Danish company is the importer and the first person to make the packaging available on the Danish market. The producer responsibility therefore lies with the Danish company.

For company-specific packaging, the producer responsibility lies with the company that first makes the packaging available on the Danish market with its own name or design, regardless of whether the packaging was purchased in Denmark or abroad.

Please note that if you purchase generic packaging in Denmark and subsequently apply, for example, logo tape, the producer responsibility is transferred to you, as the packaging becomes company specific. You must inform your Danish supplier of the generic packaging.

If generic packaging purchased in Denmark is used for goods that are exported, the packaging is generally not covered by Danish producer responsibility, as it is not made available on the Danish market. Exports must be documented.

It depends on whether the label adds a branding function to the packaging or only has a practical/informational function.

If the label contains a name, logo, images or other branding that gives the packaging a company-specific identity, the packaging is considered company-specific. In that case, the producer responsibility lies with the company adding this branding.

If, on the other hand, the label only contains practical or statutory information, such as barcodes, addresses, warning symbols, ingredient lists or nutrition declarations, the packaging is still considered generic. In this case, the label does not change the location of the producer responsibility.

Packaging is single-use packaging when it is intended to be used once and then become waste, even if it is used again in practice or as part of a new product.

EXAMPLE: Company A receives goods in cardboard boxes, unpacks the boxes and shreds them. Company A uses the shredded cardboard as filling in its own shipments. When cardboard is used as filling, company A itself makes it available on the market and thus obtains producer responsibility for this.

To be classified as reusable packaging, the packaging must be designed to form part of a system in which it is collected and reused for the same purpose over multiple use cycles, without being converted into new material.

When a company makes reusable packaging available on the market for the first time, it must be registered under the category of reusable packaging. To register packaging as reusable, the company must establish a take-back system for end-of-life reusable packaging. This system must be financed by the company, and customers must be informed about it.

Yes, pallets can be reported as reusable packaging if the company has an established and communicated take-back system for end-of-life pallets. A take-back system means that the producer at his own expense either collects pallets from the end user, has the end user return them to the producer or receives them at an agreed collection point.

Without a take-back system, pallets are considered disposable packaging and must be reported and settled as such, including payment per kilo and relevant administration fees.

Yes, producer responsibility includes both household packaging as well as commercial packaging, and both types must be reported.

Household packaging is packaging that ends up in consumers’ waste containers and is collected close to the household. Certain fractions of packaging waste collected at recycling centres are also categorised as household packaging. Commercial packaging is packaging that does not reach consumers and typically originates from deliveries to companies.

The company must report to the Danish PDA register the amount of packaging it puts on the market in Denmark. The level of detail of the reporting depends on whether you put more or less than 8 tonnes of packaging on the market per year:

Over 8 tons/year:
Detailed reporting (all in the table below).

Under 8 tons/year:
You may choose to report only total quantities, i.e. without reporting at the material level. Please note: this option will no longer be available from 1 January 2027, when reporting at the material category level becomes mandatory.

CHART: Cardboard, Paper, Metal, Aluminium, Glass, Soft plastic, Hard plastic, Hard PET, Foam plastic, Food and beverage cartons, Wood, Textile*, Porcelain*, Cork*, Ceramic*, Other*, TOTAL.

* No waste management fee per kilo will be charged for these categories.

For each material fraction, the company must report whether it has been made available for business or household.

Packaging that is to be sorted as hazardous waste and residual waste must be reported separately.

When you put more than 8 tonnes of packaging on the Danish market per year, you must eco-modulate each material/fraction depending on the packaging’s level of recyclability.

6. Environmental grading

Environmental grading is a legal requirement when more than 8 tonnes of packaging are made available in Denmark per year. This changes to 10 tons as of 1.1.27.

Eco-modulated contributions will motivate companies to design packaging that can be better recycled and be part of a circular economy. At the same time, they create an economic incentive to choose high-quality solutions in recycling.

Environmental grading applies to the following packaging: Cardboard, Paper, Metal, Aluminium, Glass, Soft plastic, Hard plastic, Hard PET, Foam plastic, Food and beverage cartons.

Depending on the attributes of the packaging, the packaging is categorized into one of the categories Red/Yellow/Green. Yellow level is only for the subcategories of plastic and food and beverage cartons.

Examples of criteria for environmental graduation include:

  • Whether the materials of the packaging consist of mono-materials or can be easily separated into different types of material
  • Use of clean and non-harmful materials/additives in packaging
  • Use of PCR plastic in plastic packaging

Read more about the model for environmental grading and the criteria for each type of packaging on the Danish Environmental Protection Agency’s website: Guidance on the determination and calculation of modulated fee following the Packaging Executive Order

 

If your packaging component does not meet the criteria for Yellow or Green, you must place it in the Red level and pay a malus of 35% per kilogram. The same applies if you cannot document that the criteria are met. The malus of 35% is calculated on the basis of the operational costs, i.e. without administrative costs.

If, on the other hand, your packaging meets all criteria and can be documented correctly, it will be placed in Green level and you will receive a bonus. The bonus depends on the total malus that companies in the Red level have paid in, and is distributed between the packaging that is in the Green level (and possibly also the Yellow level if there is money left over after distribution to the green level).

Placement at the level for environmental grading in red/yellow/green requires documentation that all design criteria for the individual material have been met. If you cannot document your level, then you must place your material in red level.

Under the current rules, the following documentation requirements apply; you must be able to provide a declaration of conformity confirming that the materials meet the design criteria set out in the legislation.

ERP Denmark has developed a template for a declaration of conformity, which can be used until the authorities issue their official guidelines. The template can be downloaded from our reporting portal.

In the case of random checks (which are legally required by your collective scheme), or by inspection by the Danish Environmental Protection Agency, you must be able to collect and document proof that the packaging meets the design criteria within a ‘reasonable time’. If you cannot document that you comply with the requirements for e.g. green level, you may risk being fined and have to pay retroactively if you have calculated the packaging at green level.

7. Prices and billing

The expenses your business will face are:

  • One-time fee to DPA for registration in the register.
  • General administration fee to the DPA authorities (fee for 2025 not yet announced from DPA, but was DKK 0.07467/kg for 2024), as well as administration fee to the Danish Environmental Protection Agency of DKK 0.025/kg.
  • Waste management fee per kilo, which started from October 1, 2025, which is either:
    • Basic fee per kg per type of packaging, or
    • Average fee per kg when choosing simple reporting under 8 t.
  • Eco-modulated contribution, depending on the ‘recyclability’ of the packaging. Red level is a malus (additional cost per kg) and Green/Yellow level is a bonus (reimbursement per kg). The green/yellow bonus depends on the distribution of eco-modulated quantities in each individual collective scheme and can only be calculated retrospectively.
  • Annual membership fee to the Collective Scheme (for legal, administrative and practical handling and service).

There may be price differences between collective schemes because their costs depend on which municipalities and waste fractions the authorities have assigned them to handle. Therefore, the fees that the collective schemes must pay for collection and handling in the individual municipalities may vary. These differences affect the prices that companies face.

It depends on how much packaging you put on the market.

  • If you make less than 200kg available, you can sign up for ERP Go. ERP Go is invoiced once a year.
  • If you are making between 200kg and 8t packaging available, you can sign up for ERP Easy. ERP Easy is invoiced every quarter if you have more than 500 kg/year.
  • If you make more than 8t of packaging available, you must register with ERP Circular. With this scheme, you report and invoice every quarter at the material category level. If you have more than 8 tons/year, you will automatically be asked for environmental grading in the reporting of the quantities.

Yes. The financial costs associated with producer responsibility can be included in the company’s prices to customers and partners. It is the companies’ own commercial decision. However, producer responsibility as a legal obligation cannot be transferred to other actors. It is always the company that makes the packaging available on the market first that is responsible for compliance, including registration, reporting and financing. How the cost is handled commercially, e.g. as part of the product price or as a separate environmental cost, is up to the individual company.

8. Collective schemes and ERP

A collective scheme is a producer responsibility organisation that, on behalf of affiliated companies, carries out the joint obligations under producer responsibility for packaging. This includes, among other things, the organisation and financing of waste management, reporting of packaging quantities, dialogue with authorities and ongoing compliance with applicable regulations.

ERP Denmark is a privately owned company with many years of experience in extended producer responsibility across multiple waste streams, operating throughout Europe and in several countries outside Europe.

The scheme differs by, among other things:

  • Local and international and can thereby help Danish companies with their producer responsibility abroad. Either by direct contact with our local branches or via a comprehensive consulting solution, where all countries are covered (via the sister company in the group, H2Compliance)
  • 20 years of experience in running a public transport scheme in Denmark (electronics and batteries)
  • covers all producer responsibilities (packaging, electronics, batteries, single-use plastics, fishing gear, and textiles) when introduced
  • Strong compliance support and practical guidance for businesses
  • European knowledge base combined with Danish regulation

The purpose is to make producer responsibility as simple, correct and efficient as possible for members.

You can sign up for ERP Denmark ApS’ collective scheme for packaging (and single-use plastics and other areas) at any time, see link at the top of the page. To sign up for producer responsibility for electronic and electrical waste and/or batteries, sign up here.

If you have any questions, you can call us at any time for further information.

You’ll find our contact persons at the bottom of the contact page.

9. Definitions and concepts

Producer: Any manufacturer, importer or distributor who first makes packaging or a packaged product available on the Danish market, either:

  1. established in Denmark or
  2. established abroad via distance selling directly to end users in Denmark.

Micro-enterprise: Any natural or legal person with fewer than 10 employees and either an annual turnover or an annual balance sheet that does not exceed DKK 15 million.

Making available on the market: means any supply of packaging or packaging products for distribution, consumption or use on the Danish market in the course of a commercial activity, whether in return for payment or free of charge.

Distance selling: Direct sales of packaging between the manufacturer and the end user without a physical presence at the same time, where the contract is concluded exclusively via electronic or digital means of communication, typically online.

Includes both B2C and B2B, including sales to businesses as end-users.

Reusable packaging is packaging that is designed to be used multiple times for the same purpose, e.g. through refilling or return schemes. The packaging remains in use without becoming waste. Recycling is when packaging that after use becomes waste, but is collected, processed and converted into new materials or products.

The difference is that recycling is about using the same packaging repeatedly, and recycling is about making new material out of used packaging.

Packaging: All items regardless of material used for packing, protecting, handling, delivering or presenting goods. Also includes single-use items as well as certain single-use plastic products (e.g. drinking cups and containers).

Single-use packaging: Packaging that is not designed for recycling.

Reusable packaging: Packaging designed to be used multiple times for the same purpose through refilling or recycling.

Sales packaging (primary packaging): The packaging that constitutes the actual sales unit to the consumer.

Multipack/secondary packaging: Packaging that brings together multiple sales units (e.g. cardboard boxes) and can be removed without changing the product’s characteristics.

Service packaging: Packaging that is filled at the point of sale (e.g. take-away packaging). Also includes certain empty single-use plastic cups and containers.

Transport packaging (tertiary packaging): Packaging that facilitates the handling and transport of multiple sales units or multi-packs (e.g. pallets, stretch film, large boxes). Excludes shipping containers.

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