{
“@context”: “https://schema.org”,
“@type”: “FAQPage”,
“inLanguage”: “en-DK”,
“@id”: “https://erp-recycling.org/en-dk/what-we-cover/streams/extended-producer-responsibility-for-packaging-epr/#faq”,
“url”: “https://erp-recycling.org/en-dk/what-we-cover/streams/extended-producer-responsponsibility-for-packaging-epr/”,
“mainEntity”: [
{
“@type”: “Question”,
“name”: “Which companies are covered?”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “Definition of ‘Producer’:nThe producer can be both the Danish company that manufactures/makes the packaging available, as well as the company that uses/makes the packaging available in connection with product sales. The responsibility lies with the company that makes packaging available on the Danish market first time if it is:n- Danish Producer (manufacturer or filler) who brings packaging to the Danish marketn- Danish importer or distributor of packaged goods (first level distribution chain)n- Danish ‘component assembler’ of primary packaging that fills new, assembled primary packaging unitsn- Foreign distance sellers that sells directly to Danish end-users (industrial end-users as well as consumers). There is a requirement for an authorized representative for producers from other EU/EEA countries.nnAuthorities have set a threshold of 8 tons/year of packaging per year. Below this threshold, Producers can choose to report less detailed. But Producers are still obliged to register and report by the first kilo.”
}
},
{
“@type”: “Question”,
“name”: “Which types of packaging are covered?”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “Sales packaging and transport packaging are covered:n- Primary (sales packaging, following the unit)n- Secondary (multi pack)n- Tertiary (transport packaging as pallets, strips etc)nnMaterial fractions that are covered are:n- Cardboardn- Papern- Plastic (is sub-divided into 4 categories in 2025: Rigid plastic, Flexible plastic, Rigid PET, Foam plastic)n- Glassn- Aluminumn- Metaln- Woodn- Food and beverage cartonsnnIn 2025 the following categories was added:n- Textilen- Porcelainn- Corkn- Ceramicn- OthernnThese 5 categories are only obliged to be reported and will not be met with any price per kilo until further notice.”
}
},
{
“@type”: “Question”,
“name”: “Does the responsibility cover both household packaging and commercial packaging?”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “Yes, producer responsibility covers household packaging as well as commercial packaging. Both types must be reported.nnHousehold packaging:n- The packaging that will probably end up in consumers waste bins in the endn- Collected at households (expensive)nnCommercial packaging (b-to-b):n- Packaging not reaching consumers and their waste binsn- Typically packaging from incoming goods”
}
},
{
“@type”: “Question”,
“name”: “Which legal and administrative tasks will be assigned to your company?”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “Companies are obliged to:n- Register at DPA (producentansvar.dk).n- Report information about specific packagings and expected volumes (weight) to be made available in Denmarkn – It includes packaging materials divided into fractions, main components, part components, weight. Have an overview of what must be reported in the following FAQ.n- Choose collective scheme (obligatory by law)nnAs a collective scheme, ERP helps with these tasks, keep you updated on legislation, do’s and don’ts, deadlines, practices and in addition financing of collection and organising/financing of recycling.nnYou can still register your company. It is a legal requirement to be compliant and you avoid the risk of fines.”
}
},
{
“@type”: “Question”,
“name”: “Who has the reporting responsibility for generic packaging?”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “Generic packaging is packaging that is off-the-shelf at Danish packaging manufacturers and wholesalers. In other words, packaging without a name or logo printed on it and can therefore be bought by anyone and everyone.nnIf a DANISH Producer buys and uses generic packaging in its shipments to its customers, bought from a Danish packaging manufacturer/wholesaler, then it is the packaging manufacturer/wholesaler who bears the manufacturer’s responsibility.nnIf the packaging is purchased abroad, the responsibility lies with the Danish Producer, who in this case becomes the importer and makes the packaging available in Denmark for the first time.”
}
},
{
“@type”: “Question”,
“name”: “When do foreign producers have producer responsibility in Denmark?”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “In short: Producers established abroad without a Danish legal entity (CVR number) only have producer responsibility when performing distance selling.nnDistance selling is sales directly to end users, both professional end users (e.g. industrial companies, hotels) and private consumers (typically via online sales).nnDistance selling is also when a foreign Producer sell to Danish distributors/dealers, if the distributor/dealer as first level in DK unpack the packaging and it becomes waste there. In this case, the distributor becomes the end user as this part of the packaging is not forwarded into the Danish market. This typically applies to transport packaging.nnForeign distance sellers from EU/EEA countries must also have an authorized representative in Denmark – a service that ERP Denmark offers.”
}
},
{
“@type”: “Question”,
“name”: “Which data are to be reported?”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “A distinction is made between total volumes in kg. over/below 8 tons/year:n- Over 8 tons in total: Detailed reporting by type obligatoryn- Below 8 tons: Companies can choose to report less detailed – in totals onlynnPlastic fractions sub-divided into 4 categories in 2025:n- Rigid plasticn- Flexible plasticn- Rigid PETn- Foam plasticnnIn addition to the subdivision of plastics the following packaging material categories are added:n- Textilen- Porcelainn- Corkn- Ceramicn- OthernnThese 5 categories are for reporting only. They will not be met with a price per kilo.”
}
},
{
“@type”: “Question”,
“name”: “What will the costs be for companies?”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “The compliance fee per kilo will be published primo August 2025.nnThere is a threefold division of costs:n- General administrative fee for the DPA authorities (one-off registration fee + yearly admin fee), and a yearly admin fee for the Danish EPA on 0,025 dkk/kgn- Eco-modulated fee per material per kilo. Fee will be modulated up/down depending on the ‘recycling potential’ of the packaging. If below 8 tonnes per year and wish for simple reporting, there will be no eco-modulation.n- Annual membership fee for the Collective Scheme (for legal, administrative and practical work)”
}
},
{
“@type”: “Question”,
“name”: “Own control requirement”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “Producers must establish a own-control procedure for how to arrive at their packaging quantities. It is important to state any assumptions that have been made to arrive at the quantities.nnThis own-control must be followed and updated when changes are made to one’s process and assumptions.nnProducers must be able to demonstrate that the own-control procedure is followed upon request.nnERP Denmark has prepared a draft of a own-control procedure that our members can download from our reporting portal.”
}
},
{
“@type”: “Question”,
“name”: “What is eco-modulated fee?”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “Companies are facing eco-modulation of fees to encourage circular packaging design. The contribution is in DKK per kilo per type of packaging. Depending on the recyclability of the packaging, the packaging is categorized into Green/Yellow/Red level.nnIf the packaging element does not meet the criteria, you land in the Red category and get an extra cost per kilo of 35% (malus). Also, if you cannot document that the criteria for green/yellow level is met, you will also be in Red level.nnIf the packaging element meets the criteria, and it is documented according to the law, you are in the Green category and receive a bonus. The bonus depends on the total malus paid in from the Red level packagings. This malus is distributed among those with Green level (and eventually Yellow) as a bonus.nnExamples on criteria:n- Less packaging volumen- The packaging materials are separate or easy to disassemble in various fractionsn- Use of pure and environmentally friendly materialsn- Content level of PCR plasticn- No use of hazardous chemistry (e.g. mineral based printing)”
}
},
{
“@type”: “Question”,
“name”: “Documentation requirements for eco-modulation level”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “Classification in the level for eco-modulation in red/yellow/green requires documentation that all design criteria for the individual material have been met.nnIf you cannot document your level, then you must classify your material in the red level.nnAs the rules now stand, there are the following documentation requirements:n1) You must be able to present a declaration of conformity from your suppliers stating that they meet the design criteria for the material as specified in the legislation. ERP Denmark has created our version of a declaration of conformity, which can be used until the authorities come up with their guidelines for this. Our version can be downloaded from our packaging reporting portal.n2) By sample controlling (which is legally required of your collective scheme), or by inspection by the Danish Environmental Agency, you must be able to collect and document evidence within a ‘reasonable time’ that the packaging meets the design criteria. This is technical documentation such as data sheets, tests, etc.n3) If you cannot prove that you comply with the requirements for e.g. the green level, you may be fined and must pay retroactively if you have placed the packaging in the green level.”
}
},
{
“@type”: “Question”,
“name”: “Does your business have to join a collective scheme?”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “It is obligatory by law to be part of a collective scheme.nnThe collective schemes handle producer responsibility on behalf of the producer/company, including compliance with deadlines, administration, reporting, invoicing, overview of legislation etc., as well as advisory.nnThere is a difference in the profiles of the collective schemes. Consider which collective scheme best suits your needs (e.g. international presence, coverage of multiple producer responsibilities, experience with practice).”
}
},
{
“@type”: “Question”,
“name”: “How do I register for ERP Denmark ApS’ collective scheme?”,
“acceptedAnswer”: {
“@type”: “Answer”,
“text”: “You can sign up for ERP Denmark ApS’ collective scheme at any time.nnTo register for producer responsibility for electronic and electrical waste and/or batteries, use the registration link on the page.nnIf you have any questions, you can always call us for further information and see contact persons on the site.”
}
}
] }