ERP Denmarks compliance fees per kilo

Prices for Q1 2026 is identical with prices in Q4 2025.
All prices are excl. VAT.
Current exchange rate: 1 EURO = 7,45 DKK.

Wood (household) is added as fraction as DPA have made allocation of it with retroactive effect.

*) Green level and yellow level in eco-modulation: Base prices follow the normal packaging prices above until final declaration. Eventual bonus from green and yellow level is calculated after declaration of volumes quarterly.

Packaging to be treated as hazardous waste:
Above prices + 5 dkk/kg

Main comment on the Q1 prices – therefore quarterly prices:

Danish collective packaging schemes continue to experience huge uncertainty in the cost base, the logistical system and volumes and, in addition, ongoing changes in legislation.

With the first reports and data sets coming in in Q4 2025, we are still largely lacking reliable data on the cost base. Further uncertainties are caused by changes in legislation that lead to a different volume allocation than in the initial setup. A continuously high level of companies that are not fulfilling their compliance obligations is causing further issues.

All these developments can have significant cost impacts in both directions and for these reasons, we have decided to keep current pricing also for Q1 2026. We will of course monitor closely and hopefully have the data basis and political clarity to be able to review prices for Q2 2026.

While we aim to achieve price stability for all our customers, we believe that quarterly prices are the only fair, serious and economically sound approach given the great uncertainties in the entire system. It adds more hassle and administration, but it is an expression of seriousness, and adjustments can go both ways.

Due to changes in legislation after the allocation was set, large quantities of cardboard, plastic and wood in particular have been moved (cardboard, plastic) to other parties or have largely disappeared as single-use packaging (wood). This has a major impact on the cost base, as allocated costs no longer correspond to the actual quantities in a scheme’s member base. This absurd, distorting competitive situation caused by legislative changes from the authorities is a fact, and unfortunately the authorities’ allocation will not change again before 1 January 2027.

When the new allocation starts on January 1, 2027, we expect to see a much more even allocation that reflects volume allocation. And there will be historical data to rely – not having any historical data is a core challenge for the “young” Danish EPR system for packaging at this point.

What the prices include:

1. The municipalities’ actual costs for collecting household waste from citizens. This cost is the vast majority of costs, and we experience huge differences from municipality to municipality.
2. ERP Denmark’s costs for transporting and recycling of household packaging for each fraction, based on the prices negotiated by ERP Denmark with transporters and facilities.
3. ERP Denmark’s costs for paying compensation for waste-producing companies’ commercial packaging waste
4. ERP Denmark’s administrative costs
5. ERP Denmark’s financial costs for the on-demand security deposit on behalf of our members

Other comments on the prices:

The prices are generally significantly higher than expected. This is primarily due to two factors:

1. DPA has made an allocation for the Wood, Household fraction with retroactive effect from 1.10.2025. Prices are added.
2. The municipalities’ actual costs are significantly higher than previous analyses and reports from the Danish Environmental Protection Agency and COWI have estimated. The executive order from the ministry has now set a ceiling for the municipalities’ costs, which we have now included in our calculations.
3. The total amount of household packaging reported is less than expected. The total packaging consumption in Denmark, as used in previous calculations from the Danish Environmental Protection Agency and COWI, is higher than the actual reported amount. The costs are thus distributed among fewer companies.
4. The Danish Environmental Protection Agency re-calculate key figures for compensation for b-to-b packaging waste to waste-producing companies.

Eco-modulation of prices:

The red prices have been determined. The red prices have a malus (additional cost) of 35% on the average operational costs.
The green and yellow prices for Q4 2025 cannot be determined before we know the declared volumes at the beginning of 2026.