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 October 1st 2025 the extended producer responsibility for packaging will enter 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.

New reporting will be required in January 2026. This reporting is done in your collective scheme’s reporting portal.

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.

Free webinars:

Producer responsibility for packaging – update!
ERP Denmark are on ongoing basis conducting webinars on EPR for packaging in Denmark, covering relevant topics and general updates

Webinars in English:

ERP Denmark webinar:
Eco-modulation and general update.

26. November 10.00 am – 11.00 am CET
Sign Up

18. December 10.00 am – 11.00 am CET
Sign Up

Webinarer på dansk:

ERP Denmark webinar:
Miljøgraduering og generel update.

25. november 2025 kl. 10 – 11
Tilmeld

17. december 2025 kl. 10 – 11
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 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.

Eco-modulated compliance fee will apply and teh size of it will depend on the ‘design for recycling’ of the packaging. A re-design process is therefore also a process you should consider 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 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 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 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)

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.

Definition of ‘Producer’:
The 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:

  • Danish Producer (manufacturer or filler) who brings packaging to the Danish market
  • Danish importer or distributor of packaged goods (first level distribution chain)
  • Danish ‘component assembler’ of primary packaging that fills new, assembled primary packaging units
  • 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.

Authorities have set a with 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.

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 (is sub-divided into 4 categories in 2025: Rigid plastic, Flexible plastic, Rigid PET, Foam plastic)
  • Glass
  • Aluminum
  • Metal
  • Wood
  • Food and beverage cartons

In 2025 the following categories was added:

  • Textile
  • Porcelain
  • Cork
  • Ceramic
  • Other

These 5 categories are only obliged to be reported and will not be met with any price per kilo until further notice.

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

Household packaging

  • The packaging that will probably end up in consumers waste bins in the end
  • Collected at households (expensive)

Commercial packaging (b-to-b):

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

Companies are obliged to:

  • Register at DPA (producentansvar.dk).
  • Report information about specific packagings and expected volumes (weight) to be made available in Denmark 
    • It includes packaging materials divided into fractions, main components, part, components, weight. Have an overview of what must be reported in the following FAQ.
  • Choose collective scheme (obligatory by law)

As 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.

You can still register your company. It is a legal requirement to be compliant and you avoid the risk of fines.

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.

If 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.

If 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.

In short: Producers established abroad without a Danish legal entity (CVR number) only have producer responsibility when performing distance selling.

Distance selling is sales directly to end users, both professional end users (e.g. industrial companies, hotels) and private consumers (typically via online sales).

Distance 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.

Foreign distance sellers from EU/EEA countries must also have an authorized representative in Denmark – a service that ERP Denmark offers.

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

Over 8 tons in total:     Detailed reporting by type obligatory

Below 8 tons:               Companies can choose to report less detailed – in totals only

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 in 2025:

  • Rigid plastic
  • Flexible plastic
  • Rigid PET
  • Foam plastic

In addition to the sudivision of plastics the following packaging material categories are added:

Textile
Porcelain
Cork
Ceramic
Other

These 5 categories are for reporting only. They will not be met with a price per kilo.

The compliance fee per kilo will be published primo August 2025.

There is a threefold division of costs:

  • 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/kg
  • 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.
  • Annual membership fee for the Collective Scheme (for legal, administrative and practical work)

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.

This own-control must be followed and updated when changes are made to one’s process and assumptions.

Producers must be able to demonstrate that the own-control procedure is followed upon request.

ERP Denmark has prepared a draft of a own-control procedure that our members can download from our reporting portal.

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. If 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.

On the other hand, if 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.

Examples on criteria:

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

Read more about the model for eco-modulation and the criteria for each type of packaging on the Environmental Protection Agency’s website:
https://mst.dk/media/gkrdavjb/vejledning-til-miljoegraduerede-bidrag-for-emballage.pdf

 

Classification in the level for eco-modulation 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 classify your material in the red level.

As the rules now stand, there are the following documentation requirements:

  1. 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.
  2. 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.
  3. If you cannot prove that you comply with the requirements for eg. the green level, you may be fined and must pay retroactively if you have placed the packaging in the green level.

It is obligatory by law to be part of a collective scheme.

The collective schemes handle producer responsibility on behalf of the producer/company. Be it compliance with deadlines, administration, reporting, invoicing, overview of legislation etc., as well as advisory.

There is a difference in the profiles of the collective schemes.

  • Is it important that the collective scheme is present internationally and can help you in any country (many producers have producer responsibility in several countries)?
  • Is it essential that the collective scheme covers several producer responsibilities such as WEEE, batteries and packaging, textiles?
  • Is it essential that the collective scheme has many years of experience in running a collective scheme and knows the practice?
Consider which collective scheme best suits your needs and ask about the above.

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

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.