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.
31. August 2024 was deadline for registering and reporting of expected quantities that your company will make available on the Danish market in 2024.

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.

The process for 2025 are as follows:
1. You MUST choose a collective scheme as partner (required by law)
2. You must report your actual 2024 quantities in Spring 2025. The quantities are to be reported in you collective schemes reporting portal. ERP Denmark will open our portal around April 1st and you will have full April to active your account and report your quantities. ERP Denmark ensure your data is submitted to the authorities before end of May 2025.
3. October 1, 2025 is set as the effective date where the compliance fee per kilo starts

In January 2026 the next reporting will come. This reporting is also in your collective schemes reporting portal and includes you categorisation of materials in red/green level, depending on recyclability (eco-modulation)

Free webinars:

Producer responsibility for packaging – update!
Product manager Lars Bruntse reviews the obligations for 2025, the reporting process, instructs you on how to calculate your packaging quantities, the eco-modulation model, and how ERP Denmark, as an experienced collective scheme e.g. helps you with advices, interpretations etc.

Webinars in English:
23. Apr. 2025 10-11 am CET. Sign Up

Webinarer på dansk:
22. apr. 2025 kl. 10-11. Tilmeld

How to report 2024 quantities in ERP Denmark’s portal (for members only):
We will walk through how to activate your account in our reporting portal, as well as how to enter your actual 2024-quantities in the portal during April 2025.

Webinars in English:
26. mar. 2025 2-3 pm CET
Read more & sign up
27. mar. 2025 10-11 am CET
Read more & sign up

Webinarer på dansk:
26. mar. 2025 kl. 10-11. Tilmeld
27. mar. 2025 kl. 13-14. 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 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. In addition you must choose collective scheme. After the deadline 31. august 2024 you can and must still register and become compliant and avoid the risk of being fined.

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. 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 (WEEE, batteries, packaging, SUP, fishing gear, textiles)
  • 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 if it is:

  • Danish Producer (manufacturer or filler) who brings packaging to the Danish market
  • Danish importer of packaged goods (first level distribution chain)
  • Wholesaler or re-packager
  • Foreign distance sellers that sells directly to Danish end-users (industrial end-users as well as 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 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: Hard plastic, Soft plastic, Hard PET, Expanded plastic)
  • Glass
  • Aluminum
  • Metal
  • Wood
  • Food and beverage cartons

In 2025 the following categories are 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 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 are obliged to:

  • Register at DPA (producentansvar.dk).
  • Report information about specific packagings and expected volumes (weight) to be made available in Denmark in 2024.
    • 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 no later than January 14th 2025 (by law).
  • Inform customers about how to sort the waste packaging (labelling, pictograms etc)

As a collective scheme, ERP helps with these tasks, keep you updated on legislation, do’s and don’ts, deadlines, practics and in addition financing of collectiona and organising/financing of recycling.

You can still register your company after 31.8.24. 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 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 Manufacturer buys and uses generic packaging in its shipments to its customers, then it is the packaging manufacturer/wholesaler who bears the manufacturer’s responsibility, IF THE PRODUCER HAS PURCHASED THE PACKAGING FROM A DANISH MANUFACTURER/WHOLESALER.

If the generic 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, distributors, retailers) and private consumers (typically via online sales).

This means that foreign producers who sell to Danish distributors/dealers are responsible for reporting the packaging that the distributor/dealer unpacks and removes in its warehouse and NOT sends on to the market. In this case, the distributor becomes the end user. 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 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

2024:

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:

  • Hard plastic
  • Soft plastic
  • Hard PET
  • Expanded plastic)

2025:

In addition to the sudivision of plastics the following 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.

As the legislation is not in place, no final size of the costs the company faces have been determined. There is a threefold division:

  • General administrative fee for the authorities (one-off registration fee + yearly admin fee).
  • Eco-modulated fee per material per kilo. Fee will be graduated up/down depending on the ‘recycling potential’ of the packaging. If below 8 tonnes per year and wish for simple reporting, this is a voluntary option.
  • Annual membership fee for the Collective Scheme (for legal, administrative and practical work)

Companies are facing eco-modulation of fees to encourage circular packaging design. The contribution is in DKK per ton per type of packaging. Depending on the recyclability of the packaging, the packaging is categorized into High/Medium/Low. If the packaging element does not meet the criteria, you land in the High category and get an extra cost per kilo of 35% (malus).
On the other hand, if the packaging element meets the criteria, you are in the Low category and receive a bonus.
The bonus depends on the total malus paid in from the High category. This malus is distributed among those with Low category 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
  • Use of recycled materials
  • 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

 

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.

No later than 14 January 2025, you must register for a collective scheme according to the legislation (under hearing).

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.