Denmark: Packaging EPR is underway

The Danish Ministry of Environment ran a consultation on its Draft Packaging Order, which closed on 1 November 2024.

The Draft outlines the details for the country’s first packaging extended producer responsibility (EPR) scheme, including producer registration regulations, compliance options, as well as requirements for producer responsibility organisations (PROs).

The Draft ensures equal access and treatment for all participating producers. It aims to establish a 3-tiered fee modulation system – applicable to all but certain medical and infant food packaging – which is based on whether the packaging meets:

high environmental standards (“green level” e.g. is recyclable, made of sustainable materials, etc.) most eco-design criteria (“yellow level”), or fails essential eco-design criteria (“red level”) in which case it incurs a 35% surcharge Moreover, the legislation establishes compliance options for single-use and reusable packaging, irrespective of whether the packaging is household or non-household packaging.

It also establishes key roles in the management of household waste packaging, setting out defined responsibilities for municipalities in terms of collecting packaging waste, designated locations for collection, as well as the fees payable for packaging waste collection by applying “distribution keys”.

Denmark is required by the Circular Economy Package amendment to the EU Packaging Directive to implement packaging EPR by the end of 2024. However, it has proposed to delay the implementation date to 1 October 2025, so stakeholders can adjust to the financial and operational changes.

The draft legislation provides the implementing details for Denmark’s first packaging EPR regime to become operational from 1 October 2025, with the first allocation period or compliance year set to run from 1 October 2025 to 31 December 2026.

Landbell Group’s Knowledge Database (KDB) already documents these changes. Find out more about the KDB here.

If your company needs support for packaging EPR in Denmark, then please contact ERP Denmark here.

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