Get answers to your questions about producer responsibility on packaging

Be well prepared in order to live up to your producer responsibility when it comes into force in October 2025. And remember, you company must be registrated and report expected quantities already in 2024.

Read more about the following topics under the respective headlines:

Producer responsibility

In 2025, all companies that put packaging on the Danish market will be responsible for financing and organising the collection, sorting and treatment of their packaging when it becomes waste.

It will be a large and complex task for the individual company, and most manufacturers therefore choose to solve the task through a PRO (producer responsibility organisation) like VANA.

The producer responsibility on packaging is determined in the EU directive for packaging and packaging waste.

The purpose of introducing extended producer responsibility on packaging in Denmark is to promote a circular economy where:

no unnecessary packaging is used
greater use is made of reusable packaging
real recycling of packaging waste is taking place
recycled materials are used to make new packaging
it is significantly more expensive to use environmentally harmful packaging compared to environmentally friendly packaging
the solutions are cost-effective.

Read about the producer responsibility on packaging here.

The extended producer responsibility for packaging will enter into force on 1 October 2025. But already now covered companies must be registered with Dansk Producentansvar (DPA - Danish Producer Responsibility) and report expected packaging quantities for 2024.

Read more about registration and membership of VANA here.

See the status of implementation of the producer responsibility here.

In relation to the registration obligations it is a good idea to check which packaging your company puts on the market - what materials are the packaging made of and how much do they weigh?

The general rule is that producer responsibility belongs to the producer that makes packaging available on the Danish market.

Please note that the first availability applies to all types of packaging, i.e. if you buy generic packaging (e.g. transport packaging) from a Danish supplier, it will probably be the supplier/manufacturer who has the producer responsibility for it.

Read more and check whether your company is covered here.

Read more about the producer responsibility here.

Read more about packaging types here.

Executive orders
Read the executive order on registration and reporting of packaging here.

Read the executive order on certain requirements for packaging here.

Yes: It is not only packaging that will be subject to the producer responsibility – you will also have to pay for the costs of collection, clean-up and waste treatment certain single-use plastic products.

Registration and reporting
Producers who market single-use plastic products as of 31 December 2024 must be registered in Dansk Producentansvar (Danish Producer Responsibility) for each product category by 17 December 2024 at the latest.

See requirements for single-use plastic products here

Companies that put less than 8 tons of packaging available on the Danish market annually can choose to report less information about their packaging. They are therefore subject to fewer administrative burdens.

This does not mean that the company is exempted from the producer responsibility.
The company is still obliged to register and report packaging quantities, as well as paying for costs associated with the collection and treatment of packaging, corresponding to what is made available on the market.

With the implementation of the producer responsibility comes an obligation to provide information on the correct handling of packaging and packaging waste and avoid littering (obligation regarding awareness raising measures).

The political agreement stipulates that this obligation will be fulfilled by the state at the expense of the companies. Based on the draft of Environmental Protection Act, it is therefore expected that the obligation will lie with the municipalities and the Environmental Protection Agency. The executive order to implement this is scheduled for mid 2024.

As a company covered by the producer responsibility on packaging, you must cover the costs for collection, transport and waste treatment of your packaging.

Read more about prices for being a member of VANA here and the financial consequences in connection with the producer responsibility here.

The eco-modulated fees are an economic structure to ensure increased incentive to produce/have packaging produced that is reusable or recyclable.

The authorities determine the eco-modulation as well as the design requirements that form the basis of the modulating. The Environmental Protection Agency has published a draft of the proposed design requirements, which can be found here: Model for ecomodulated fees | Vana.

The statutory order with the final text is expected in September 2024 - find more about relevant legislation here.

It is expected that emphasis will be placed on minimisation of material, recyclability, the amount of recycled material in packaging and the presence of hazardous substances.

The EU-directive on packaging and packaging waste sets a broad overall framework for the member states: It is up to the individual member states how they want to implement the legislation in practice. This means that there are national differences in the legislation of producer responsibility on packaging across Europe.

If your company puts packaging on the market in countries other than Denmark, you must therefore comply with the respective country's rules for the producer responsibility on packaging.

In the upcoming EU packaging regulation, the plan is to harmonise the rules across Europe, so that it will be easier for companies to live up to the producer responsibility across the EU.
Read more about the legislation here.

Free-riders are companies that are covered by producer responsibility without being registered in the Daaks Producentansvar's (DPA's) official register. Find more information about free-riders and the notification function at DPA here.

To address the challenges of free-riders, the Danish Environmental Protection Agency, as part of their supervision, has an anonymous whistleblower scheme where it is possible to report producer responsibility violations anonymously - find it here: Notify - Dansk Producentsvar.

Registration and reporting

In 2024, you must register your company and report your expected available packaging quantities on the Danish market in 2024.

From 1 October 2025, you must report based on the design requirements for environmental graduation, which the authorities are preparing.

If the packaging consists of several materials, which cannot easily be separated, the combined weight must be reported in the material category of which the packaging mainly consists of.

In other areas of implementation, the authorities have defined weight as the decisive factor. Until there is a guide, we therefore recommend that you evaluate "mainly" based on the material that weighs the most in the packaging.

Find more about packaging types and materials here.

The requirement in the executive order is that the registration must be carried out by the company covered by the producer responsibility.

In many cases, it will be possible to document that the producer and therefore the producer responsibility lies with i.e. a parent company, if they are, for example, owners of the trademark.

Special for group reporting

IThe Danish Environmental Protection Agency's guide states:

Page 14: 9. Different company structures

The Danish Environmental Protection Agency is aware that the executive order on registration and reporting of packaging does not address how companies should register in the event of different company structures.

In this regard, the Danish Environmental Protection Agency notes that the key issue is that the registration requirements set out in section 10 of the Executive Order on registration and reporting of packaging are adequately fulfilled.

We recommend that you always document in your self-control mechanism how you have placed the producer responsibility and contact Dansk Producentansvar (DPA - Danish Producer Responsibility) if you are in doubt.

It is important that you describe the placement of responsibility in the company's self-monitoring. Find a template for self-check of compliance here.

If the producer responsibility cannot be placed with the main group/parent company/chain office, etc.

The authorities have stated that the producer responsibility cannot be transferred - what can you do?

DPA states that if you want another company to handle the registration and reporting, you can link a person from the other company to your company in MitID Erhverv as a new user. If you wish to have yourself represented by a power of attorney from another company, it is possible to create a “business power of attorney” in MitID Erhverv. Therefore, you can choose to let the primary contact person for the company subject to registration be a person in the main group, etc.

The Environmental Protection Act, which sets the framework for the producer responsibility, does not apply to the Faroe Islands and Greenland. Therefore, it is only the packaging that you make available on the Danish market that you must report.

According to the draft amendment to the Environmental Protection Act from 2024, the Ministry of the Environment will lay down rules on procedures for reimbursement to manufacturers regarding importers when packaged products are marketed outside Denmark. That is, in cases where products are registered as marketed in Denmark, but are subsequently exported, e.g. by one's customer. Find relevant legislation here.

The draft executive order on extended producer responsibility for packaging (expected to be issued at the end of December 2024) states that producers can change the reported quantities if it is documented that they later are exported from Denmark.

In its consultation response to the Ministry of the Environment, VANA has submitted a request focusing on companies avoiding significant administrative burdens and liquidity challenges in this connection, and also called for the definition of making available on the Danish market and how repayment can be handled in practice to be clarified in guidelines. Read VANA's full consultation response here (only in Danish).

The general rule is that the producer responsibility falls to the company that first makes packaging or packaged products available on the Danish market.

The decisive factor for the allocation of the producer responsibility is whether the packaging/packaged product is designed/manufactured under your own name and trademark or whether it is generic packaging.

Packaging/packaged products manufactured/designed under your own name and trademark

The Danish Environmental Protection Agency's guidelines (link) state that liability may fall to a company other than the manufacturer if one of the following conditions is met:

If a company is responsible for the design
If a company has the packaging manufactured in its own name
If a company has packaging manufactured under its own brand name.

Generic packaging
According to the Danish EPA, generic packaging should be understood as the opposite of the above. And in these cases, it is the manufacturer (if established in Denmark) that has the producer responsibility.

Overall, it is therefore important for companies to be aware of whether they manufacture packaging for a company that fulfils one of the three conditions above, since this is crucial for the placement of responsibility.

Labels that are put directly on a product or otherwise placed on the product are packaging.

Self-adhesive labels placed on another packaging item are part of the packaging. For more information about packaging, read here.

The DPA has stated the following about producer responsibility for labels:

When labels, tags, stickers, marks, decals or the like are placed on a package, they become part of the package on which they are placed. In this way, for example, the label is covered by the producer responsibility for packaging.

As an example, self-adhesive shipping labels on transport packaging are covered by producer responsibility for packaging.

It is the first company that makes the label available on the Danish market, who is covered by the producer responsibility.

If, for example, a Danish company puts an adhesive shipping label on transport packaging that it sends to another Danish company, the first Danish company will have producer responsibility for the adhesive shipping label.

The company that has producer responsibility for the transport packaging is not necessarily the same as the company that has the producer responsibility for the label.

If, for example, a Danish company sends transport packaging to another Danish company, which applies the self-adhesive shipping label and forwards the transport packaging to a third Danish company, the first Danish company will have producer responsibility for the transport packaging, and the second Danish company will have producer responsibility for the self-adhesive shipping label.

Foreign companies can only have the producer responsibility if they sell packaging/refilled packaging for the first time on the Danish market directly to an end user (consumer/company).

If a foreign webshop sells packaging/refilled packaging for the first time in Denmark to a Danish end user, the webshop will have the producer responsibility.
If a Danish company removes transport packaging that it has received from a foreign company, the Danish company becomes the end user of the packaging, and the foreign company has the producer responsibility.

Especially in relation to repackaging

For example, if a foreign company sells packaged products to Danish company A via distance selling (by means of distance contracts), and Danish company A removes the packaging because the products need to be repackaged, Danish company A becomes the end user of the packaging, and the foreign company will in this case have the producer responsibility.

VANA and producer responsibility organisations (PRO's)

A PRO is a private company that offers companies subject to the producer responsibility to handle the administrative and practical tasks associated with the producer responsibility on packaging on their behalf.

However, it is still the producer responsible company which is responsible for collecting data on its own packaging and registering these with the PRO.

Packaging and design

All packaging is covered by the producer responsibility, except packaging which is covered by the deposit and return system.

Packaging: All products of any kind and material used for the packaging, protection, handling, delivery and presentation of goods.

Relevant packaging types:

sales packaging (primary packaging)
grouped packaging (multipack / secondary packaging)
transport packaging (tertiary packaging)
service packaging
reusable packaging
primary production packaging.

Se more about packaging here

To make your business as ready as possible, it is important to keep track of what packaging you have - in other words, what components and materials the packaging consists of.

Find more knowledge and inspiration on how to prepare your company and what data is important here

In 2024 all covered companies have to report expected packaging volumes for 2024 in kilograms for the fractions: paper, cardboard, metal, aluminium, glass, plastic, food and drink cartons and wood. Furthermore, it must be reported for all categories, how much packaging ends up in businesses and households, respectively.

Packaging which has been conceived, designed, and placed on the market with the aim of going through a number of trips or cycles during its lifetime by being refilled or reused for the same purpose for which it was conceived.

DPA states the following:

If your product unambiguously falls under the definition of reusable packaging, this packaging will not be covered, until the producer responsibility comes into force in 2025. In the second phase of the executive order it will, among other things be described, how reusable packaging quantities, which are added and taken back from the market, must be calculated.

In relation to reusable packaging, it is important to distinguish between "reusable packaging" defined in the executive order and “reuse of packaging”. Packaging is not reusable packaging just because it is reused as packaging. If it is a question of reusing packaging, it is decisive whether a previous link has claimed the producer responsibility for the packaging. If company A from Denmark reuses e.g. cardboard boxes as packaging, which they have received as packaging from company B from Denmark, and if company B has reported the cardboard boxes as packaging in the producer responsibility register, then the cardboard boxes do not need to be reported again.

Nor is it a question of "reusable packaging" just because a packaging consists of recycled materials.

No. Reusable packaging must only be reported when the producer responsibility comes into force on 1 October 2024.

Find definition of recycling here.

Therefore, euro pallets which are part of the global recycling system do not have to be reported in 2024.

Pallet types which are not part of a closed recycling loop MUST be reported in 2024.

Reuse of packaging will be supported in the future system by manufacturers using reusable packaging only having to pay once for the packaging’s circulation on the market. For example, if reusable packaging can be circulated 30 times before it is discarded, the fee is paid only once, instead of the 30 times which would have had to been paid for using single-use packaging.

The specific regulation of recycling solutions is not yet in place, but it is a political wish to ensure a flexible framework for manufacturers with new packaging solutions, e.g., recycling and return systems.

NOTE: Reusable packaging is not included in the reporting of packaging quantities for 2024, but must not be registered until 2025.

Clarification from the authorities awaits. We will update continuously.

The Ministry of the Environment has stated that: "In relation to textiles and other packaging materials, which are used to a very small extent today, it is being clarified how they are included in the extended producer responsibility". (VANA translation).

The national recommendations and guidelines on which the eco- modulated fees will be based have not yet been established. So far, we refer to the recommendations prepared by Danish and foreign trade associations.

Find inspiration for designing your packaging here

Eco-friendly packaging is packaging such as:

material is minimised
is made of a single material (if possible)
is easy to sort the source – possibly take apart
can effectively be fed into the recycling process
retains high value as secondary raw material
is reusable packaging.

Get more advice and inspiration about eco-design here

Single-use plastic products

The main rule is that the producer responsibility accrues to the company that first makes the single-use plastic products available (empty or filled) on the Danish market. Read more here: Registration of single-use plastic products.

Registration opened on 1 October. The deadline for registration is 17 December 2024 for companies that make single-use plastic products available.
Read more here: Registration of single-use plastic products.

If you choose VANA as a PRO to handle the producer responsibility for single-use plastic products, you can register your company and product categories directly through the Member Porta l.

You can also register directly with the authorities (Dansl Producentansvar - DPA).

No, it is not a requirement to be a member of a PRO in order to handle the producer responsibility for single-use plastic products. You can register and report directly to the authorities (Danska Producentansvar - DPA).

It is possible to choose VANA to handle the producer responsibility for single-use plastic products, so VANA handles registration and reporting to the authorities on behalf of the members.
Choosing VANA to handle the producer responsibility for single-use plastic products costs a basic annual administration fee of DKK 1,000, which also gives you access to our knowledge, templates and guides in the area as well as guidance from VANA's Member Services.

The first report must be made between 1 and 10 April 2025.
Read more here: Registration of single-use plastic products.

8 product categories must be reported:

food containers
wrapping bags and foils
beverage containers
drinking cups
lightweight plastic carrier bags
wet wipes
balloons
filters for tobacco products.

Read more here: What are single-use plastic products?

Yes, there is. But the so-called executive order on plastic products will be deleted and become part of the producer responsibility for single-use plastic products.

No, there is no triviality limit for single-use plastic products.

Yes, there is no distinction. All companies that make single-use plastic products available on the market are covered.

Yes, packaging can be covered by both the producer responsibility on packaging and the producer responsibility on single-use plastic products. It is not necessarily the same company that has both producer responsibilities.

DPA informs the following about this topic:

The reason is that for the producer responsibility on packaging, there is an exception to the general rule that it is the first company that makes a product available on the Danish market that has producer responsibility. Companies that are not micro-enterprises have the producer responsibility if they have designed/manufactured packaging/packaged products under their own name/trademark. (A micro-enterprise is a company that employs less than ten people and has an annual turnover, understood as the amount earned in a certain period, or an annual balance sheet, understood as an overview of the company's assets and liabilities that do not exceed DKK 15 million.)

If, for example, company A from Denmark sells a single-use plastic product/packaged single-use plastic product, which is also packaging, to company B from Denmark (which is not a micro-enterprise) with company B's name and logo on it, company A will have the producer responsibility for the single-use plastic part and company B will have the producer responsibility for the packaging part.

For the clean-up obligation itself, which is paid 4 times a year (3 times in 2025), fees and tariffs can be found on the Danish Environmental Protection Agency's website here: Single-use plastic - The Danish Environmental Protection Agency. The first payment will be made based on the reporting in April 2025, which covers the period from 1 January to 31 March.

In addition, a registration fee of DKK 1,000 (DKK 500 if the company is already registered with DPA) must be paid to DPA for single-use plastic products, as well as an annual (though biannually in 2025) administration fee to DPA, depending on the amount reported (fee amounts are not yet known).

How much does it cost to use VANA as a PRO for single-use plastic products?

It is not a requirement to use a PRO to handle the producer responsibility for single-use plastic products. If you choose VANA to handle it, it costs a basic annual administration fee of DKK 1,000, which also gives you access to our knowledge, templates and guides in the field as well as guidance from VANA's Member Services.

Waste management

In Denmark, we handle waste differently depending on whether it comes from households (private citizens) or businesses.

The municipalities are still responsible for the collection of waste from households, while private actors handle waste from businesses.

No. Waste producing companies only have to pay for the handling of non-packaging waste. The manufacturer must pay for the part that is packaging.

A packaging is registered in the producer responsibility by the company that first makes it available on the Danish market, with business as end user (producer). When the packaging becomes commercial waste, it is collected, e.g., by a private waste collector, who is compensated by the PRO (producer responsible organisation).

General waste packaging

The starting point is that all packaging is reported as ordinary waste. It is only in cases where packaging is designed to be sorted as residual or hazardous waste according to sorting instructions that it does not have to be reported in the category of ordinary waste.
See the Danish Environmental Protection Agency's sorting guidelines here

Therefore, most packaging will probably have to be categorised as this type of waste divided into the material categories:

cardboard
paper
ferrous metals
aluminium
glass
plastics
food and drink cartons
wood.

Packaging for residual waste

Waste not covered by other established collection or referral schemes. This means waste that is not recyclable, is not dangerous or is not covered by another producer responsibility scheme e.g. pizza boxes.

The packaging must be designed to fall under this category. It is not important what you expect the end user will do with the packaging.

Packaging for hazardous waste

Substances, materials or products that have expired, such as chlorine-containing detergents, paints and aerosols, etc., see the Danish Environmental Protection Agency's sorting guidelines here.

Hazardous waste must not contain products that may pose a danger during collection and treatment, such as fireworks.

The packaging must be designed to fall into this category. It does not matter what you expect the end user will do with the packaging.

If in doubt, you can read the Danish Environmental Protection Agency's sorting guide here.

All companies in Denmark that generate waste and therefore need to dispose of it, e.g. by entering into an agreement with a private waste collector, are waste producing companies.

Concepts in the executive order

Manufacturer: Any physical or legal person who:

(a) manufactures packaging or filled packaging

(b) has packaging or filled packaging designed or manufactured under its own name or trademark, irrespective of who produced the packaging or filled packaging and whether other trademarks are visible on the packaging or filled packaging

c) provides packaging or refilled packaging to a micro-enterprise that has the packaging designed or manufactured under its own name or trademark when it comes to transport packaging, recycled packaging, primary production packaging or grouped packaging.

An importer is any physical or legal person established in the EU who makes packaging, or filled packaging, from a third country available on the EU market.

A distributor is any physical or legal person in the supply chain, other than a manufacturer or importer, who makes packaging or filled packaging available on the Danish market.

Companies which employs fewer than 10 persons and whose annual turnover and/or annual balance sheet total does not exceed DKK 15 mio.

Dansk Producentansvar (Danish Producer Responsibility) states: 10 people are counted as heads. Part-time and full-time are counted equally.

The Danish executive order is based on the upcoming packaging regulation, which refers to the following recommendation from the EU, which the Danish EPA also refers to here.

We have made DPA aware of this difference.

Commission Recommendation 2003/361/EC, Article 5:

The number of persons employed is equal to the number of annual work units (AWU), i.e. the number of persons who worked full-time in the establishment concerned or on behalf of that establishment during the whole of the year in question.

Work performed by persons who did not work the whole year or who worked part-time, regardless of duration, or seasonal workers are included as fractions of AWUs.

The following are counted as employed:

a) employees

b) persons who work for the enterprise, have a subordinate relationship with it and are treated as employees under national law

c) active business owners

d) partners who regularly work in the business and receive economic benefits from the business.

Apprentices and students in vocational training who have an apprenticeship contract or a vocational training contract are not included in the number of persons employed. Maternity and parental leave are not included.

Definition of availability in the Executive Order:

Delivery of packaging, or pre-filled packaging, for distribution, consumption or use on the Danish market as part of a commercial activity, whether for or without remuneration.

DPA (Dansk Producentansvar) has stated that the decisive factor for availability is who has entered into or mediated the agreement on the packaging/filled packaging, and not who, e.g. has sent and paid the invoice or where the packaging/filled packaging in question is physically located (logistics).

The Danish Environmental Protection Agency has indicated that they are working on a guideline, in which we expect that availability will be further clarified.

An end-user is any physical or legal person residing or established in the EU to whom a packaging, or filled packaging, has been made available, either as a consumer or as a professional end-user, in the course of his/hers industrial or professional activities, and who does not make the packaging, or the filled packaging, available on the market in the form in which it was supplied.

By means of distance contracts (distance selling) means direct sale between the company and the end user of a packaging, where the two parties are not physically present, e.g. online sales.

Distance contracts also cover B2B sales, where the end user is a business.

The statutory order on registration of packaging: Distance contracts are any agreement on the sale or purchase of packaging that is entered into between the producer and the end user, without the simultaneous physical presence of the producer and the end user, and where up to and including the time of the conclusion of the agreement, one or more forms of remote communication techniques are used exclusively, including online sales.

Where can I find more information about the producer responsibilities on packaging and single use plastics?

The Danish Environment Agency on packaging - view here.

The Danish Environment Agency on singe-use plastics - view here.

Dansk Producentansvar (DPA) on packaging: view here.

Dansk Producentansvar (DPA) on single-use plastics: view here.

Executive orders - find relevant legislation here.

VANA is working on tools that can help you clarify your responsibility. The FAQ will thus be updated continuously.

Producer responsibility

What is the extended producer responsibility for packaging?

What is the purpose of introducing the extended producer responsibility on packaging?

When does the extended producer responsibility for packaging come into force?

How do we prepare for the producer responsibility?

How do I find out if we are covered?

Is single-use plastics part of the producer responsibility?

What does the triviality limit of 8 tons mean?

What does the obligation regarding awareness raising measures mean?

What are the financial costs?

What are eco-modulated fees?

What if you also put packaging on the market in other countries?

What is a free-rider?

What can you do if a company is a free-rider?

Registration and reporting

What do you have to report?

What does it mean to report the material that the packaging "mainly" consists of?

Can several companies be registered under one VAT number ?

Do we have to report packaging made available in Greenland or the Faroe Islands?

What do we do if packaging is registered under the producer responsibility in Denmark but subsequently is exported out of the country?

What does packaging manufactured/designed under own name and trademark vs. generic packaging mean?

Are labels packaging?

Can our foreign supplier have the producer responsibility for the packaging/refilled packaging they sell to us?

VANA and producer responsibility organisations (PRO's)

What is a producer responsibility organisation (PRO)?

What tasks do the PRO's solve?

Do you have to join a producer responsibility organisation (PRO)?

How do I join the producer responsibility organisation VANA?

Can several companies be registered under one VAT number ?

Who has founded VANA?

Packaging and design

Which types of packaging are covered?

What data should I collect on my packaging?

What is reusable packaging?

DPA states the following:

Should reusable packaging, e.g. euro pallets, be reported in 2024?

How will reusable packaging be promoted in the future producer responsibility?

Is packaging made of textile covered?

Where can I find good advice on packaging design?

What is eco-friendly packaging design?

Single-use plastic products

How do you find out if you are covered?

When do you need to register in the authority register?

How do you register your business?

Is it mandatory to be a member of a PRO?

When should you report for the first time?

Which single-use plastic products must be reported?

Is there not already producer responsibility on filters for tobacco products?

Is there a triviality limit?

Are micro-enterprises covered?

Can a packaging be covered by both the producer responsibility for single-use plastic products and the producer responsibility for packaging?

What does it cost and when do you have to pay?

Waste management

How is packaging waste handled?

Do you have to pay twice for the management of commercial packaging waste if you are both a producer and a waste-producing company?

How do we determine whether packaging is ordinary, residual or hazardous waste?

General waste packaging

Packaging for residual waste

Packaging for hazardous waste

What is a waste producing company?

What is a take-back scheme?

Concepts in the executive order

What is a manufacturer?

What is an importer?

What is a distributor?

What is a micro-enterprise?

What does availability mean?

What is an end-user?

What is distance selling?

Where can I find more information about the producer responsibilities on packaging and single use plastics?

Link to guides and legislation

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