FAQ - Covered companies
The main rule is that the producer responsibility lies with the company that first makes packaging available on the Danish market.
Be aware that, the first availability applies to all types of packaging, i.e., if you purchase generic packaging (e.g., transport packaging) from a Danish supplier, it will likely be the supplier/manufacturer who has the producer responsibility for this.
Read more, and check if your company is covered
Read more about producer responsibility
Read more about types of packaging
Statutory Orders
Read the statutory order on registration and reporting of packaging (Danish)
Read the statutory order on certain requirements for packaging (Danish)
Businesses that employ fewer than 10 people and have an annual revenue, understood as the amount earned in a specific period, or an annual balance, understood as a statement of the company's assets and liabilities, that does not exceed 15 million DKK.
Danish Producer Responsibility informs: 10 persons are counted as heads. Part-time and full-time are counted equally.
The Danish statutory order is based on the upcoming packaging and packaging waste regulation, which refers to the recommendation from the EU below, which the Environmental Protection Agency also refers to (Danish).
We have made DPA aware of this difference.
Commission Recommendation 2003/361/EC, Article 5:
The number of employed is equal to the number of annual work units (ÅAE), i.e., the number of persons who have worked full-time in the respective business or on behalf of this business throughout the entire year.
Work performed by persons who have not worked the entire year, or who have worked part-time, regardless of its duration, or seasonal workers counts as fractions of ÅAE.
Included in the employed are:
a) wage earners
b) persons working for the company, who are subordinate to this and are equated with wage earners in national law
c) active business owners
d) partners who regularly work in the business and benefit from financial advantages from the company's side.
Apprentices and students under vocational training, who have entered into an apprenticeship contract or a vocational training contract, are not included in the number of employed. Maternity leave and parental leave are not included.
Yes, there is a triviality limit for each of the two main types of packaging. That is to say, a triviality limit for one-way packaging of 8 tons and a triviality limit for reusable packaging of 8 tons.
Companies that make available less than 8 tons of packaging on the Danish market annually can choose to report fewer details about their packaging and are therefore subject to fewer administrative burdens.
This does not mean that they are exempt from producer responsibility.
The company must still be registered and report packaging quantities, just as they must pay for costs associated with the collection and treatment of packaging, corresponding to what they make available on the market.
Free-riders are companies that are covered by producer responsibility without being registered in the producer register with DPA. Find more information about free-riders and the reporting function with Dansk Producentansvar (DPA).
To address the challenges with free-riders, the Environmental Protection Agency, as part of their supervision, has, among other things, an anonymous whistleblower scheme where it is possible to report violations of producer responsibility anonymously - find it here: