FAQ - Producer Responsibility
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.
In 2025, all businesses that place packaging on the Danish market will be responsible for financing and organizing the collection, sorting, and treatment of their packaging when it becomes waste.
The producer responsibility on packaging is defined in the EU directive for packaging and packaging waste.
The purpose is to promote a circular economy, where:
- unnecessary packaging is not used
- reusable packaging is used to a greater extent
- there is a real recycling of packaging waste
- recycled materials are used for the production of new packaging
- it is significantly more expensive to use environmentally harmful packaging compared to environmentally friendly packaging
- the solutions are cost-effective
The extended producer responsibility for packaging comes into effect on October 1st, 2025. Affected companies have registration and reporting obligations already now.
Read more about the registration of companies and membership of VANA here
In relation to the obligation regarding awareness raising measures and reporting, it is a good idea to investigate which packaging the company makes available on the market - what materials are the packaging made of, and how much do they weigh, for example?
Read more about the requirements for registration and reporting here
Find the guide 'Get started with producer responsibility' here
The main rule is that the producer responsibility falls to the company that first makes packaging available on the Danish market.
Note 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/producer who has the producer responsibility for it.
Read more and check if your company is included here
Read more about producer responsibility here
Read more about types of packaging here
Regulations
Read the regulation on registration and reporting of packaging here.
Read the regulation on certain requirements for packaging here.
Yes: It is not only packaging that is covered by producer responsibility – there must also be payments for costs related to collection, clean up, and waste treatment for certain single-use plastic products.
Read more about the obligations regarding single-use plastic here.
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 one is exempt from producer responsibility.
The company must still register and report packaging quantities, just as there must be payment for costs associated with the collection and treatment of packaging, corresponding to what they make available on the market.
With the implementation of producer responsibility, there comes an obligation regarding awareness raising measures about the proper handling of packaging and packaging waste and to avoid littering (obligation regarding awareness raising measures).
This obligation will rest with the municipalities and the Environmental Protection Agency, but businesses must contribute financially through their producer responsibility organisation (PRO).
The eco-modulated fees are a financial structure aimed at ensuring increased incentives among companies to produce or have produced packaging that is recyclable or reusable.
Emphasis is placed on minimizing material, recyclability, the amount of recycled material in packaging, and the presence of hazardous substances.
The state sets the eco-modulated fee as well as the design criteria that form the basis for the grading. Find the design criteria for environmental grading in the statutory order on packaging (annex 14) under relevant legislation here.
The EU directive on packaging and packaging waste sets a broad overall framework for member states: It is up to each individual member state how to implement the legislation in practice. This means that there are national differences in the legislation regarding producer responsibility for packaging across Europe.
If your company puts packaging on the market in countries other than Denmark, you must therefore comply with the respective countries' regulations for producer responsibility on packaging.
Read more about international obligations here
Read more about VANAs partnerships regarding data management and international compliance here
In the upcoming EU packaging regulation, there are plans to harmonize the rules across Europe, making it easier for companies to meet producer responsibility across the EU.
Free riders are companies that are covered by producer responsibility without being registered in the producer register at DPA. Find more information about free riders and the reporting function at Danish Producer Responsibility (DPA) here.