FAQ - Registration and reporting
If you are not already registered or are a new enterprise, you must register the business and report your expected available packaging quantities for the current year in the producer register immediately. If you are a member of VANA, the registration and reporting can be done directly through the Member Portal.
Members of VANA can report and register in the Member Portal.
From October 1, 2025, you must report your actual available quantities based on the design requirements for eco-modulation.
The Environmental Agency's guidance
Read more about reporting when the producer responsibility takes effect
The Environmental Protection Agency confirms that there is methodological freedom. Therefore, groups that have the decisive influence on the purchasing and marketing of goods and thus the packaging will be able to register their responsibility centrally from the parent company, even if there are several independent CVR numbers within the group.
The above also applies to the registration of single-use plastic products. It is, however, essential that there is consistency between registered companies and reports.
The important thing is that all quantities are registered. The supervision will place particular emphasis on whether there is correct reporting in cases where a group has reported on behalf of several CVR numbers.
The method used regarding the group or individual CVR must be described and justified in the mandatory self-control. You can find a template for self-control here:
It appears from the draft amendment to the Environmental Protection Act from 2024 that the Ministry of the Environment will set rules for procedures for repayment to producers and importers when packaged products are marketed outside Denmark. This means, in cases where products are registered as marketed in Denmark but are subsequently exported, for example by a customer of theirs.
Read more about the relevant legislation
From the draft statutory order on extended producer responsibility for packaging (expected to be issued by the end of December 2024), it is stated that producers can change reported quantities if it is documented that they are later exported from Denmark.
VANA has submitted a recommendation in response to the Ministry of the Environment focusing on ensuring that companies avoid significant administrative burdens and liquidity challenges in this context, and has also urged that the definition of availability on the Danish market, as well as how repayment can be practically managed, be clarified in guidelines.
Danish Producer Responsibility (DPA) provides information about the responsibility of foreign companies:
Foreign companies can only obtain producer responsibility if they sell packaging/packaged products for the first time on the Danish market directly to an end user (consumer/business).
• If a foreign webshop sells packaging/packaged products for the first time in Denmark to a Danish end user, the webshop will have producer responsibility.
• If a Danish company removes transport packaging it has received from a foreign company, the Danish company becomes the end user of the packaging, and the foreign company has producer responsibility.
Particularly in relation to repackaging
• If a foreign company, for example, sells packaged products to Danish company A via 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 producer responsibility.
The EU directive on packaging and packaging waste sets a broad overarching framework for member states: It is up to the individual member states how to practically implement the legislation. This means that there are national differences in the legislation on 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' rules for producer responsibility on packaging.
Read more about international obligations
Read more about VANAs partnerships regarding data management and international compliance
In the upcoming EU packaging regulation, there are plans to harmonize the rules across Europe, making it easier for businesses to comply with producer responsibility across the EU.
The Environmental Protection Act, which sets the framework for producer responsibility, does not apply to the Faroe Islands and Greenland. Therefore, it is only the packaging that one makes available on the Danish market that must be reported.
Yes, there is an overall overview, which can be found here:
More specific requirements can be found under registration of business and expected packaging quantities and ongoing reporting.