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. Members of VANA can register and report directly through the Member Portal.
Read more about registration and reporting obligation here
From October 1, 2025, you must report your actual available quantities based on the design criteria for eco-modulation. Find the link to the Danish Environmental Protection Agency's guidance here.
If you place reusable packaging on the market, the company must register in the category 'Reusable Packaging'. Quantities made available for 2024 must be reported by May 31, 2025, at the latest.
Find the definition of reusable packaging here
The registration is open at DPA. Members of VANA can complete the registration of reusable packaging directly through VANA's Member Portal.
Read more about registration and reporting of reusable packaging here
If the packaging consists of multiple materials that cannot easily be separated and do not fall under the mentioned material categories, the total weight should be reported in the material category that the packaging predominantly consists of.
The authorities have defined weight as the determining factor in other areas of implementation. Until there is guidance available, we therefore recommend assessing "predominantly" based on the material that weighs the most in the packaging.
See also VANAs guide here: Reporting of packaging quantities 2024
See more about packaging types here
The Environmental Protection Agency confirms that there is freedom of method. Therefore, corporations that have decisive influence over packaging will be able to register their responsibility centrally from the parent company, even if there are several independent CVR numbers within the corporation.
The important thing is that all quantities are registered. The oversight will focus particularly on whether reporting is done correctly in cases where a corporation has reported on behalf of multiple CVR numbers.
The method used regarding the corporation or individual CVR must be described and justified in the mandatory self-control mechanism. You can find a template for self-assessment here: Templates for self-assessment | VANA
The main rule is that producer responsibility falls to the company that first makes available packaging or packaged products on the Danish market.
The determining factor for the allocation of producer responsibility is whether the packaging/packaged products are designed/manufactured under one’s own name and trademark, or whether they are generic packaging.
Packaging/packaged products manufactured/designed under one's own name and trademark In the Danish Environmental Protection Agency's guidance (link), it states that responsibility may fall to another company than the manufacturer if one of the following conditions is met:
- If a company has the packaging designed
- If a company has the packaging manufactured in the company's own name
- If a company has the packaging manufactured under its own trademark.
Generic packaging
According to the Danish Environmental Protection Agency, 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 producer responsibility.
Overall, it is therefore important for a company to be aware of whether it is manufacturing packaging for a company that meets one of the three conditions above, as this is crucial for the allocation of responsibility.
The Danish Environmental Protection Agency states that it is a specific assessment when it comes to determining whether packaging is generic and when it can be said to be manufactured or designed under one’s own name and trademark. And in case of doubt, it is the Danish Producer Responsibility (DPA) that, as an authority, can make a decision regarding the individual product.
It is stated in the draft amendment to the Environmental Protection Act from 2024 that the Ministry of Environment will establish rules regarding procedures for reimbursement 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. Find relevant legislation here.
According to the draft of the statutory order on extended producer responsibility for packaging (expected to be issued at 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 Environment emphasizing that companies should avoid significant administrative burdens and liquidity challenges in this regard, and additionally urged that the definition of availability on the Danish market, as well as how reimbursement can be handled in practice, be clarified in guidelines. Read VANA's full response here.
Danish Producer Responsibility (DPA) informs 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 that 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 regarding repackaging
• If a foreign company, for example, sells packaged products to Danish company A via fjernsalg, 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 obtain producer responsibility.
Labels that are directly affixed to a product or otherwise placed on the product are a form of packaging.
Self-adhesive labels placed on another packaging item are part of the packaging. For more information about packaging, read here.
For the assignment of responsibility for labels, read more here.