FAQ - Reusable Packaging
Packaging that has been designed, shaped, and brought to market with the intention 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 designed.
DPA states:
If your product clearly falls under the definition of reusable packaging, this packaging will only be covered when producer responsibility takes effect in 2025. The second part of the statutory order will describe how quantities of reusable packaging introduced to and taken back from the market must be accounted for.
In relation to reusable packaging, it is important to distinguish between “reusable packaging” as defined in the statutory order and the reuse of packaging. A packaging is not reusable packaging merely because it is reused as packaging. If it is a matter of the reuse of packaging, it is crucial whether a previous party has taken producer responsibility for the packaging. If Company A from Denmark reuses cardboard boxes as packaging that they have received as packaging from Company B from Denmark, which has reported the cardboard boxes as packaging in the producer register, the cardboard boxes do not need to be reported again.
It is also not a matter of “reusable packaging” merely because a packaging consists of recycled materials.
What distinguishes one-way packaging from reusable packaging is whether the packaging is designed for and included in an established reuse system that ensures the reusable packaging is taken back and used multiple times for the same purpose as it was designed for.
A one-way packaging does not become a reusable packaging just because it is used again (and that is a good idea).
See more about definitions of packaging here:
Prepare for producer responsibility with good packaging design
If you place reusable packaging on the market, the company must be registered in the category 'Reusable packaging'.
The registration is open at Dansk Producentansvar (DPA). Members of VANA can manage it directly through VANA's Member Portal.
Read more about the registration and reporting of reusable packaging
VANA has continuously, including in our consultation responses, made the authorities aware that there is a lack of clarity regarding the understanding, placement of responsibility, and registration of, for example, EUR pallets.
The Ministry of the Environment and Gender Equality has stated in their consultation note regarding the statutory order that they have informed the Danish Environmental Protection Agency and Dansk Producentansvar (DPA) that there is a need for clear guidelines and guidance for EUR pallets. The Danish Environmental Protection Agency has indicated that they will include this in the upcoming guidance work.
As clarification is pending, we cannot provide further details at this time other than to refer to DPA, which has the authority to make decisions in cases of doubt. We will, of course, inform as soon as there is clarification from the authorities.
For a packaging to be categorized as a genbrugsemballage, it is essential that the company takes back (link to take-back) the packaging with the aim of placing it on the market again in its original form. There will be specific rules on how genbrugsemballage quantities that are introduced and taken back from the market must be accounted for.
Reporting of reusable packaging
DPA states the following:
In relation to genbrugsemballage, it is important to distinguish between “genbrugsemballage” defined in the regulation and reuse of packaging. A packaging is not genbrugsemballage simply because it is reused as packaging. If it involves reuse of packaging, it is crucial whether a previous entity has taken the producer responsibility for the packaging.
If company A from Denmark reuses cardboard boxes as packaging, which they have received as packaging from company B from Denmark, which has reported the cardboard boxes as packaging in the producer responsibility register, the cardboard boxes do not need to be reported again.
There is also no notion of “genbrugsemballage” simply because a packaging consists of recycled materials.
Reuse of packaging is supported in the upcoming system by the fact that producers using reusable packaging only need to pay once for the packaging's circulation in the market. If a reusable packaging, for example, can be circulated 30 times before being discarded, a fee is only paid once instead of the 30 times that would have been charged with the use of one-way packaging.
It is desired in the political agreement on producer responsibility that flexible frameworks for producers with new packaging solutions are ensured, for example in the form of reuse and return systems. Read more here.
Read more about the registration and reporting obligation for reusable packaging
All three concepts are important to understand and know the difference between.
Reuse is when the packaging is collected and used again in its original form a number of times. For example, a cup that is washed and used again, still as a cup.
Recycling is when the packaging is shredded or separated and the material is used in and for new products. In the example with the cup, when it becomes waste, it will be treated and for example ground down to become new material such as rPET, which can be included in new products.
Recycled content is when the material included in a packaging (both single-use and reusable packaging) is recycled. This means that the raw material used for production is made of entirely or partially recycled material such as rPET. In the cup example, the cup can be produced with entirely or partially recycled raw material.