VANA and our founders call on the authorities for decisive clarifications prior to legislative proposals and registration obligations

In the joint request, the authorities are encouraged to:

• Send information directly to the relevant companies and prepare a guide, including clarification of doubts in the definition of producers before the summer holidays
• Confirm group enrolment options in DPA
• Ensure an effective date that takes the companies' budgeting processes into account.

Read the joint request here.

At the time of writing, the Danish Environmental Protection Agency's information letter is being sent to thousands of companies, and yesterday the Ministry of the Environment sent a draft amendment to the Environmental Protection Act for consultation.

The crucial points of impact in the bill are:

• Producer responsibility is proposed to be postponed from 1 July 2025 to 1 October 2025:
  This date is far from optimal for companies' budget processes, which is emphasised in the joint request. VANA and our founders continue to work for 1 January.
• The registration deadline of 31 August 2024 has been maintained:
  In the joint letter, it is also emphasised that clarification of the manufacturer definition, accompanying guidance and confirmation of group registration is absolutely crucial, and a clarification must be available before the summer holidays since the registration deadline is so close. As a member of VANA, you get help and guidance for registration and reporting in our Member Portal, see more here: Membership benefits | VANA
• Upcoming requirements for membership of a PRO (Producer Responsible Organisation):
  When the last part of producer responsibility is implemented, membership of a PRO will become a legal requirement according to the bill. VANA ensures equal treatment of our members taking market share into account, so that we as a PRO are attractive to all companies, regardless of size.

Read more about the status of the implementation here and VANA's consultation response after the consultation deadline on 22 August 2024.

If there are elements in the bill that you think could be usefully commented on in a consultation response, you are welcome to write to info@vana.dk.