It is here: Part 2 of the Executive Order in consultation now

The second part of the executive order sets among other things the criteria (design requirements) for the eco-modulated fees, as well as the framework for organising responsibility and transfer, compensation and take-back schemes.  At VANA, we are currently reading and preparing consultation responses to the Ministry of the Environment, and in this connection, we can already highlight three key points that will be crucial for companies. 

Please note that there may be changes, since the executive order is still only in consultation and should therefore be considered a draft: 

• Actual packaging volumes made available in 2024 must be reported before 1 June 2025

Until now, the Danish Environmental Protection Agency has stated that packaging volumes should only be reported again after the producer responsibility comes into force. The executive order states that reporting must be submitted one more time before 1 June 2025. 

For VANA's members, this simply means that the advance quantities you reported in 2024 must be adjusted or confirmed in the Member Portal.  Member Services will of course be ready with help and guidance.

• Quantities must be reported in 13 categories with a 35% ‘penalty’ for packaging with low recyclability

The costs that companies must cover will be eco-modulated within 10 material categories. Be aware that the design requirements for plastics are divided into four subcategories. Companies that market packaging with low recyclability will pay a larger share (35%) of the costs as an incentive to work with more sustainable packaging (specific design requirements can be found in Appendix 14 of the Executive Order).

 The 13 material categories are: 

1) cardboard
2) paper
3) ferrous metals 
4) aluminium
5) glass
6) plastic (subcategories: flexible plastic, rigid plastics, foam plastic, and rigid PET).
7) food and beverage cartons
8) wood (will not be eco-modulated)
9) textile (no payment for waste management)
10) porcelain (no payment for waste management)
11) cork (no payment for waste management)
12) ceramics (no payment for waste management)
13) other (no payment for waste management). 

3) Requirement for membership of a PRO (producer responsibility organisation) by 14 January 2025

Covered companies must join a PRO at the same time as they are registered in the official register with DPA (Dansk Producentansvar). Companies that are already registered with DPA but have not joined a PRO must do so by 14 January 2025. 

Read more about how to become a VANA member and obtain benefits here.

Dive in and learn more

Find the executive order and the full consultation material here.

We hold a webinar for members on 3 October 2024 at 10-11 a.m. (in Danish) with clarification, explanations and the opportunity to ask questions about the executive order. VANA members have been notified directly. 

If you are not a member yet, you can sign up here until the day before the webinar if you would like to participate.