VANA emphasises: Lack of guidance makes the producer responsibility unnecessarily burdensome for companies
Yesterday, VANA sent a consultation response to the Executive Order on the extended producer responsibility for single-use plastics to the Danish Environmental Protection Agency. VANA strongly urges that follow-up with guidelines with concrete examples and correlation to the producer responsibility on packaging should take place soonest possible, so that companies better can understand and comply with the requirements of the two new producer responsibilities.
In October, the Danish Environmental Protection Agency sent a draft of an amended Executive Order on single-use plastics for consultation. Changes to the Executive Order, which was issued this summer, primarily concern Appendix 2 on the calculation of the amount of single-use plastic products subject to reporting fees and rules regarding information.
VANA's CEO, Marianne Roed Jakobsen, emphasises: "At VANA, we constantly focus on how the administrative burdens and regulatory hassle can be made simpler for companies, which is why we generally encourage that both implementation and practice regarding the two producer responsibilities for single-use plastic products and packaging are synchronised and harmonised as far as possible. For example, we propose that both producer responsibilities come into force on 1 January 2026 and that companies are given methodological freedom in terms of group reporting."
VANA calls for that:
- the Danish Environmental Protection Agency (EPA) ensures comprehensive and uniform guidelines with concrete examples and links to the producer responsibility for packaging
- the understanding of the fee for single-use plastic products and the connection to the producer responsibility on packaging is clarified
- the implementation of the two producer responsibilities for single-use plastic products and packaging will be synchronised, so that both responsibilities come into force with the producer responsibility for packaging
- companies only have to report for single-use plastic products once a year
- the changes do not change the legal situation; including the current method of calculation
- The Danish Environmental Protection Agency describes how repayment can be handled in practice and across the EU
- there is freedom of method in connection with group reporting, as in the case of packaging, and that this is stated directly in the Executive Order
- The fee is adjusted regularly to reflect the quantities actually collected and treated
- it is ensured that the obligation to provide information, which is carried out by both municipal councils and the Danish EPA, does not entail double fees.
"Furthermore, we also call for companies to report their single-use plastic products once a year and for the clean-up fees to be continuously adjusted to reflect the actual quantities collected. Anything else is not fair," concludes Marianne Roed Jakobsen.
VANA's consultation response was signed by CEO Marianne Roed Jakobsen and VANA's Board of Directors and sent to the Danish EPA on 18 November, which was the official consultation deadline.
Find more information about the status of the implementation of producer responsibility for single-use plastic products and packaging here and about relevant legislation here.
Note: Deadline 17 December 2024
The deadline for registration of a number of single-use plastic products remains 17 December 2024 at the latest, and the first reporting of quantities musttake place between 1 and 10 April 2025. If you have chosen VANA as your PRO (Producer Responsibility Organisation)e for single-use plastics, you can manage reporting for both single-use plastic products and packaging in the Member Portal.
Choose VANA for single-use plastics and manage all registration and reporting together