Recyclable packaging: All companies must register by 1 February

Since the Packaging Order (Emballagebekrndtgørelsen) came into force at the turn of the year, there has been great uncertainty about the interpretation of the legislation in relation to which companies should be registered, who and whether or not quantities of reusable packaging should be reported before the deadline of 1 February 2025. Therefore, VANA has been in ongoing dialogue with the authorities over the past few weeks, and the Danish Environmental Protection Agency has now changed the guidance (see the Danish Environmental Protection Agency's elaboration marked in italics below).

This means that ALL companies that make reusable packaging available MUST be registered for reusable packaging in the authorities' register at DPA - even if they are already registered.
If you are a member of VANA, you must therefore, before the deadline of 1 February 2025, go into the Member Portal and opt in for reusable packaging if you make these available on the Danish market.

No reporting of quantities yet
No quantities - neither expected nor actual - need to be reported when registering reusable packaging as a packaging type if you are already registered in the DPA for packaging.

The Danish Environmental Protection Agency's amendment and elaboration reads:

Companies covered by
the rules are obliged to be registered in the Danish Producer Responsibility (DPA) register. When a company is to be registered in the producer responsibility register, it must be stated whether the company makes disposable packaging, reusable packaging or both types of packaging available.

The requirement to register and report reusable packaging came into force together with the issuance of the final legislation on 31-12-2024 (ed. the Packaging Order). During 2024, companies covered by producer responsibility had to comply with temporary rules in accordance with the Executive Order on the Registration and Reporting of Packaging that did not require registration of reusable packaging. The temporary rules meant that companies had to report the quantities of disposable packaging that they expected to make available in 2024 before 31-8-2024. When companies report the actual quantities of disposable packaging available in 2024 before 1 June 2025, there is a requirement that any quantities of reusable packaging made available in 2024 must also be reported.

You can find the rules on producer responsibility for packaging here.

What your company must do in 2025
What you are obliged to do in 2025 depends on the type of packaging that your company has made available in 2024 (disposable or reusable packaging). If you start making packaging available in 2025, there are also different requirements depending on whether the availability starts before or after 1 June.

Companies that have made DISPOSABLE PACKAGING AND REUSABLE PACKAGING available in 2024

1. A) Companies that have made both reusable packaging and disposable packaging available before 31-12-2024 and that are already registered in DPA's register for disposable packaging:

REUSABLE PACKAGING REGISTRATION: Before February 1, 2025, you must reopen your registration with DPA and add reusable packaging as the packaging type.

REPORTING: Before 1 June 2025, you must report actual quantities of disposable and reusable packaging available in 2024 per material category.

1. B) Companies that are the only type of packaging that have made REUSABLE PACKAGING available before 31-12-2024:
   
   REGISTRATION OF REUSABLE PACKAGING: Before 1 February 2025, you must register with DPA for producer responsibility for packaging and select reusable packaging as the packaging type.
   
   REPORTING: Before 1 June 2025, you must report actual quantities of reusable packaging available in 2024 per material category.

Companies that START making REUSABLE OR DISPOSABLE PACKAGING AVAILABLE IN 2025.

Commencement will take place before 1 June 2025:

1. A) Company that is already registered in DPA's packaging register:
   REGISTRATION: 14 days before the new packaging type is made available (disposable or reusable packaging), you must reopen your registration with DPA and add the new packaging type.
2. B) Company that is not in DPA's packaging register:
   REGISTRATION: 14 days before the start of the making available, you must register with DPA for packaging producer responsibility and choose the type of packaging (disposable or reusable packaging or both).

Commencement will take place after 1 June 2025:

1. A) Company that is already registered in DPA's packaging register:
   REGISTRATION: 14 days before the new packaging type is made available (disposable or reusable packaging), you must reopen your registration with DPA and add the new packaging type.
   
   PROVIDE EXPECTED QUANTITIES FOR THE WHOLE OF 2025: At the same time as the registration, you must provide the expected quantities made available for the whole year 2025 for the newly added packaging type.
2. B) Company that is not in DPA's packaging register:
   REGISTRATION: 14 days before the start of the making available, you must register with DPA for producer responsibility on packaging and choose the type of packaging (disposable or reusable packaging or both).

PROVIDE EXPECTED QUANTITIES FOR THE WHOLE OF 2025: At the same time as the registration, you must provide the expected quantities made available for the whole year 2025 for the added packaging type(s).

Read more in the Danish Environmental Protection Agency's guidelines here.  

You can also find more information about reusable packaging and the reporting in 2025 here