Partial clarification on the allocation of responsibility for reusable packaging.

VANA has continuously, including in our consultation response, made the authorities aware that there is ambiguity regarding the understanding, responsibility allocation, and registration of reusable packaging, e.g., EUR pallets. Since it is not necessarily the same company that puts reusable packaging on the market and simultaneously handles take-back, and thereby recycling of the packaging in a reuse loop, it has led to much doubt about, among other things, the allocation of responsibility.

The Environmental Protection Agency has now provided some partial clarification. We are still awaiting examples to be included in their guidance material (Danish), but for now, they have confirmed that:

• the same producer definition applies to both single-use and reusable packaging.
• it is Dansk Producentansvar (DPA) that can decide whether a company is subject to the obligation to register, and whether a packaging is single-use or reusable packaging

Additionally, they have sent some written examples of responsibility allocation regarding reusable packaging, e.g., for a Danish company that imports/distributes reusable packaging in reuse systems such as EUR pallets.