VANA still sees challenges despite improvements in the new allocation

Dansk Producentansvar (DPA) has, on April 4, 2025, sent out a new version of the allocation for packaging for consultation. The allocation contains improvements compared to the first draft, but there are still challenges that should be addressed.

Read VANA's full consultation response (Danish)

VANA suggests the establishment of a follow-up group

Although the allocation has become slightly more balanced, there are still challenges – particularly with the allocation of joint collections and clear frameworks for organisational and financial responsibility. To ensure ongoing improvements and better implementation of producer responsibility, VANA recommends that DPA establishes a follow-up group involving collective schemes, municipalities, DPA, and possibly other relevant stakeholders.

Precision vs. Practice

DPA prioritises market shares and high precision as the primary criterion for allocation. VANA agrees that market shares are crucial but emphasises that the reported quantities are associated with significant uncertainty – among other things due to a lack of guidance and because companies have been uncertain about whether their packaging should be registered as household or commercial waste.

VANA suggests that an allocation with lower precision, which also takes into account considerations for combined and joint collections, will be far more cost and logistically efficient as well as administratively sustainable.

Competition Considerations

With such a fragmented allocation and the potential need for coordination among the collective organisations, VANA encourages the competition law aspects of the allocation to be addressed to ensure clear frameworks and minimum requirements for this.