Eco-modulated fees

Bonus/malus-model

The eco-modulation must ensure cost neutrality for each individual material category, so companies with quantities in a material category as a whole do not pay more or less than the actual costs of waste treatment.
Read more about material categories here, and about waste management here.

The eco-modulation is based on a bonus/malus-model, where companies that make packaging with low recyclability available must pay a larger share of the costs.

Malus (additional cost)
The PRO must give producers who make packaging available at red level a malus in the form of 35 % of the individual producer's calculated operational costs for waste management of all their packaging that falls below the red level.

Bonus
The PRO must use the extra income from the charged malus for packaging at red level in a given material category to cover the operational costs of waste management of packaging at green level within the same material category.

For the material categories where there is a yellow level, the individual producer pays the calculated operational costs for waste management of the packaging that falls under this level.

However, companies must cover at least 20 % of the operational costs.

Read more about the requirements that apply in other countries here.

Categorization of packaging by level

Businesses must categorize their respective packaging into red/yellow/green levels based on the design criteria in the statutory order on packaging.

Packaging is categorized into the 10 subcategories for materials and hereunder either two (red/green) or three (red/yellow/green) levels.

1. Green level: Packaging that meets the design criteria for green level, and none of the design criteria for red level, within the individual subcategory of packaging.
2. Yellow level: Packaging that meets the design requirements for yellow level, and none of the design requirements for red level, within the individual subcategory of packaging.
3. Red level: Packaging that meets one or more of the design requirements for red level, or does not meet the requirements for green or yellow, within the individual subcategory of packaging.

If the business cannot document a design criterion, the packaging must be categorized at red level.

Find the Danish Environmental Protection Agency's guidance on the design criteria here.

The role of VANA in eco-modulation

Once you have categorized your packaging and reported your quantities in the levels red/yellow/green in the Member Portal, we ensure the mandatory reporting to DPA as well as the further processing of your packaging waste based on VANA's high requirements for price and environmental responsibility.

VANA is responsible for ensuring that your financial contributions for the handling of packaging waste are eco-modulated correctly. We do this by:

1. ensuring that the reporting in the Member Portal is done in the mandatory material categories and levels (red/yellow/green), and that the invoicing is based on the rules regarding the distribution of bonus/malus.
   
   
2. supervising that members' reporting is categorized at the correct level, for example, through random checks, etc.

VANA is in dialogue with the Environmental Protection Agency about what documentation is sufficient for you as members to meet the design criteria in environmental grading. We are also working to ensure that the guidelines are updated so that companies have a better basis for working with the categorization of their own packaging.