Dansk 
Earlier this week, the Danish Chamber of Commerce, the Confederation of Danish Industry, and the Danish Agriculture & Food Council sharply criticised the implementation of the extended producer responsibility for packaging. Particularly under fire is the high municipal pricing for waste management.
At Emballageretur, we fully share their concern.
Together with ERP Denmark, we have warned the authorities and the parliamentary parties behind the producer responsibility for packaging about these challenges since April 2023. We raised the issue again in October 2024, when one of our spot checks revealed that municipal costs per household could differ by as much as 79%.
We recognise that there may be valid reasons for price differences between municipalities, but the problem arises when producer responsibility organisations (and thereby companies) are assigned different cost levels based on chance.
However, there is a solution to this problem, which Emballageretur and ERP Denmark presented back in spring 2023: a financial clearing house to even out the differences in municipal fees and ensure fairer, more predictable costs for Danish businesses.
Unfortunately, the proposal from Emballageretur and ERP – two of Denmark’s most experienced producer responsibility organisations – was not supported.
Instead, a possible reconsideration was postponed until after the ramp-up period – that is, at the earliest in 2027.
Now we see the consequences:
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Differences in municipal fees of up to 4,000%
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Opaque calculation bases causing uncertainty for businesses
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Risk of higher prices for consumers
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Municipalities lacking guidelines – companies paying the price
While the criticism from the Danish Chamber of Commerce is justified, it does not tell the whole story.
A major reason for the large differences in municipal fees is that municipalities have never received clear guidance from authorities on how to calculate their costs for collecting household packaging waste.
In addition, waste collection companies’ prices vary significantly between municipalities due to differences in geography, population density, and local systems. This means companies selling the exact same products may face vastly different bills – purely depending on where their packaging waste is collected. Again, this is a problem a financial clearing house could solve.
The system contradicts the fundamental idea of producer responsibility
There is nothing fundamentally wrong with a litre of milk costing more if it is sold in packaging that harms the environment more than necessary. That is the entire premise of the extended producer responsibility: that environmental impact should be reflected in the price, so both companies and consumers make better choices.
But right now, it is not environmental concerns that are making packaging more expensive. It is a mess. A mess in processes, calculations, municipal fees, and the system’s structure.
It is obviously unfair that two companies with identical products end up with completely different costs just because their producer responsibility organisations collect waste in two different municipalities. Nor is it fair if companies’ very existence is threatened by the costs of taking responsibility for their packaging waste.
The result is a system that contradicts the fundamental idea of producer responsibility: that packaging with the greatest environmental impact should be more expensive than more environmentally friendly alternatives – not that companies should pay extra because municipalities have chosen different collection solutions and lack a sufficient calculation basis.
Listen to those of us who work with producer responsibility in practice – and let’s fix this
The biggest challenge with implementing the producer responsibility for packaging has undoubtedly been Denmark’s hesitation in fully implementing it by the deadline – and even after.
This has led to rushed processes, missing guidelines, postponed deadlines, high prices, and unclear information – which is highly critical for a producer responsibility system set to cost Danish business billions.
Far too few have listened to those who actually understand how the system works in practice.
Our message is simple:
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We need a national guideline so municipalities calculate fees uniformly and transparently.
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We need to revisit the idea of a clearing house before the problem grows even bigger.
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We need the necessary legal authority to correct any calculation errors that may already exist.
Emballageretur remains ready for dialogue.
Because if we don’t get this right now, the producer responsibility for packaging will be neither green nor good. It will just be expensive and messy.
