Dansk 
The compensation model for commercial packaging should be reconsidered
The current model for compensation for commercial packaging waste entails significant administrative burdens and involves a risk of incorrect payments. Very large resources are currently spent on administration rather than on real environmental impact.
We therefore propose that the model be fundamentally simplified, and that the Act provides greater flexibility to establish a more flexible and secure scheme in the executive order.
Producer fees and transparency
There are significant differences in municipal producer fees without access to transparency in the calculation basis and without a real possibility of having errors corrected.
This may create distortion of competition between producer responsibility organisations. We therefore propose that a legal basis is established to correct errors in producer fees, including with retroactive effect.
Clarity regarding the approval of producer responsibility organisations
It remains unclear how and when the approval procedure for producer responsibility organisations will be carried out. This uncertainty makes planning, conclusion of contracts and financial management more difficult.
The framework should be communicated clearly and in a timely manner, so that the implementation can take place efficiently and uniformly from day one.
Emballageretur is pleased to participate constructively in the further dialogue and to contribute practical experience from operating producer responsibility schemes on behalf of more than 3,400 Danish companies.
Additional measures that can strengthen enforcement and practical operation
Emballageretur also points to three specific elements that can make producer responsibility more enforceable and easier to operate in practice:
- Authorised representatives for producers from third countries: The possibility of imposing requirements for authorised representatives may reduce free riders and strengthen enforcement, but this presupposes clear procedures and a clear allocation of responsibility.
- Duty of disclosure in connection with transfer of waste: When municipalities are required to transfer household packaging waste, including commercial packaging waste collected together with household waste, to producer responsibility organisations, the duty of transfer should be supplemented by a duty to provide key information in good time, for example time of transfer, quantities, composition and place of transfer.
- Reasonable consequences in case of missing municipal information: If the municipal council does not provide the necessary information in due time, sanctions linked to the producer responsibility organisation’s start-up obligations should lapse, because the organisation cannot be expected to comply with requirements without the necessary prerequisites.
Read the full consultation response from February 2026 here.
