Dansk 
Emballageretur has sent our consultation response to the Ministry of Environment’s supplementary consultation on the revised draft of the regulation on registration and reporting of packaging.
In our consultation response, we address several points, including:
Implementation Date:
We request that the Ministry of Environment consider postponing the implementation date for the Extended Producer Responsibility for Packaging to January 1st, 2026.
Increased Bureaucracy and Pricing:
When reviewing the draft, Emballageretur believes that the producer responsibility has, in many cases, been over-implemented and does not account for regulatory simplification and transparency, which we have supported and advocated for throughout the process.
We are therefore concerned that the overarching goal of introducing the Extended Producer Responsibility for Packaging – namely, to reduce the amount of packaging, ensure effective collection and handling of packaging waste, and motivate companies to develop better and more environmentally friendly packaging designs – risks being lost in increased bureaucracy and cumbersome processes between the involved parties.
Furthermore, we express serious concern that the increased bureaucracy will have a significant and unnecessary impact on the price of packaged products when the Extended Producer Responsibility for Packaging comes into effect. We also question whether concrete economic calculations have been made on what the increased administration due to this bureaucracy will cost Danish businesses, in addition to the proposed fees that producers will need to pay.
Lack of Registration and Reporting from Affected Companies:
As of August 22nd, 2024, there are currently approximately 2,400 companies that have either individually or collectively registered and reported their expected packaging quantities for 2024 to DPA.
In Emballageretur’s view, this is critically low, as the authorities themselves have estimated that up to 41,000 companies will be covered by the upcoming regulations. Consequently, there are potentially many companies that will not fulfill their obligations under the producer register regulation, which is unfair to those companies that have actually registered by August 31st, 2024.
The situation is critical, and we recommend that the authorities strongly consider the next steps after August 31st, 2024, for how the remaining companies will be registered and report their packaging quantities. With the current registration level, we anticipate a distortion of competition between registered and non-registered companies.
Read the full consultation response here.
Other Highlights in the Consultation Response:
In addition to the three aforementioned points, we also address other issues such as:
- Increased supervisory efforts to reduce the number of “free riders”.
- Packaging quantities not covered by the Extended Producer Responsibility for Packaging.
- Cost-effective collection of packaging in municipalities.
- Complaint possibilities for calculation of municipal fees and setting deadlines.
- Establishment of a Financial Clearing House.
- Implementation of uniform rules across producer responsibilities.
- The Producer Responsibility for Fishing Gear – lack of targets and limitations in producer responsibility.
- Harmonization of the threshold for packaging.
- Coverage of costs for handling packaging waste from waste-producing companies.
- Establishment of service levels for municipal task management.
- Allocation periods.
- Use of a common municipal invoicing template.
- Transfer of waste.
