You can quickly find the answers to your questions in our FAQ.
If you wish to delve deeper into a topic, visit our dedicated theme page about the Producer Responsibility.
Remember! If you can’t find the answers to your questions, we are always ready to help you by phone or email. Contact us.
The Producer Responsibility for packaging is based on the principle that the ‘polluter pays’.
This means that if a company places a product on the market, the company bears the judicial, financial and practical responsibility for collecting and handling waste generated by the product.
The Producer Responsibility for packaging covers all companies that package their products or import packaged products, making the company using the packaging responsible instead of the packaging manufacturer.
The Producer Responsibility for packaging covers all types of packaging, meaning that whether the material is plastic, glass, wood, metal, cardboard, paper, etc., and regardless of where it is used – in households, industry, offices, the service sector, etc. – it is covered by the Producer Responsibility.
We differentiate between three types of packaging: 1) Primary packaging/sales packaging, 2) Secondary packaging/multipack, and 3) Tertiary packaging/transport packaging.
There is a distinction between transport packaging with and without a trademark (logo/private label).
No own trademark
If a company receives transport packaging without a trademark, the packaging producer holds the Extended Producer Responsibility.
Own trademark
If a company has transport packaging designed or manufactured under its own trademark, the company itself holds the Extended Producer Responsibility.
Labels are generally not considered transport packaging. In cases where the label producer does not know the end use of the label, producer responsibility does not apply.
The general rule is that labels, which are purchased on rolls independently of the packaging and subsequently affixed to a specific packaging, become part of the packaging and end up in the waste stream together with the packaging. In this case, the entity that affixes the label to the packaging holds the producer responsibility.
If the label producer knows the end use and the printing on the label clearly indicates that it is to be affixed to packaging, it is the packaging filler who holds the Extended Producer Responsibility.
Packing slips and invoices are not part of the packaging and therefore do not need to be reported.
A product that is not originally made to serve as packaging is generally not covered by the producer responsibility. For example, this applies to moving boxes or gift wraps. However, if a company decides to use these products as packaging, the company that first uses the product as packaging in the Danish market will typically hold the producer responsibility – not the manufacturer or the company that resells the products as moving boxes.
Examples:
Please note:
According to Annex 1 of the new regulation, rolls, tubes, drums (e.g., made of cardboard) are considered packaging if a flexible material is wound around them (e.g., plastic film, aluminum, paper).”
The responsible producer is the ‘filler’ or ‘importer’ who markets or makes packaged products available in Denmark.
This means that companies covered by the Producer Responsibility for packaging, is not the company that manufactures the packaging itself but rather the one that places packaged products on the market that has the producer responsibility.
As a general rule, the covered companies can be divided into four main categories.
Read more about the four main categories here.
Pleae note! Be aware that your company may also be covered by the Producer Responsibility even if you are not responsible for the product in the primary packaging but perhaps only in the secondary or tertiary.
With the introduction of producer responsibility for packaging, the legislation includes special exemptions for micro-enterprises, which in Denmark are defined by the criteria: fewer than 10 employees and a turnover of less than 15 million DKK/year.
Exception: If you, as a Danish micro-enterprise, receive or have packaging (generic or branded) or packaged products manufactured by a Danish producer, the producer responsibility lies with the manufacturer – even if you are the one who actually makes the goods or packaging available to the end user in Denmark.
Exception to the exception: A Danish micro-enterprise must register if the sales packaging is manufactured by a foreign producer and imported (you will then have producer responsibility as importers).
The legislation is still under development, and not all rules are in place yet.
However, Emballageretur is built on almost 20 years of experience handling the Producer Responsibility.
We expect that, as a company with a Producer Responsibility, you will have the following obligations:
Around 41,000 companies will be covered by the Producer Responsibility for packaging.
The legislation is not yet finalized, and we cannot provide definite information regarding the financial framework for the Producer Responsibility.
However, for individual producers joining a PRO, the expense will consist of a combination of legally determined environmentally graded contributions, collection and treatment costs for the quantity of packaging the producer places on the market, and administrative costs.
Read more about the economic consequences here.
Emballageretur has developed the Price Indicator, a tool that can give you an idea of what the Producer Responsibility might potentially cost your company.
In 2024, companies covered by the Extended Producer Responsibility for Packaging will complete their first registrations. From April 1st, 2024, to August 31st, 2024, companies must report the quantities of packaging they expect to place on the market in the form of packaged products in 2024.
The materials to be registered in 2024 are:
The quantities of materials must be stated per packaging category (in kilograms), and the information will be used to make the allocation for the collection and treatment of packaging waste quantities in 2025.
If you are a member of Emballageretur, you must report your data via our Budget Form. You can find the form by logging in to the member pages. From here, you just need to follow the form’s instructions, and when all the data is ready, upload the completed budget form to us. We will then report your company’s packaging quantities to the DPA.
Please be aware; If we are to be your authorized representative, different rules apply. Contact us to learn more.
If your company markets packaging that is classified as hazardous waste due to its contents when disposed of (e.g., hairspray, cleaning and descaling agents, etc.), this must be registered separately.
The rules for the 2025 reporting are not yet fully in place. Therefore, it is not yet fully clarified what you must report as a producer responsible company.
However, we do know that your company’s quantities of reusable packaging will only need to be reported from 2025 onwards.
We will update you in our newsletter and here on the site as soon as we know more.
Read more about the upcoming producer responsibility for packaging here.
Companies subject to the Extended Producer Responsibility for Packaging must register with the DPA by August 31st, 2024. The Ministry of Environment informs that if a company covered by the Extended Producer Responsibility for Packaging does not fulfill its obligation to report expected packaging quantities for 2024, it may lead to a police report and a fine.
Companies that either register or begin marketing products subject to the Extended Producer Responsibility after August 31st, 2024 must register no later than 14 days before they start marketing these products.
By becoming a member of Emballageretur, we will register you with the DPA. You can use our budget form, which is available on the member page. Once you have completed the budget form, we will upload your packaging quantities to the DPA.
Please be aware; If you are an authorized representative, different rules apply. Contact us to learn more.
Note: Please note that we close for adjustments to the quantities in the budget form on June 4. If you have not yet completed the budget form, you can always enter your quantities, but you will not be able to make updates afterwards.
The DPA informs that if a company wishes to have a specific person make the report on the company’s behalf, the company can link that person to the company in MitID Erhverv as a new user.
If a company wants another VAT number to report on their behalf in the producer responsibility register, it is possible to create a “business power of attorney” in MitID Erhverv. Read more here.
The purpose of the environmentally graded contribution is to create an incentive for better packaging design.
The mechanism behind the environmentally graded contribution is that companies are rewarded with a discount on the costs of producer responsibility by using packaging with good environmental design, but penalized with an additional contribution for poor environmental design.
Specifically, the environmentally graded contribution adjusts the producers’ contributions to the collective schemes based on the environmental impact of the individual packages. This means that producers who market “good” packaging will pay less than producers who market “bad” packaging.
A trivial limit is incorporated into the producer responsibility for packaging.
The trivial limit applies to companies that place less than 8 tons of packaging on the market per year.
The trivial limit does not exempt companies from being subject to producer responsibility.
However, the trivial limit makes it easier to manage producer responsibility in certain respects, as the companies concerned are required to report fewer details about their packaging and are not subject to the same amount of administrative fees as companies that exceed the limit.
If your company falls under the trivial limit for packaging, you can choose to register or report your packaging quantities as “total packaging,” rather than distributing the quantities across individual material categories.
Companies with less than 8 tons of total packaging annually are not required to join a PRO. However, it may still be a good idea to join and report in more detail than required. For instance, Emballageretur assist you with registration, reporting, advice and guidance. You get access to highly specialized knowledge, relevant tools, ESG data, etc.
When municipalities have collected packaging waste, the waste is transferred to the PRO at locations designated by, for example, Emballageretur.
Subsequently, for example, Emballageretur, on behalf of our members, handles the responsibility for further sorting and treatment of the packaging waste and ensures that our members meet the recycling targets set by the Producer Responsibility for packaging.
Individual businesses freely negotiate agreements with private collection companies to collect commercial waste.
The implementation of the Producer Responsibility for packaging does not change this approach.
The only difference is that the waste-producing company will be compensated for the costs it incurs for the collection and treatment of the portion of its waste, that is packaging waste.
A Producer Responsibility Organisation (PRO) is a private company that, for a fee, offers individual covered companies to perform the administrative and practical tasks associated with the Producer Responsibility.
There are both commercial and non-profit PROs. Emballageretur is organized as a non-profit PRO.
As a PRO, Emballageretur assumes the mandatory producer responsibility – legally, financially, and practically – on behalf of all companies that have joined us as members.
Emballageretur has been managing the Producer Responsibility since 2005, and we are by far the most experienced PRO in Denmark.
In the summer of 2024, the Danish Environmental Protection Agency informed companies operating in Denmark that it expects to make membership of a PRO a legal requirement from 2025.
There are many good reasons to register your company in a PRO as Emballageretur.
If your company is subject to the Extended Producer Responsibility for Packaging, your company has the practical, legal, and financial responsibility for handling your packaging when they become waste.
At first glance, this may sound quite straightforward, but there are many different tasks associated with having an Extended Producer Responsibility.
Your company must, among other things, be responsible for:
All these tasks are time-consuming and costly for a single company to handle alone.
As a PRO, we take on all these tasks collectively for our member companies.
Thus, we lift a significant administrative burden from your shoulders, we create economies of scale, and as one of the most cost-effective and experienced PROs in Europe, we also ensure you the most value and effect for your money.
Fortunately, it’s easy to join Emballageretur.
It only takes a minute. Simply click here and follow the instructions.
Emballageretur is here to help your company fulfill the Producer Responsibility for packaging.
In addition to the practical tasks associated with the Producer Responsibility, we offer free advice and guidance from our experienced team with relevant knowledge, webinars, tools, guides, newsletters, etc.
Read about the benefits of a membership at Emballageretur here.
Membership in Emballageretur costs 1500 DKK per year, regardless of the size of your company.
If you are already a member of one or more PROs under Retur, you only pay the total amount of 1500 DKK for all memberships.
You can sign up for Emballageretur by clicking here and following the instructions.
In addition to the practical tasks associated with the Extended Producer Responsibility, we offer free advice and sparring from our experienced team with relevant knowledge, webinars, tools, guides, newsletters, etc.
You can read more about the benefits of our membership here.
Read about the benefits of a membership at Emballageretur here.
As a member of Emballageretur, you will receive our ECO Badge.
The badge shows that you support a responsible course of development built on circular principles of increased reuse and recycling.
If your company places packaging on the markets in countries other than Denmark, you must comply with the respective countries’ rules regarding the Extended Producer responsibility for packaging.
If you sell your products in the EU, Norway, Switzerland, or the UK, Emballageretur can also help you fulfill your producer responsibility for packaging in those regions.
Retur is a family of non-profit Producer Responsibility Organisations managing the producer responsibility for electronics, batteries, packaging, and textiles on behalf of importers and producers.
As a member of one or more of Retur’s Producer Responsibility Organisations, you benefit from our nearly 20 years of experience and extensive knowledge of producer responsibility management.
We do more than just help you manage your producer responsibility in Denmark. We also handle your producer responsibility through WEEE Europe in the EU, Norway, Switzerland, and the UK.
Retur’s Producer Responsibility Organisations are among the most cost-effective collective compliance schemes in the EU, and through us you are guaranteed legitimate waste flows and reliable ESG data.
Recycling and reuse are an integral part of our organisation and daily work.
Together with the members of our Producer Responsibility Organisations – Elretur, Emballageretur, Batteriretur, and Tekstilretur – Retur works to lift as many materials as possible out of the waste stream through recycling and reuse.
Our efforts and those of our members contribute to several of the UN Sustainable Development Goals – especially no. 11, 12, and 14.
Emballageretur / Retur
Skagensgade 39, 2 sal
2630 Taastrup
Denmark
Phone: +45 3336 9198
Email: info@emballageretur.dk
VAT no.: DK-44502275
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