Dansk 
Date: March 4th 2026
Denmark ranks mid-range on price in COWI’s neighbouring country comparison of packaging producer responsibility. However, several important nuances lie behind the figures, including the fact that the data for the study was collected after a political intervention that secured a DKK 400 million reduction for Danish producers. Read on for an overview of the key nuances in the widely debated comparison.
A new neighbouring country comparison by COWI places Denmark in the middle of the field when it comes to the price level of packaging producer responsibility.
This is an important finding, and it has led several stakeholders to note that the high costs of the producer responsibility scheme, which many companies have criticised, may not be as well founded as previously assumed.
However, an important factor behind the comparison puts this conclusion – and Denmark’s mid-range ranking – into a different perspective.
The data used for the comparison was collected in October 2025, after a legislative intervention ensured that municipalities may only charge producers 62.5% of the actual costs of municipally collected packaging waste instead of 100%, and after the producer responsibility organisations had incorporated this regulation into their pricing.
This is significant, because it means that Denmark’s mid-range position in the comparison does not necessarily reflect the underlying cost level of the Danish system. It also reflects the effect of this political intervention, which in September reduced the costs of producer responsibility for Danish companies by approximately DKK 400 million.
However, producer responsibility should not only be assessed based on whether costs are higher or lower than in neighbouring countries. It should also be evaluated based on whether the system is stable, transparent and fair for the companies that finance it.
The comparison shows that Denmark is not unequivocally more expensive. But it also shows that Denmark has chosen a model that is technically ambitious, municipally cost-based and fully environmentally modulated from the outset.
This has clear strengths, particularly in relation to the upcoming requirements under the EU’s Packaging and Packaging Waste Regulation (PPWR). At the same time, during its early implementation phase the model has led to considerable volatility and large differences in municipal pricing, which in turn affect the prices set by producer responsibility organisations and create uncertainty for companies.
Emballageretur’s position is therefore clear:
Denmark’s mid-range position on price is not a definitive conclusion, nor is it sufficient in itself. Producer responsibility must work in practice for the companies that finance the system.
This requires greater transparency in municipal pricing, more consistent principles for calculating costs, and more stable framework conditions so that companies and producer responsibility organisations can budget and compete on equal terms.
New legislation is currently under consultation that may once again change the framework for pricing. As a result, we cannot assume that Danish prices for household packaging will remain mid-range after 1 July this year.
At the same time, we should acknowledge what is working.
Denmark is among the countries that are regulatorily most advanced in implementing eco-modulation, and is therefore better prepared for the upcoming requirements under PPWR.
The key question is therefore not simply whether the system is expensive or inexpensive.
The question is how to make it more robust.
In the following sections, we review the report’s main findings and what they mean for the development of producer responsibility in Denmark.
1. Price levels: Denmark is neither more expensive nor cheaper – unless we look at commercial packaging
The overall conclusion of the COWI report is that Denmark does not appear to be clearly more expensive or cheaper than other countries. However, the picture becomes more complex when looking more closely at the data.
For household packaging, prices vary significantly between countries and between material fractions. Denmark sits solidly in the middle – neither consistently high nor low.
However, it is important to emphasise that this picture is based on prices after the legislative change limiting municipal charges to 62.5% of the actual costs of municipally collected packaging waste.
If the analysis had been based on municipalities’ full costs, the picture would likely look significantly different, as producer payments for household waste represent a substantial share of companies’ overall costs.
The lowest prices are found in Estonia and Germany. These countries typically have:
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Full financial and operational responsibility placed with the producer responsibility organisations (meaning producers finance and organise collection and treatment through the schemes)
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Lower service levels
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Limited practical implementation of eco-modulation
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Systems that do not yet fully comply with the PPWR
Sweden and Belgium, whose systems more closely resemble the Danish model, have price levels similar to or higher than Denmark’s and generally higher than Estonia and Germany.
Price levels are therefore not only a matter of efficiency but are closely linked to the level of ambition and degree of implementation.
When it comes to commercial packaging, however, the picture is markedly different compared to neighbouring countries.
The report concludes that Danish prices for commercial packaging are significantly higher than in the other countries. Since commercial packaging represents approximately half of the total packaging volumes in Denmark, this is important for the overall cost picture.
At the same time, the definition of commercial packaging differs between countries. Denmark likely includes more household-like packaging in the commercial category, which affects comparability.
This also means that producers of commercial packaging may effectively be contributing to the cost of household waste in other countries, helping to keep household prices lower when the burden is distributed across a broader base.
Direct price comparisons without understanding system design and definitions can therefore be misleading.
For this reason, Emballageretur believes that the conclusion that Denmark sits “mid-range” cannot stand on its own. Price levels must be seen in the context of system design, definitions and policy ambition before clear conclusions can be drawn.
The analysis also highlights that the political intervention reducing municipal charges has had a major impact on the current price level for household packaging. Similar considerations may therefore be relevant for commercial packaging, where Denmark still ranks relatively high.
2. Denmark’s particular challenge: Uncertainty in the pricing system
The COWI report compares price levels. However, for Danish producers the greatest challenge has not only been the level itself but the uncertainty surrounding payment levels, driven by variations in municipal pricing.
In Denmark, each municipality sets its own costs for managing packaging waste, which are then financed through producer responsibility.
As a result, during the implementation of packaging producer responsibility, producers have in a short period experienced:
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Initial estimates
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Municipal cost determinations
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Subsequent adjustments
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New allocation mechanisms
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Announced legislative changes
This volatility creates uncertainty about producer responsibility costs, and uncertainty itself is an economic burden.
A key question only indirectly addressed in the report is the transparency of municipal cost calculations.
It remains unclear:
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how costs are calculated
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how they are allocated across fractions
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how large the variations between municipalities are
Lack of consistency and transparency can weaken trust in the system and make it difficult to assess whether cost levels are justified.
At the same time, the Danish model can create distortions because companies’ payments may vary significantly depending on which municipalities their producer responsibility organisation is allocated to and how the scheme is organised.
Emballageretur has for some time highlighted the need for clearer guidance, greater standardisation and more consistent principles for calculating municipal costs. We have previously presented concrete proposals on how greater uniformity and stability in municipal pricing could be achieved.
An important finding of the report is that none of the other countries analysed use a model similar to the Danish one. In most neighbouring countries, producer fees are relatively stable, enabling long-term budgeting.
When the report compares price levels without simultaneously addressing differences in governance models and price stability, it does not present the full picture.
For Emballageretur, this does not mean Denmark should simply accept being mid-range on price. It means the report should be used as a starting point to strengthen transparency, stability and predictability in the pricing system.
This could include clearer guidance to municipalities, greater standardisation of service levels and a more consistent and fair allocation of costs.
3. Eco-modulation: Denmark is the most advanced – and this matters for PPWR
A key finding of the COWI report is that Denmark is currently the only country in the comparison that has implemented eco-modulation across all material fractions.
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Sweden and Belgium have introduced modulation but are not considered fully PPWR-compatible
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Germany and Estonia have only limited implementation in practice
Denmark therefore appears regulatorily among the most advanced systems in the comparison.
This is particularly important in light of the EU Packaging and Packaging Waste Regulation (PPWR), where eco-modulation will become a mandatory element and a condition for market access.
When eco-modulation becomes a requirement for market access, the key question will not only be who has the lowest fees today, but who has already implemented the requirements that all countries will soon need to meet.
Countries that have not yet fully implemented eco-modulation will need to adjust their systems as PPWR enters into force. This may affect data requirements, administrative structures and contribution levels.
The comparison is therefore not static – it is dynamic.
Price levels cannot be assessed in isolation from ambition and implementation. Denmark has already undertaken part of the regulatory transition that other countries still have ahead of them.
Read more in our blog on PPWR and remember to sign up for our courses.
4. Administrative structure and the producer experience
In Denmark, producers pay fees to three different entities:
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the Danish Environmental Protection Agency
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the Danish Producer Responsibility organisation (DPA)
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the producer responsibility organisation
This contributes to a perception of administrative complexity and multiple parallel contact points.
In Belgium, administrative costs are collected collectively through the producer responsibility organisations based on market share.
There may therefore be inspiration to draw from models that create more coherent structures and simpler contact points for producers.
A more integrated administrative model could reduce perceived complexity without weakening control, transparency or ambition.
5. Free-riders: A shared European challenge
All countries in the comparison face challenges with free-riders.
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Estonia uses tax authorities in enforcement
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Germany has strong controls at the retail level
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Sweden reports that insufficient enforcement may affect fee levels
A common pattern across countries is that the stronger the enforcement focus, the greater the perceived scale of the problem.
Free-riding is therefore a structural and European challenge, not a uniquely Danish one.
From our sister organisation Elretur, we know that Denmark has faced free-rider challenges in the electronics sector for many years.
Experience shows that if registration, monitoring and sanctions are not sufficiently clear and consistent from the authorities, compliant producers risk carrying a disproportionate share of the costs.
This underlines that a robust producer responsibility system is not only about price levels and system design, but also about effective regulatory enforcement.
What does the comparison mean – and what are the next steps?
The comparison shows that Denmark is not unequivocally more expensive than neighbouring countries. This is an important finding in a debate often reduced to price alone.
However, the report primarily compares price levels – not governance models. It does not address whether the Danish design creates the most stable and transparent framework for companies.
At the same time, Denmark is among the most advanced countries in terms of eco-modulation. We have already implemented key elements that other countries will still need to incorporate as PPWR enters into force.
The comparison therefore does not show that Denmark should lower its ambitions.
It shows that we must ensure those ambitions rest on a more robust foundation.
If producer responsibility is to function in the long term, it requires both a high level of ambition and high system quality.
For companies, the key issue is not only the level of fees but the ability to trust the calculation basis, plan ahead and compete under fair and transparent conditions.
That is the direction the development of producer responsibility in Denmark should take.
