The Extended Producer Responsibility for Single-Use Plastic Products

Studies have shown that plastic makes up between 80 and 85% of all waste on beaches. Of this, single-use plastic products account for about 50%.

Therefore, with the Extended Producer Responsibility for Single-Use Plastic Products, there is a particular focus on collecting products that are frequently found on beaches, coastlines, and other areas in nature.

At the same time, the ambition is to promote the use of reusable and recyclable products, so they can become part of a circular economy rather than ending up as waste after a single use.

An important part of the Extended Producer Responsibility for Single-Use Plastic Products is, therefore, the introduction of a cleanup responsibility for certain producers.

The cleanup responsibility for a range of single-use plastic products will be introduced from January 1st, 2025. This means that, from that date onward, producers will have to pay for the cleanup performed by municipalities and the state.

A large portion of the waste collected from trash cans or public spaces is single-use plastic. The purpose of producer responsibility is therefore to reduce plastic pollution, protect the marine environment, and make producers more accountable for the entire lifecycle of the products they bring to market.

With cleanup responsibility at the core of the Extended Producer Responsibility for Single-Use Plastic Products, companies that manufacture single-use plastic products are required to contribute to financing the cleanup and waste management if their products end up in nature or public spaces.

This responsibility especially applies to products such as plastic bottles, cigarette butts, food containers, cutlery, and straws — the products that are frequently found as waste in nature.

The producer responsibility supports the EU’s goal of reducing plastic pollution and gives producers a greater responsibility for the entire lifecycle of the product.

The cleanup responsibility element can also include financial support for awareness campaigns on the correct disposal of plastics and their environmental impact. With this initiative, the goal is to push producers to develop more sustainable designs, reduce plastic consumption, and switch to materials that are easier to recycle or reuse.

How does producer responsibility work?

Because the Extended Producer Responsibility for Single-Use Plastic Products is essentially a cleanup responsibility, this means that you, as affected companies, in collaboration with local authorities and waste organizations, must cover the costs of:

• Cleanup: Contribute financially to the cleanup of single-use plastic waste in nature and public spaces, especially on beaches, in parks, and along coastal areas.
• Waste management and recycling: Ensure that there are the necessary facilities and systems to collect and recycle single-use plastic products so that they do not end up in the environment.
• Awareness and prevention: Fund information campaigns that aim to educate consumers about the correct disposal of single-use plastic products and the environmental consequences if these products are discarded in nature.

Your company’s share of the cleanup costs depends on how many products you sell and how large the cleanup task is. The fee will be charged by the Environmental Protection Agency (EPA).

As your PRO, Emballageretur manages the tasks related to producer responsibility for single-use plastic products on your behalf.

Benefits of producer responsibility

By imposing cleanup costs on affected companies, the aim is to:

• Strengthen accountability among producers: By making you financially responsible for waste management and cleanup, which can lead to changes in production and material selection. The ambition of producer responsibility is also to motivate your value chain to demand better-designed and recyclable products.
• Promote the development of sustainable solutions: Encourage you as producers to design products with fewer plastic components or to use materials that are easier to recycle.
• Reduce waste in nature: Consumers are better educated, for example, through information campaigns, and more plastic products are collected and managed properly.

The Extended Producer Responsibility for Single-Use Plastic Products is part of the EU’s broader effort to achieve a circular economy, where resources are used more efficiently, and waste is reduced. For you as producers, this means that you must actively consider the entire lifecycle of your products and take part in responsible solutions for plastic pollution.

Division of responsibilities among the actors in producer responsibility

The division of responsibilities in the Extended Producer Responsibility for Single-Use Plastic Products is structured as a collaboration between municipalities, the state, and producers (represented through PROs such as Emballageretur) to ensure efficient waste management and reduce plastic pollution.

In short, the division of responsibilities is as follows:

• Producers (represented by Emballageretur) pay and take responsibility for ensuring their products are properly managed.
• Municipalities handle the practical aspects of waste management and cleanup.
• The state regulates, monitors, and ensures that the legislation is followed.

This collaboration creates a structure where producers are motivated to reduce plastic pollution, municipalities can focus on effective cleanup, and the state ensures that all parties meet their obligations.

Selling or distributing means that your company makes the products available to other businesses or consumers in Denmark, whether for payment or free of charge.

The primary product categories and companies covered by the Extended Producer Responsibility for Single-Use Plastic Products include:

• Producers of specific single-use plastic products: This includes companies that manufacture or import single-use plastic products such as plates, cutlery, straws, cotton swabs, and stirring sticks. Additionally, products like plastic balloon holders, plastic bags (of specific types), and cups are also covered.
• Producers of beverage containers and bottles: Companies that manufacture single-use plastic bottles and containers for beverages are also included.
• Producers of food packaging: Companies that manufacture plastic packaging for food intended for single use, often used for take-out, are included. This includes packaging for items like burger boxes, sandwich wraps, and other containers that are typically discarded after one use.
• Producers of tobacco and tobacco products: Cigarette butts are a significant source of plastic pollution. Therefore, tobacco producers, especially those that manufacture plastic filters, are included. These producers may be required to finance the cleanup of cigarette butts in nature.

There is no minimis threshold or limit regarding how little plastic the covered product categories must contain to be subject to the Extended Producer Responsibility for Single-Use Plastic Products.

This means that it doesn’t matter whether the product is primarily made of plastic or another material – even a small amount of plastic can mean that the producer responsibility applies.

Since the producer responsibility for single-use plastic products and packaging is based on the Single-Use Plastics Directive and the Waste Framework Directive (and eventually the Packaging Regulation), the definitions of producers for the two responsibilities are not the same.

This means that the producer responsibility for a product may fall to one producer under the single-use plastic responsibility, while another producer may be responsible under the packaging producer responsibility.

The differences arise, among other things, because the criteria for micro-enterprises and trademarks may influence who is assigned the producer responsibility for packaging, while these criteria are not relevant for the producer responsibility for single-use plastic products.

The producer responsibility for single-use plastics differs from the Extended Producer Responsibility for Packaging in that it specifically focuses on plastic products that often end up as waste in nature, and imposes additional responsibilities on companies to prevent pollution.

While the two areas of responsibility are separate, this does not exclude the possibility that a company may be subject to both. If your products are both single-use plastics and packaging, you could be responsible under both schemes.

In short, the Extended Producer Responsibility for Single-Use Plastics is focused on the waste problems in nature and imposes stricter requirements on producers of certain plastic products, while the Extended Producer Responsibility for Packaging is broader and focuses on proper waste management and recycling of all types of packaging.

If your company is subject to the Extended Producer Responsibility for Single-Use Plastic Products, you must register with the DPA and designate your chosen PRO as Emballageretur.

Emballageretur can assist with registering your company with the authorities and ensuring that your data is correctly reported.

Contact us at info@emballageretur.dk if we should handle the registration for you. Be sure to provide us with the product categories when requesting registration.

Timeline for Registration

If you are already a producer, you must register no later than December 17th, 2024.

New producers must register at least 14 days before they begin selling or distributing single-use plastic products.

If you are already a member of Emballageretur, you will be familiar with the registration process. Please note that you have 7 days to approve Emballageretur as your chosen PRO once we have registered you with the DPA.

Remember to set up MitID Erhverv

MitID Erhverv has replaced the NemID employee signature and must be used by all businesses, associations, and authorities that have employees or users who need to log in to public self-service solutions.

Before Emballageretur takes over the management of your company’s producer responsibility, your company must confirm that we handle the Extended Producer Responsibility for Single-Use Plastic Products on your behalf as part of the registration process. The approval is done within the DPA’s systems, and to access them, your company must have MitID Erhverv.

Setting up MitID Erhverv may take some time, so we recommend that your company starts the setup process now if you haven’t already begun.

Membership with Emballageretur

If you are already a member of Emballageretur because you are covered by the Extended Producer Responsibility for Packaging, you will not receive a separate contract for handling your company’s Extended Producer Responsibility for Single-Use Plastic Products. This is because your existing contract with Emballageretur for packaging already covers any producer responsibility for single-use plastic products.

If your company is not already a member of Emballageretur, you will receive a membership contract when you choose Emballageretur to handle your Extended Producer Responsibility for Single-Use Plastic Products.

The rules for foreign companies are the same.

The first time you need to report, it will be for the quantities of single-use plastic products that you have placed on the market between January 1st and March 31st, 2025.

The actual reporting period will be from April 1st to April 10th, 2025.

Reporting from 2025 onward

Once the first report is submitted in April 2025, your company will need to report every three months.

Each time, you will need to report how much single-use plastic you have sold in the previous quarter, categorized by product type.

The reporting periods will be from the 1st to the 10th of the following months: April, July, October, and January.

Reports to the DPA will be done via Emballageretur. We will inform you on how the reporting process will work as we get closer to the dates.

We cannot say with 100% certainty what the financial framework will be for you as an individual company.

However, we do know that for each producer who joins a PRO, the costs will consist of a combination of legally required environmental contributions, collection and treatment costs for the amount of single-use plastic you place on the market, as well as administrative costs, including membership in the collective scheme.

Membership in a Collective Scheme – Emballageretur

If you are already a member of one or more of Retur’s PROs – Emballageretur, Elretur, and/or Batteriretur – it will not cost you extra to have your company’s Extended Producer Responsibility for Single-Use Plastic Products handled. This is already included as part of your membership.

This is because, as a member of one or more of Retur’s PROs, you pay 1500 DKK per year regardless of your company’s size or how many memberships you have in the Retur family.

If you are not yet a member of one of Retur’s PROs, membership will cost you 1500 DKK per year. You can register for Emballageretur by clicking here and following the instructions.

Payment to the DPA

If you only have the Extended Producer Responsibility for Single-Use Plastic Products, you must pay 1000 DKK to the DPA to register.

If you are already registered in the producer register because you are covered by another producer responsibility – for example, electronics, batteries, or packaging – you will instead need to pay a one-time fee of 500 DKK.

In addition to the one-time registration fee, your company will also need to pay a semi-annual administration fee to the DPA. The exact amount has not yet been disclosed.

Fee to the Environmental Protection Agency 

All companies that market the covered single-use plastic products must pay a fee to the Environmental Protection Agency every quarter.

The size of the fee depends on the product category and the quantities marketed, and it will be the Environmental Protection Agency that collects these fees from you.

The fee, including price and wages, is adjusted annually on January 1st. The fee must balance over a period of 4 years. This means that if too much is paid in one year, the fee will be reduced accordingly in the following years. If too little is paid, the fee will be increased in the subsequent years.

Each product category functions as a separate fee area and must therefore maintain financial balance independently of the other categories.

What does DPA say about the Extended Producer Responsibility for Single-Use Plastic Products?

• Read more on DPA’s topic page for single-use plastic products here.

We are ready to assist you by phone Monday to Friday between 9:00 AM – 3:00 PM.

Call us at +45 3336 9198
Email us at info@emballageretur.dk.
Visit our website.

As the name suggests, single-use plastic products are made entirely or partially of plastic and are intended to be used only once.

Some single-use plastic products may be subject to both the Extended Producer Responsibility for Single-Use Plastic Products and the Extended Producer Responsibility for Packaging.

Single-use plastics come in many different forms, especially in the packaging and food industries. These products typically end up as waste after brief use and constitute a significant portion of the plastic waste often seen in nature and on beaches.

This is problematic because it often ends up as waste in nature, where it can take decades or even centuries to break down. It harms wildlife and contributes to the development of microplastics, spreading in the marine environment and food chain, with unpredictable consequences for ecosystems and human health.

The EU’s Single-Use Plastics Directive specifically focuses on these types of plastic products to reduce their environmental impact.

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