{"id":4597,"date":"2026-02-13T12:22:00","date_gmt":"2026-02-13T12:22:00","guid":{"rendered":"https:\/\/emballageretur.dk\/?p=4597"},"modified":"2026-02-19T12:29:39","modified_gmt":"2026-02-19T12:29:39","slug":"consultation-response-february-2026-the-implementation-of-the-packaging-and-packaging-waste-regulation-requires-clarity-predictability-and-administrative-realism","status":"publish","type":"post","link":"https:\/\/emballageretur.dk\/en\/consultation-response-february-2026-the-implementation-of-the-packaging-and-packaging-waste-regulation-requires-clarity-predictability-and-administrative-realism\/","title":{"rendered":"Consultation Response February 2026: The Implementation of the Packaging and Packaging Waste Regulation Requires Clarity, Predictability and Administrative Realism"},"content":{"rendered":"[vc_row el_class=”container big” el_id=”blog-hdr” css=”.vc_custom_1757599587947{background-image: url(https:\/\/emballageretur.dk\/wp-content\/uploads\/2025\/09\/Billede2.jpg?id=3654) !important;}”][vc_column][vc_row_inner equal_height=”yes” content_placement=”middle” el_class=”wrapper”][vc_column_inner animation_in_type=”transition.slideUpBigIn” animation_in_offset=”100″ animation_in_duration=”500″ animation_in_delay=”0″][vc_custom_heading text=”Consultation Response February 2026: The Implementation of the Packaging and Packaging Waste Regulation Requires Clarity, Predictability and Administrative Realism” font_container=”tag:h1|text_align:center” use_theme_fonts=”yes”][\/vc_column_inner][\/vc_row_inner][\/vc_column][\/vc_row][vc_row el_class=”container” el_id=”blog-content”][vc_column][vc_row_inner el_class=”wrapper”][vc_column_inner][vc_custom_heading text=”Consultation Reponse” font_container=”tag:p|text_align:left” use_theme_fonts=”yes” el_class=”label”][vc_custom_heading source=”post_title” use_theme_fonts=”yes”][vc_column_text]Date: February 13th 2026<\/em><\/p>\n

Emballageretur has submitted a consultation response to the Ministry of Environment and Gender Equality\u2019s draft act on the implementation of the EU\u2019s Packaging and Packaging Waste Regulation (PPWR).<\/h4>\n

At Emballageretur, we acknowledge the need to adapt Danish legislation to the new EU rules. However, the implementation must take place in a way that is predictable, administratively simple and practice-oriented, otherwise both companies and producer responsibility organisations risk facing significant uncertainty shortly before the entry into force in August 2026.<\/p>\n

Below you will find the key points of our consultation response.<\/p>\n

You can read the full consultation response here.<\/a><\/p>\n

Timely clarification is crucial<\/h3>\n

Experience from previous producer responsibility schemes shows that late clarification creates unnecessary uncertainty and increases the risk of errors and lack of compliance. Companies must be able to budget, set prices and adapt systems and contracts well in advance.<\/p>\n

We therefore strongly encourage that executive orders and guidance are available well in advance of August 2026.<\/p>\n

Definitions can shift responsibility and financial obligations<\/h3>\n

When Danish definitions are replaced by those of the Regulation, even minor changes can have major practical consequences. In particular, changes to the end user definition and the application of the so-called unpacking rule may shift producer responsibility and payment obligations between actors.<\/p>\n

There is a need for practice-oriented guidance with concrete examples, so that companies know where responsibility is in fact placed.<\/p>\n

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The compensation model for commercial packaging should be reconsidered<\/h3>\n

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.<\/p>\n

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.<\/p>\n

Producer fees and transparency<\/h3>\n

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.<\/p>\n

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.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n

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Clarity regarding the approval of producer responsibility organisations<\/h3>\n

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.<\/p>\n

The framework should be communicated clearly and in a timely manner, so that the implementation can take place efficiently and uniformly from day one.<\/p>\n

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.<\/p>\n<\/div>\n

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Additional measures that can strengthen enforcement and practical operation<\/h3>\n

Emballageretur also points to three specific elements that can make producer responsibility more enforceable and easier to operate in practice:<\/p>\n