[DA] Understand extended producer responsibility

From 2025, companies will be responsible for the cost and management of packaging they put on the market. This means that companies will be responsible for the collection, sorting and treatment of packaging when it becomes waste. This is done as part of EU regulations, where the ‘polluter pays’ principle is central. Companies are therefore encouraged to choose environmentally friendly packaging that can be recycled and reused.

Who is responsible?
Although it’s called “producer responsibility”, it doesn’t only apply to manufacturers. It applies to all companies that manufacture, import or sell packaging. In other words, any company that puts packaging into circulation must comply with these rules.

The purpose of producer responsibility
The aim is to reduce packaging waste and promote a circular economy. This is to be achieved by:

Avoiding unnecessary packaging
Using reusable packaging whenever possible
Recycle waste from packaging
Using recycled materials for new packaging

This promotes environmentally friendly solutions and makes it more expensive to use packaging that harms the environment.

When will the rules come into force?
Extended producer responsibility will come into force on 1 October 2025. Originally planned for 1 January 2025, it has been postponed several times.

What packaging is covered?
All types of packaging are covered, including:

Sales packaging (the primary packaging you see on the shelves)
Multipak (secondary packaging, e.g. a box with multiple units)
Transport packaging (tertiary packaging used for shipping)
Service packaging
Reusable packaging
Primary production packaging

What is private label packaging?
This is packaging designed specifically for your business, either with your logo or customised to your needs. However, if your business is very small (micro-business), you are exempt from some of the rules.

Is my company covered?
If your company has less than 10 employees and an annual turnover of less than DKK 15 million, you are exempt from producer responsibility unless you import packaging yourself.

What do I do if I have questions?
You can get help from the Danish Environmental Protection Agency or the Danish Producer Responsibility (DPA), which administers the rules. At RAJA, we are also ready to advise you on the extended producer responsibility.

Can RAJA take over the responsibility?
No, the law does not allow RAJA or other companies to take over producer responsibility on your behalf.

What does the 8 tonne limit mean?
If your company sends less than 8 tonnes of packaging to the Danish market annually, you can report fewer details, but you still need to register and pay for waste management.

What is a collective scheme?
A collective scheme is a private organisation that helps companies manage their producer responsibility. Examples of such schemes are VANA and Emballageretur.

Do I need to be enrolled in a collective scheme?
Not yet, but it is expected to become a legal requirement from 2025.

What needs to be reported by 31 August 2024?
Companies with producer responsibility must register with DPA and report their expected packaging volumes for 2024. You must report how much packaging you expect to put on the market and where it will end up as waste.

How do you keep track of all this?
It is expected that the Danish Environmental Protection Agency will monitor companies’ compliance. Your collective scheme can help you with what exactly needs to be done.

Environmentally graduated contribution
This is a financial scheme to incentivise companies to use recyclable packaging. The Danish Environmental Protection Agency sets these requirements.

What if I export packaging?
If the packaging does not become waste in Denmark, a refund is likely to be possible. This will be clarified in a later regulation.

How do I report packaging materials?
In 2024 you can report up to eight different material types (e.g. plastic, paper, glass), with more details to come after the extended producer responsibility comes into force.

What does it cost?
Prices for packaging waste management are not yet finalised, but VANA offers a price calculator for their members.

How do I get an overview of the packaging I have purchased from RAJA?
We are working on an environmental report that covers all your needs.

Summary
The extended producer responsibility means that companies that put packaging on the Danish market will be responsible for its handling from 2025. If you have customised solutions, the responsibility lies with the filler.