Denmark
Extended Producer Responsibility for Packaging in Denmark
According to Danish law, starting from April 1, 2024, all manufacturers, importers and traders must register for the EPR rules in Denmark. The approved rules may be subject to change over the next year, so companies should monitor the latest information.Who must register for Packing EPR in Denmark
Based on the EPR rules in Denmark, every company that supplies packaging to the Danish market for the first time must register in the recycling system, namely:- manufacturers;
- distributors;
- traders;
- importers;
- and other related categories that supply packaging to the Danish market.
What is included in Packaging
The Danish Packaging Act defines the following packaging categories:- Cardboard
- Paper
- Metal (ferrous)
- Aluminum
- Glas
- Plastics
- Food and drink carton
- Wood
Thresholds
There are no thresholds for registration. Every company that sells packaging has to register and report on the amount of waste it produces.Registration procedure
The procedure for registration in Denmark for EPR packaging consists of the following steps.- Joining to Producer Responsibility Organization (PRO);
- Appointment of an Authorized Representative for your company. (Mandatory for all companies located outside Denmark);
- Registration with the Ministry – Dansk Producentansvar;
- Conclusion and signing of cooperation contracts;
- Obtaining certificates of conformity and further compliance with the rules.
Authorized representative
All companies that do not have a registered address in Denmark are required to appoint a representative who will be jointly and severally liable for further compliance with the EPR rules.Reporting Deadline
31 August 2024 – is the deadline for submission of the first EPR report on Packaging.-
Danish manufacturers or packers are fully responsible for their packaging from the moment the product is first placed on the Danish market.
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Importers and distributors assume full liability at customs clearance—unless the packaging has already been licensed upstream.
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Foreign distance sellers become liable (through an authorised representative) when they make a direct B2C sale to a Danish consumer.
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Collective schemes take on the operational tasks of collection and recycling.
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Miljøstyrelsen / the Danish Producer Responsibility authority (DPA) handle enforcement and registry functions, including audits and fines.
Duties of each responsible party
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Producers and importers must:
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Register with the DPA.
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Join an approved collective scheme.
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Pay the requisite fees.
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File annual weight reports.
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Keep the necessary records.
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Authorised representatives must:
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Hold a Danish CVR number.
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Sign a contract with a collective scheme.
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Submit or confirm the producer’s reports.
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Receive all official correspondence.
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Collective schemes are obliged to:
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Meet Denmark’s material-specific recycling targets.
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Invoice their members and audit the reported data.
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Forward compliance results to the DPA.
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Miljøstyrelsen / DPA:
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Maintain the national producer register.
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Publish lists of compliant producers.
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Impose fines of up to DKK 500 000 for non-compliance.
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