Articles · 2026-09-15
Export packaging: what Denmark does not ask you to report
Packaging you can document as leaving Denmark is not reported to DPA — but the receiving country's EPR applies. A reusable pallet pays nothing at all.
You pack goods in Denmark and send them abroad. Someone tells you to register with Dansk Producentansvar and report every kilogram. Someone else says export is outside it. Both are partly right, and the part they leave out is the one that costs money.
Do I report packaging that leaves Denmark?
Not if you can show it leaves. Miljøstyrelsen's own guidance says that if the first company in the chain can reasonably document that its packaged goods are sent out of the country in a later link, those quantities are not reported to DPA. The documentation can be demanded during supervision of your own internal control.
Read that twice: the relief is not automatic and it is not a claim. It is a documentation duty. If you cannot show which shipments left, you report them.
Then who reports them?
The receiving country does, under its own rules. Kilograms that leave Denmark do not disappear — they turn into a German, French or Dutch obligation, with a different register, a different unit of counting and a different deadline. Our country table sets the 27 side by side.
So a Danish exporter has two jobs that look like one: prove what left, and declare it where it landed.
What about the pallet under the goods?
This is the part almost nobody writes down. A company that first makes reusable pallets available in Denmark — a Europallet designed for reuse and sold on to others who reuse it — pays no collective-scheme contribution for its waste handling.
But the duty does not vanish. The seller must take the pallet back when it is no longer being reused, and handle its waste itself.
That is a very different economic answer from the one most summaries give, and it applies exactly to the firms that ship on pallets and crates rather than in parcels.
What if I unpack imported goods?
From 12 August 2026 the unpacker rule applies. A Danish company that unpacks imported packaging before the product reaches the end user carries the producer responsibility for that packaging. If you buy in from abroad and strip the transport packaging in your own yard, that packaging became yours.
The Commission's own guidance adds the other half: responsibility for sales and grouped packaging sits with the company that fills it or has it filled, whatever name or trademark is printed on it.
Is the threshold 8 tonnes or 10?
Both figures are in circulation, and the register confirms neither.
8 tonnes is what Miljøstyrelsen's FAQ still states today, together with the plain warning that it is not an exemption — below it the reporting is simpler, but registration and payment remain.
10 tonnes is what DAKOFA reports from the environment minister's answer to the Folketing: the de minimis is fully harmonised across the EU by the packaging regulation from 12 August 2026. Dansk Erhverv says the same. Beierholm states both and adds the detail that settles nothing and explains everything — the Ministry of Environment has not announced the change.
We publish both, marked unconfirmed, because that is the honest state of it. Either way the number decides how much detail you report, not whether you are in.
When do I register, and when do I report?
Registration must be made at least 14 days before you begin making packaging available, and it is complete only once the fee is paid and the certificate issued.
The 2026 quantities go into the DPA register between 1 January and 31 May 2027, in most cases through your collective scheme. And 2026 is split in two: 1 January to 11 August under the old rules, from 12 August under the new definitions. One year, two rulebooks, one report.
What a spreadsheet cannot do here
A spreadsheet will add up kilograms. It will not know which of those kilograms left the country, or hold the delivery note that proves it. It will not remember that the pallet under shipment 4471 was a Europallet and the one under 4472 was a one-way pallet, which is the difference between paying and not paying. It will not tell you, a year later, whether a weight was measured or estimated, or keep the split at 11 August so the two halves of 2026 stay apart.
None of that is the spreadsheet's fault. It is a tool without a memory, and Danish export packaging is a question about which shipment, not about a total.
What Tarafex does about it
One row per component, with the weight frozen on the shipment line the day you ship, so a figure in a report still matches the document behind it a year later. Kilograms per country, taken from the shipments you already recorded — which is the same data that shows what left Denmark and what stayed. The recycled share on a weight basis, with the component nobody answered named rather than counted as zero. Supplier answers through a link with no account and no password, kept with a name and a date on them.
What it does not do: it does not register you, it does not calculate the money, it does not file anything with DPA, and it will not tick a box you have not answered. Where the law itself is unsettled — as with 8 against 10 tonnes — the page says so and names both sources, instead of picking the one that sounds tidier.
Denmark and Latvia are the current country pages under review.
Sources: Tarafex country table; Denmark: DPA, Miljøstyrelsen, Miljøstyrelsen: genbrugsemballage, Folketinget, DAKOFA, Dansk Erhverv, Beierholm; Commission PPWR FAQ. Checked 15 September 2026. This is information, not legal advice.