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Packaging EPR in Denmark
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Checked 2026-09-16 · 13 sources · 4 open questions
- Register
- Producentansvarsregistret (DPA)
- Authority
- Dansk Producentansvar (DPA); supervision Miljøstyrelsen
- Law
- BEK nr. 1146 af 29/09/2025 om udvidet producentansvar for emballagepackaging EPR took effect in Denmark on 1 Oct 2025. From 12 Aug 2026 packaging counts as made 'under own name or trademark' even with no mark on it — what decides is who ORDERS the packaging or the packed product. Matters for contract manufacturing. 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. From 12 Aug 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. The Commission guidance also places responsibility for sales and multipack packaging on the company that fills it or has it filled, whatever name is on it. Designing or making packaging for another company is not itself a first making-available. Quantities the first company can document as leaving the country in a later link are not reported to DPA. And a reusable pallet designed for reuse — a Europallet sold on to others who reuse it — carries no collective-scheme payment, but the seller must take it back and handle its waste at end of life. Membership of a collective scheme is a legal requirement for single-use packaging — from 1 January 2025, according to DPA's own guidance — and it applies below 8 tonnes as well: the environment minister told the Folketing that such companies must register like every other producer and, for single-use packaging, also belong to a collective scheme (reported by DAKOFA). A company responsible only for reusable packaging is not required to join a scheme. It must still register the reusable packaging with DPA, report by 1 June, pay the administration fees to DPA and Miljøstyrelsen, and pay for treating the reusable packaging it takes back once it can no longer be reused.
- Who registers
- Whoever first places packaging on that market, foreign sellers included
- Threshold
- 8 t a yearNOT an exemption — the ministry says so itself: below it the reporting is simpler, registration and payment still apply. Whether the figure is still 8 t from 12 Aug 2026 is unsettled; see the open question.
- Authorised representative
- Mandatory for a producer established abroadbemyndiget repræsentant (BR) established in Denmark
- Reporting
- Annually, by 1 Junereporting window opens 1 Jan for the previous calendar year; quantities split into household and commercial packaging. For 2026 the year splits in two: 1 Jan–11 Aug under the old rules, from 12 Aug under the new definitions. The 2026 quantities go into the DPA register between 1 January and 31 May 2027, in most cases through the collective scheme.
- Household packaging schemes
- ERP Denmark (by the Landbell group), VANA – Dansk Emballageansvar, Emballageretur
- Industrial packaging schemes
- No separate scheme: the same collective schemes cover commercial packaging as well as household packaging, and an approved scheme must handle every material fraction.
What is not settled
- Authorised representative Not established at sourceThat an EU-established producer must appoint a Danish representative is stated by a scheme operator, not by the register or the ministry.
- Threshold Sources disagreeTwo figures are in circulation and the register confirms neither. Miljøstyrelsen's own FAQ still states 8 tonnes today. DAKOFA, reporting the environment minister's answer to the Folketing, states that the de minimis is fully harmonised to 10 tonnes across the EU by the packaging regulation from 12 August 2026; Dansk Erhverv says the same. Beierholm states both figures and adds that the Ministry of Environment has not announced the change. Either way the figure decides how much detail is reported — not whether you register, pay, or need a representative.
- Reporting Sources disagreeHow often you report depends on whom you report to, and the sources do not agree on what is law. To DPA it is once a year, before 1 June (Miljøstyrelsen). To the collective scheme, Emballageretur describes totals every quarter below 8 tonnes and figures by material every month above, and Beierholm says monthly or quarterly depending on volume; ERP Denmark, itself a scheme, reports quarterly on some of its membership plans and once a year on another. Whether that monthly or quarterly rhythm is a legal requirement or the scheme's own arrangement is not settled by any source we have read.
- Authorised representative Sources disagreeThe authorised-representative duty is under review. On 10 December 2025 the Commission published COM(2025) 982, part of the Omnibus VIII environmental simplification package, whose Article 2 would suspend Art. 45(3) until 1 January 2035; COM(2025) 983 proposes the same for the Single-Use Plastics Directive. The suspension as drafted covers producers ESTABLISHED IN THE UNION selling cross-border directly to end users. Producers established in third countries are not covered — member states may still require a representative or ensure traceability by other means. European Parliament committee reports of May 2026 would narrow the relief to micro and small enterprises. PROPOSAL, AND NOW LARGELY STOPPED: on 24 June 2026 the Council decided not to proceed with the suspension, opposed by a large majority of member states. A Parliament committee vote is expected around October 2026, and even the Parliament's narrower approach would keep the framework for producers outside the EU. Article 45(3) applies as written today, and for a producer established in a third country nothing in this proposal ever applied.
The same in every EU country
- PPWR Art. 44 — registration is a precondition for placing packaging on that market
- PPWR Art. 45(3) — a producer under Art. 3(1)(15)(c)/(d), i.e. one making packaging available in another Member State DIRECTLY TO END USERS, must appoint an authorised representative there. From 12 Aug 2026.
- set nationally, Art. 68; national rules due by 12 Feb 2027
- Art. 44(14) implementing act still pending; central EU register not before 1 Jan 2029
Sources
Countries with the same answer
We do not register you, we are not your authorised representative, and we do not pay a scheme. This is public information gathered in one place and checked on the date shown. Confirm with the national authority before acting.
Tarafex
The number these registers ask for is kilograms by material for one year of deliveries. If your shipments are recorded as they go out, that number already exists.
See what Tarafex does →
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