EPR in Denmark from 2025: current changes at a glance
Since 1 July 2022, you must also comply with the guidelines that apply to online trading under the EPR on electronic marketplaces. This has also been the case for Amazon since the deadline. The e-commerce platform is subject to the statutory inspection obligation and is obliged to check manufacturers, sellers and retailers to ensure that they have the corresponding LUCID packaging register numbers in the context of the EPR in online retail and are participating in a system. There is also an obligation to report packaging quantities to both the registered system and the LUCID Packaging Register. If this is not the case, manufacturers must expect fines or even a distribution ban. eBay followed suit on 1 July 2023.
What do you need to look out for with the EPR in online retail, when are you subject to system participation and what obligations do you have in addition to the packaging guidelines with regard to electronic and electrotechnical devices and batteries? We have taken a closer look at this for you.
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The EPR in Denmark will come into force on 1 January 2025. The extended producer responsibility has been gradually introduced since 2023. There is an obligation to report the planned consumption of packaging by 30 September 2024 at the latest. In addition, from 1 July 2025, the proportion of recycled material and the quantity of each individual type of material that is generated as waste in private households or commercial businesses must be reported. Every company that introduces packaging into the circular economy in Denmark for the first time must register in the Danish Producer Register (DPA) as part of the EPR in Denmark. This includes Danish manufacturers and fillers as well as importers and foreign online retailers. Companies that are not established in the country, sell their goods to Danish private customers and do not have a Danish VAT identification number (CVR number) comply with the provisions of the EPR in Denmark by means of an authorised representative. Are you unsure whether you are required to register and report? Please contact Deutsche Recycling GmbH for comprehensive advice on the EPR in Denmark.
The aim of the EPR in Denmark
The EPR in Denmark, as in all other EU countries, is intended to help support the recycling and reuse of packaging and the materials used, reduce consumption and conserve important resources. The more sustainable approach strengthens environmental goals and makes companies jointly responsible.
The EPR in Denmark is based on the revision of the statutory minimum requirements of the Packaging Ordinance.
EPR in Denmark: producer responsibility, mandatory reporting and registration
The laws on EPR in Denmark apply to every company that places packaging on the Danish market for the first time. This includes manufacturers established in Denmark as well as bottlers, but also importers and foreign online retailers. Manufacturers are defined as all natural or legal persons who fill or have products filled under their own brand and market them in packaging.
As an obligated company for the EPR in Denmark, you must report your planned packaging consumption by 30 September 2024 at the latest. This initially only applies to the year 2024, but from 1 July 2025 there will also be an obligation to report the recycled content and the expected quantity of each individual type of material.
In order to fulfil the EPR in Denmark as an obligated company, registration in the Danish Producer Register (Dansk Producentansvar – DPA) is required. The DPA manages the national producer responsibility for electrical appliances, batteries, vehicles, packaging and single-use plastic parts. The producer responsibility systems are implemented and monitored via the digital and legal register.
A prerequisite for registration under the EPR in Denmark is the CVR number, the most important contact information and, if applicable, information on membership of a collective system. If you do not have a Danish VAT number, you can appoint an authorised representative in Denmark.
How you can register in the context of the EPR in Denmark and what costs are involved
You can register online for the EPR in Denmark on the DPA website. In addition to the documents mentioned above, you must select the correct material from the categories (electronics, batteries, vehicles, single-use plastics and packaging) and the type (primary, secondary, tertiary or service packaging) that you are placing on the market as packaging. Here you will also find information on what exactly is covered in the category. You then assign the estimated quantity in kilograms for the entire year 2024 to each selection. After confirmation, all you need to do is sign the form. Finally, before you are registered for the EPR in Denmark, you must pay the one-off registration fee and wait for authorisation. The registration fee is around DKK 1,000.00 (about 134€). If you are already registered, you can extend the areas for DKK 500.00 (about 67€).
The volume-based packaging fees within a calendar year of the EPR in Denmark are regularly recalculated and approved by the Minister of the Environment. They are published on the DPA website.
EPR in Denmark: Labelling and disposal obligation
Each company has the choice of taking over the EPR in Denmark on its own or joining a collective programme or concluding an agreement with a take-back & recycling system. As with electronics or batteries, for example, these take over the professional disposal, sorting and recycling, as well as the legal responsibility. This fulfils the disposal obligation.
In addition, there is an obligation to inform consumers within the framework of the EPR in Denmark. This primarily includes specific information on how packaging must be disposed of. The requirements are set out in Annex 4 of the Packaging Ordinance. You can use universally valid pictograms that everyone can understand (e.g. for batteries: crossed-out container symbol with wheels), which are stored in the Danish pictogram system. These are used to label products that must be disposed of separately for reuse or recycling, such as batteries and electrical or electronic devices. In addition, standard texts drawn up by the Danish Environmental Protection Agency concretise the instructions.
Small quantity regulation at the EPR in Denmark
If you put less than 8 tonnes of packaging into circulation per year, you fall under the EPR’s small quantity regulation in Denmark. This means that you have to carry a small volume. Your reporting obligation for less than 8 tonnes of packaging per year consists solely of reporting the total amount of packaging placed on the market. For example, you do not have to break down the packaging quantities by packaging type or material.
Tackling EPR in Denmark with professional support
We at Deutsche Recycling GmbH are your experts for EPR in Denmark and environmental compliance. We are happy to carry out compliance checks on request and support you in meeting the regulations of the EU member states. We provide you with professional, personalised and individual support for EPR in Denmark.
