Find answers to frequently asked questions about producer responsibility for packaging, packaging design, waste management and membership of VANA in the overview below - then you are well prepared to live up to your producer responsibility from July 2025.
About the producer responsibility
The purpose of introducing extended producer responsibility for packaging in Denmark is to promote a circular economy where:
- no unnecessary packaging is used
- greater use is made of reusable packaging
- real recycling of packaging waste is taking place
- recycled materials are used to make new packaging
- It is significantly more expensive to use environmentally harmful packaging compared to environmentally friendly packaging
- The solutions are cost-effective.
This is done by incentivising companies to produce more environmentally friendly packaging by placing responsibility for this at the stage of the value chain that has the greatest influence on packaging design – also known as the polluter-pays principle.
The general rule is that the responsible manufacturer is the "filler" or "importer" who markets or makes filled packaging accessible in Denmark.
Examples of manufacturers are (cf. model below): a private label owner, a product manufacturer, an importer and, in the case of foreign e-commerce, "an authorised representative".
Read more and find an overviw here.
However, the companies should be aware of that even if you are not responsible for a product in the primary packaging, you may well be responsible for putting secondary and tertiary (transport) packaging on the market. Read more about packaging types here.
In relation to the registration obligations (the first registration takes place March 2024), it is a good idea already now to check which packaging your company puts on the market - what materials are the packaging made of and how much do they weigh?
Read more abouot the requirements for registration here.
Review your packaging now and see where it can be improved environmentally or minimized. You can read more about the possibilities to prepare. Read more about the option for preparation here.
At this stage, we know the overall framework for reporting for 2024, but not what it will look like from July 2025 and onwards.
The reporting for 2024 should be seen as a kind of "baseline", where the sector needs some data to allocate the waste volumes for treatment for 2025. Therefore, reporting will most likely look different in 2025.
Reporting must initially be made in kilograms for the quantities of commercial packaging and household packaging placed on the market. In addition, it must be stated whether the packaging should be sorted as residual waste or hazardous waste.
Read more about reporting and registration here.
If your company is a member of VANA, we will guide you in your reporting to DPÅ. Read more about VANA membership here.
As a manufacturer, you will be responsible for the costs of:
- Waste treatment, which includes collection, sorting and recycling.
- An environmentally graduated contribution (based on packaging composition and content) which should encourage improved packaging design.
- An administrative contribution to the operation of the Producer Responsibility Organisation (PRO) that handles the producer responsibility on your behalf.
The municipalities will, as they do today, be responsible for collecting the waste. When producer responsibility comes into force in July 2025, municipalities will be compensated by producers (via the Producer Responsibility Organisation (PRO)) for the costs of collection.
Thereafter, the PRO will assume legal, financial, and practical responsibility for the waste and its further treatment on behalf of their members.
Since part of the waste will be non-packaging, municipalities must compensate the Production Responsibility Organisation (PRO) for the proportion of waste that is non-packaging. This part still must be paid through municipal waste fees. However, it is the PRO that will ensure the further management of both packaging waste and non-packaging waste and put this out to tender.
No. Waste producing companies only have to pay for the handling of non-packaging waste. The manufacturer must pay for the part that is packaging.
A packaging is registered in the producer responsibility by the company that first makes it available on the Danish market, with business as end user (producer). When the packaging becomes commercial waste, it is collected, e.g., by a private waste collector, who is compensated by the PRO (Producer Responsible Organisation).
All companies in Denmark that generate waste and therefore need to dispose of it, e.g. by entering into an agreement with a private waste collector, are waste producing companies.
Companies who put less than 8 tonnes of packaging on the Danish market annually will have to report less information on their packaging and face fewer administrative burdens.
This does NOT mean that you are exempted from the producer responsibility scheme, either in an organisational, legal, or financial way.
They will continue to pay for the costs associated with the collection and treatment of packaging similar to what they put on the market but will not be obliged to report data based on the environmentally graduated contributions.
From July 2025, all companies that put packaging on the Danish market will be responsible for financing and organising the collection, sorting and treatment of their packaging when it becomes waste.
It will be a large and complex task for the individual company, and most manufacturers therefore choose in practice to solve the task through a Producer Responsibility Organisation (PRO) such as VANA.
Producer responsibility for packaging is laid down in the EU directive for packaging and packaging waste, §7 (94/62/EC).
The short answer is: all packaging is covered, i.e.:
- Sales packaging (primary packaging)
- multipack (secondary packaging)
- transport packaging (tertiary packaging).
The extended producer responsibility for packaging will enter into force on 1 July 2025. But already in April 2024 affected companies must have registered with Dansk Producentansvar (DPA) (Danish Producer Responsibility) and report expected packaging quantities for 2024.
The 2024 figures are thus considered a kind of "baseline" for the producer responsibility in the start-up year 2025. DPA allocates waste volumes to the Producer Responsibility Organisations (PROs) for 2025 based on the companies' reported expected volumes for 2024. Therefore, it is also important to join the Producer Responsibility Organisation (PRO) VANA now, so that we can achieve the best economies of scale on behalf of our members.
The EU directive on packaging and packaging waste sets a broad overall framework for the member states: It is up to the individual member states how the legislation will be implemented in practice. This means that there are national differences in producer responsibility legislation for packaging across Europe.
If your company puts packaging on the market in countries other than Denmark, you must comply with the respective countries' rules for their producer responsibility on packaging.
In the upcoming packaging regulation from the EU, which is on the way, the stage is set for harmonising the rules across Europe, making it easier for companies to live up to the producer responsibility across Europe.
Read more about the legislation here.
The eco-graduated contributions are an economic structure to ensure increased incentives for companies to produce/have packaging produced that is recyclable or recyclable.
The criteria for the environmentally graduated contributions are determined by the Danish state in consultation with industry and the trade industry and are currently not defined. These criteria will follow with part 3 of the executive order.
Find more information about legislation and status here.
It is expected that emphasis will be placed on, among other things, material minimisation, recyclability, the amount of recycled material in packaging and the presence of hazardous substances.
Learn more about the financial consequences here.
Private waste collectors will, as they do today, collect waste from businesses and be responsible for further treatment.
The producers will (via the Producer Responsibility Organisation (PRO)) compensate the private collectors for the proportion of the waste which is packaging.
The Environmental Protection Act, which sets the framework for the producer responsibility, does not apply to the Faroe Islands and Greenland. Therefore, it is only the packaging that you make available on the Danish market that you must report.
With the implementation of the producer responsibility comes an obligation to provide information on the correct handling of packaging and packaging waste and avoid littering (duty of disclosure).
The political agreement stipulates that this obligation will be fulfilled by the state at the expense of the companies. Based on the draft of Environmental Protection Act, it is therefore expected that the obligation will lie with the municipalities and the Environmental Protection Agency. The executive order to implement this is scheduled for May 2024.
About VANA and Producer Responsibility Organisations (PROs)
A Producer Responsibility Organisation (PRO) is a private company that offers companies subject to the producer responsibility to handle the administrative and practical tasks associated with the producer responsibility for packaging on their behalf.
However, it is still the producer responsible company which is responsible for collecting data on its own packaging and registering these with the PRO.
The PRO VANA will, on behalf of producers and importers, handle the legal, financial, and practical responsibility for collecting, sorting, and recycling packaging. This ensures economies of scale and thereby better economics of commitments. The more members a PRO has, the larger the (waste) packaging volumes are accrued to the PRO the better the tenders can thus be made.
As a Producer Responsibility Organisation (PRO), VANA will assume the statutory producer responsibility on behalf of the covered companies that have joined the scheme - legally, financially and practically.
At VANA we see it as our task to make it as simple and straightforward to comply with the producer responsibility as possible, e.g., by developing an easy and clear reporting system for our members, so that you only must deal with reporting data in one place.
The short answer is no. However, if you choose not to be a member of a Producer Responsibility Organisation (PRO), you will have to pay for the collection and treatment of the packaging you put on the market from July 2025. In practice, it can be almost impossible (and financially very expensive) to live up to your obligations in the producer responsibility if you are outside a PRO.
If you put more than 8 tonnes of packaging on the market per year, and thus is above the so-called minimum limit, you must be registered in a PRO, unless you can prove that you collect and treat packaging waste yourself similar to what you put on the market.
If you are below the minimum limit of 8 tonnes, you can still benefit from being a member of VANA and get help and sparring with how live up to your obligations in the producer responsibility - but you do not have to be part of a PRO.
VANA ensures economies of scale
The more companies that join the PRO, the better economy can be created in the system. The larger (waste) packaging quantities which are allocated to VANA based on our members' reported packaging quantities, the better tenders we can make. This way we can ensure economies of scale and better finances for all our members.
A membership of VANA gives access to advice and sparring with our consultants, all knowledge content on the website (marked with a padlock) and webinars only for members of VANA with the latest and updated knowledge about the producer responsibility for packaging.
Membership of VANA is free and non-binding until April 2024, when registration with DPA starts up.
A take-back scheme means that producers have the opportunity to organise taking back their packaging and to recycle it - either in their own production or at another private handler. This can, for example, be as deposit schemes, but in the long term can also be organised through Producer Responsibility Organisation (PRO) such as VANA.
The four largest Danish business organisations in Denmark, the Danish Agriculture & Food Council (Landbrug & Fødevarer), the Danish Chamber of Commerce ( Dansk Erhverv), DagSam (Association of MLDK and the Federation of Retail Grocers Samvirkende Købmænd) and the Confederation of Danish Industry (Dansk Industri), founded VANA in 2021 with the aim of lifting the practical and legal responsibility for the companies that will be covered by the extended producer responsibility on packaging.
With the support of the four founders, VANA is broadly based in the Danish business community and has a solid political foundation. Thereby we represent 80% of Danish companies and cover all industries.
About packaging and design
The national recommendations and guidelines on which the eco-graduated contributions will be based have not yet been established. So far, reference is made to the recommendations prepared by Danish and foreign trade associations.
Eco-friendly packaging is packaging such as:
- is material minimised
- are made of a single material (if possible)
- is easy to sort the source – possibly take apart
- can effectively be fed into the recycling process
- retains high value as secondary raw material
- is reusable packaging.
To make your business as ready as possible, it is important to keep track of what packaging you have - in other words, what components and materials the packaging consists of.
Reuse of packaging will be supported in the future system by manufacturers using reusable packaging only having to pay once for the packaging’s circulation on the market. For example, if reusable packaging can be circulated 30 times before it is discarded, the fee is paid only once, instead of the 30 times which would have had to been paid for using single-use packaging.
The specific regulation of recycling solutions is not yet in place, but it is a political wish to ensure a flexible framework for manufacturers with new packaging solutions, e.g., recycling and return systems.
NOTE: Reusable packaging is not included in the reporting of packaging quantities for 2024, but must not be registered until 2025.
In this executive order, service packaging also means beverage containers and drinking cups which are disposable plastic products and which are sold empty and are not designed and intended to be filled at the point of sale (from the draft executive order on registration and reporting).
Packaging that has been conceived, designed and placed on the market in order to undergo a number of trips or cycles during its lifetime by being refilled or reused for the same purpose for which it was conceived (as defined in the Executive Order on Certain Requirements for Packaging).