FAQ - Covered companies
There is a difference in the definition of producer (which company is included), depending on whether it is about producer responsibility for packaging or producer responsibility for single-use plastic products (clean up responsibility).
Read more here: Included companies
The authorities have indicated that it is not possible to transfer producer responsibility between companies.
Although the producer responsibility itself, and hence the reporting obligation, cannot be transferred, according to the authorities, it will be possible for companies to enter into private agreements regarding the distribution of costs.
Additionally, Dansk Producentansvar provides information about various options for linking a person from another company to one's own company.
Particularly for groups, chain offices, and other business structures;
Here, the authorities have confirmed in guidance that responsibility can be placed centrally.
Particularly for EU companies:
EU companies must, according to Dansk Producentansvar, use an authorised representative.
Companies that employ fewer than 10 people and have an annual turnover, understood as the amount earned in a specific period, or an annual balance, understood as a summary of the company's assets and liabilities, that does not exceed 15 million DKK.
The Environmental Protection Agency uses the European Commission's recommendation of May 6, 2003, as guidance for the concept of micro-enterprise: § 3, paragraph 1. No. 28): Micro-enterprise: Any natural or legal person that employs fewer than ten people and has an annual turnover, understood as the amount earned in a specific period, or an annual balance, understood as a summary of the company's assets and liabilities, that does not exceed 15 million DKK.
A micro-enterprise may choose to comply with either the turnover threshold or the annual balance threshold.
The Environmental Protection Agency's guidance describes how a company can determine the three criteria mentioned above: Calculation of the number of employees and annual turnover/annual balance.
Commission Recommendation 2003/361/EC, Article 5:
The number of employed is equal to the number of annual work units (ÅAE), i.e., the number of persons who have worked full-time in the respective business or on behalf of this business throughout the entire year.
Work performed by persons who have not worked the entire year, or who have worked part-time, regardless of its duration, or seasonal workers counts as fractions of ÅAE.
Included in the employed are:
a) wage earners
b) persons working for the company, who are subordinate to this and are equated with wage earners in national law
c) active business owners
d) partners who regularly work in the business and benefit from financial advantages from the company's side.
Apprentices and students under vocational training, who have entered into an apprenticeship contract or a vocational training contract, are not included in the number of employed. Maternity leave and parental leave are not included.
Yes, there is a triviality limit for each of the two main types of packaging. That is to say, a triviality limit for one-way packaging of 8 tons and a triviality limit for reusable packaging of 8 tons.
Companies that make available less than 8 tons of packaging on the Danish market annually can choose to report fewer details about their packaging and are therefore subject to fewer administrative burdens.
This does not mean that they are exempt from producer responsibility.
The company must still be registered and report packaging quantities, just as they must pay for costs associated with the collection and treatment of packaging, corresponding to what they make available on the market.
Free-riders are companies that are covered by producer responsibility without being registered in the producer register with DPA. Find more information about free-riders and the reporting function with Dansk Producentansvar (DPA).
To address the challenges with free-riders, the Environmental Protection Agency, as part of their supervision, has, among other things, an anonymous whistleblower scheme where it's possible to report violations of the producer responsibility via DPA - find it here: