FAQ - Packaging and Packaging Waste Regulation (PPWR)

The Packaging and Packaging Waste Regulation (PPWR) replaces the current packaging directive and is, in principle, directly applicable in all EU member states. The PPWR sets requirements for the entire life cycle of packaging and regulates prevention, design, reuse, recycling and the framework for the extended producer responsibility EPR.

Read more about the Packaging and Packaging Waste Regulation

The Packaging and Packaging Waste Regulation entered into force on 11 February 2025 and was implemented on the 12th of August 2026. Not all requirements enter into force at the same time. From August 2026, the following apply:

• Definitions (including for producer, manufacturer, end-user, etc.) cf. Article 3

• Certain requirements for substances in packaging, including limits for PFAS in food packaging cf. Article 5

• Requirements for technical documentation and declarations of conformity regarding compliance with the sustainability requirements cf. Articles 15–19

• Obligations regarding reusable packaging in reuse systems cf. Articles 11, 26, 27 and Annex VI

• Obligations regarding refilling in HORECA cf. Article 28

Read more about the Packaging and Packaging Waste Regulation

The Packaging and Packaging Waste Regulation regulates the entire life cycle of packaging and therefore places requirements on all actors in the value chain. As a producer, you may therefore be affected differently depending on whether you are an importer, distributor, manufacturer or final distributor (point of sale).

As regards the extended producer responsibility EPR for packaging, the biggest change is the harmonisation of definitions, including the definition of availability, producer, manufacturer and end user.

Read more about the changes of definitions in VANA guide to PPWR: How to get started here (for members; login required)

View the VANA webinar's on the Packaging and Packaging Waste Regulation for further information on this. There is also a specific webinar about definitions and roles (Danish and for members; login required).

With the packaging regulation, the definition of producer and end user changes from the Danish legislation applicable before August 12 in particularly two areas: the unpacker rule and the new end user definition, which shifts focus from packaging to the packaged product.

Before August 12, 2026

Companies that today import packaged products in transport packaging, which they unpack in Denmark, generally do not have producer responsibility for the transport packaging. In that situation, the responsibility currently lies with the foreign supplier, because the assessment follows the packaging. This will change with the regulation.

After August 12, 2026

From now on, the assessment will more closely follow the packaged product. If the foreign supplier does not sell directly to an end user of the product in Denmark, the supplier will generally not incur producer responsibility for the transport packaging. Instead, the responsibility can be placed on the Danish company that imports and unpacks the product. This is due to the so-called unpacker rule, where the company that unpacks the packaging can take responsibility if no other company has producer responsibility for the packaging.

Read more about the significance of the change in the producer definition in VANA's guide to PPWR: how to get started, here (for memebers, requires login).

See VANA webinars on PPWR here for more information on this (in Danish, for members, requires login).

The authorities have updated what applies regarding packaging with and without a trademark after August 12 on their website under typical questions and answers with the following:

The producer responsibility for packaging and packaged products is placed on the company that manufactures or has manufactured packaging or a packaged product under its own name or trademark, unless it concerns a micro-enterprise (see the question “Do micro-enterprises have producer responsibility?”).

Understanding until August 12, 2026:

Packaging is only considered to be manufactured under its own name or trademark if the company’s name or trademark is affixed to the packaging.

Understanding from August 12, 2026:

Packaging and packaged products can be considered to be manufactured under its own name or trademark, even if the packaging is not marked with the company’s name or trademark.

The crucial factor in determining whether packaging is considered to be manufactured 'under its own name and trademark' is:

• which company places the order for the manufacturing of the packaging or the packaged product

• which company has determined the design specifications of the packaging

Therefore, it is recommended that companies identify and agree on who has determined the design specifications.

Read more on the Danish Environmental Protection Agency's website here (Danish).

Read more about the manufacturer role and responsibility allocation in VANA's guide to PPWR: How to get started, here (for members, requires login).

The Packaging and Packaging Waste Regulation sets out various requirements for the design and construction of packaging in Articles 5-12 — also referred to as sustainability requirements. These requirements apply continuously.

We monitor developments in this area and will regularly update our guide and information on our website along with the ongoing specifications of the requirements and their implementation.

Read more about the sustainability requirements in VANAs guide, PPWR: how to get started, here (for memebers, requires login).

See also VANA's webinar about the sustianability requirements here (in Danish, for memebers, requires login).

The Packaging Regulation (PPWR) takes effect from August 12, which means that producer responsibility may, in some cases, shift from one company to another. 

Who is responsible before and after August 12?

• Up until and including August 11: The company that was responsible under the current regulations has producer responsibility.

• From August 12: The company that meets the producer definition under the new regulations takes over responsibility.

How should reporting to VANA be done regarding the change?

When reporting to VANA on September 1 (for quantities made available in August), the following applies:

• Company with responsibility before August 12: Must report quantities made available between August 1 and 11.

• Company that takes over responsibility from August 12: Must report quantities made available between August 12 and 31.

Please note that the new responsible company must be registered in DPA and choose a producer responsibility organisation (PRO) if the company has not had producer responsibility before August 12. Registration must be done no later than 14 days before the first availability, which is August 12. 

What do we do if we are in doubt about who has producer responsibility?

It is Dansk Producentansvar that has the competence to make a decision if there is doubt/disagreement about the allocation of responsibility.