FAQ - Reusable Packaging
Packaging that has been designed, shaped, and brought to market with the intention of undergoing a number of trips or cycles during its lifetime by being refilled or reused for the same purpose for which it was intended (§ 3, section 1, no. 17 in the statutory order on packaging, which is in Danish).
The Environmental Protection Agency states the following:
The definition of reusable packaging is cumulative, meaning that all three elements of the definition must be fulfilled before a packaging can be considered reusable packaging. For example, if a EUR pallet is not brought to market for reuse, it is not a reusable packaging. It also implies that there is an indirect requirement that the EUR pallet must be part of an active reuse system, otherwise it cannot be guaranteed that the purpose was to bring it to market with the aim of at least undergoing a number of trips or cycles.
DPA states the following:
In relation to reusable packaging, it is important to distinguish between "reusable packaging" defined in the order and reuse of packaging. A packaging is not reusable packaging merely because it is reused as packaging. If it is a case of reuse of packaging, it is crucial whether a previous link has taken producer responsibility for the packaging. If company A from Denmark reuses cardboard boxes as packaging that they have received as packaging from company B from Denmark, which has reported the cardboard boxes as packaging in the producer responsibility register, the cardboard boxes do not need to be reported again.
There is also no such thing as "reusable packaging" simply because packaging consists of recycled materials.
What distinguishes one-way packaging from reusable packaging is whether the packaging is designed for and included in an established reuse system that ensures the reusable packaging is taken back and used multiple times for the same purpose as it was designed for.
A one-way packaging does not become a reusable packaging just because it is used again (and that is a good idea).
See more about definitions of packaging here:
Prepare for producer responsibility with good packaging design
If you place reusable packaging on the market, the company must be registered in the category 'Reusable packaging'.
The registration is open at Dansk Producentansvar (DPA). Members of VANA can manage it directly through VANA's Member Portal.
Read more about the registration and reporting of reusable packaging
VANA has continuously brought to the attention of the authorities that there is a lack of clarity regarding the understanding, allocation of responsibility, and registration of, for example, EUR pallets.
The Environmental Protection Agency has now provided guidance on the allocation of responsibility when it comes to genbrugsemballager, including for EUR pallets.
For a packaging to be categorized as a genbrugsemballage, it is essential that the company takes back (link to take-back) the packaging with the aim of placing it on the market again in its original form. There will be specific rules on how genbrugsemballage quantities that are introduced and taken back from the market must be accounted for.
Reporting of reusable packaging
DPA states the following:
In relation to genbrugsemballage, it is important to distinguish between “genbrugsemballage” defined in the regulation and reuse of packaging. A packaging is not genbrugsemballage simply because it is reused as packaging. If it involves reuse of packaging, it is crucial whether a previous entity has taken the producer responsibility for the packaging.
If company A from Denmark reuses cardboard boxes as packaging, which they have received as packaging from company B from Denmark, which has reported the cardboard boxes as packaging in the producer responsibility register, the cardboard boxes do not need to be reported again.
There is also no notion of “genbrugsemballage” simply because a packaging consists of recycled materials.
Reuse of packaging is supported in the upcoming system by the fact that producers using reusable packaging only need to pay once for the packaging's circulation in the market. If a reusable packaging, for example, can be circulated 30 times before being discarded, a fee is only paid once instead of the 30 times that would have been charged with the use of one-way packaging.
It is desired in the political agreement on producer responsibility that flexible frameworks for producers with new packaging solutions are ensured, for example in the form of reuse and return systems. Read more here.
Read more about the registration and reporting obligation for reusable packaging
All three concepts are important to understand and know the difference between.
Reuse is when the packaging is collected and used again in its original form a number of times. For example, a cup that is washed and used again, still as a cup.
Recycling is when the packaging is shredded or separated and the material is used in and for new products. In the example with the cup, when it becomes waste, it will be treated and for example ground down to become new material such as rPET, which can be included in new products.
Recycled content is when the material included in a packaging (both single-use and reusable packaging) is recycled. This means that the raw material used for production is made of entirely or partially recycled material such as rPET. In the cup example, the cup can be produced with entirely or partially recycled raw material.