New VANA prices – continuing legal uncertainties
VANA has just announced lower prices to our members based on the intentions in the government's political statement. However, the draft amendments to the statutory order on packaging, which forms the legal framework for producer responsibility on packaging, still create significant uncertainty. VANA has just sent a consultation response focusing on 4 problematic areas.
Based on the government's political announcement last week, VANA has recalculated the prices for handling packaging waste for Q4 2025. The new, lower prices were communicated to our members yesterday. This means that VANA's members can now see the first concrete results of the political intentions to reduce the companies' bills for handling packaging waste.
Regulation of prices
Price adjustment September 2025
The base prices of VANA were adjusted on September 18, 2025, based on the government's political announcement regarding the adjustment of the framework for producer responsibility for packaging.
The Danish Environmental Protection Agency has since the price adjustment on 18/9 informed that the updated key figures for payment for households' non-packaging as well as commercial packaging waste, which VANA has based its price recalculation on, contain errors. This error will be incorporated into our next recalculation of base prices, which is expected to become effective from January 1, 2026 - unless the content of the revised version of the statutory order on packaging, which is currently pending, necessitates adjustments beforehand.
Members are always directly informed via email about any adjustments to prices. Read more here.
Uncertain frameworks and unresolved questions
At VANA, we view the government's announcement positively, which we, along with our founders, have worked intensively to establish. But unfortunately, there are still many uncertainties, as the draft of the amended statutory order on packaging, which sets the very frameworks for producer responsibility for packaging, does not reflect the political announcements. And this naturally creates a significant risk that the good intentions will not be realised in practice.
Therefore, VANA has today sent a clear consultation response to the Ministry of Environment and Gender Equality, where we emphasise that it is crucial for the order to be aligned with the intentions of the government's announcement. And we are, as always, in ongoing dialogue with the authorities and working constructively to ensure that producer responsibility can commence on Wednesday, October 1st.
We have chosen to send a very clear signal in our consultation response, as we must be able to expect that the legislative framework will reflect the government's goals. If this does not happen, it may unfortunately mean yet another recalculation and adjustment of VANA's prices.
CEO
Four problematic areas
In VANA's consultation response, we particularly highlight four areas where there are discrepancies between the political announcement and the current text in the draft statutory order:
1. Cap on municipalities' producer fees
Government's announcement: a maximum fee of 1.2 billion DKK.
Challenge: The statutory order does not set the cap – it must first be negotiated with the municipalities.
2. Installment payment of recalculation
Government's announcement: possibility to spread any payable amount over four years.
Challenge: This is not stated in the statutory order – and may contradict state aid rules.
3. Basic service level: Uniform calculation of municipal fees
Government's announcement: a common method so that, for example, glass does not become unreasonably expensive.
Challenge: The statutory order does not obligate municipalities to recalculate according to a new method – and the timeframe is unrealistically short since producer responsibility enters into force organisationally in 11 days (1st of October).
4. Administrative fees to the authorities
Government's announcement: Look at the fees for The Danish Environmental Protection Agency and Dansk Producentansvar.
Challenge: Invoices have already been sent out – and companies must pay now, even though the fees could, in the worst case, drive companies to their knees.
Focus points in VANA's consultation response
The political desires must be ensured in the statutory order
- Clarity and a cap on municipal fees – a maximum of 1.2 billion DKK for producers.
- Transparency and reasonable fees to municipalities – municipal fees must be calculated using a uniform method and published collectively.
Administration fees
– need for a clear statement regarding invoices and cost levels at The Danish Environmental Protection Agency and Dansk Producentansvar.
Eco-modulation
– should be postponed until the EU's final criteria are in place to avoid unnecessary administrative burdens.
The packaging fee
– should be permanently abolished, not just temporarily for 2026-2027.
Free-riders and commercial waste – need for concrete measures and more market-responsive key figures.