The statutory order on packaging has arrived – legal framework in place by October 1st
The Ministry of Environment has now published the revised statutory order on packaging. The legal framework for producer responsibility on packaging, which enters into force organizationally tomorrow, October 1, 2025, is thus in place. Unfortunately, it does not provide answers to everything.
VANA is in the process of closely reviewing the statutory order in order to translate it into practice for our members and ensure that it aligns with the government's political statement made earlier this month. The draft that was sent for consultation last week did not achieve this, which is why VANA, in its consultation response - and in the media over the past week - has pointed out a number of challenges that were important to clarify in the legal framework. Read more here.
Preliminary summary on the statutory order in relation to the challenges
- The challenge with the quarterly municipal fee of 400 million has been solved: Municipalities must multiply the fee by 62.5 percent - meaning if the fee was 100 DKK from a municipality, they may only charge 62.5 DKK to the producer responsibility organisations. Thus, the total quarterly fee to municipalities will be 250 million DKK.
- There is still no ceiling on the municipalities' producer responsibility fee, and there is still a lack of clarification regarding the municipalities' volume-based recalculation.
- The supplementary payment to municipalities of a maximum of 200 million DKK, distributed over four years, is not included.
It appears that a type of ceiling over municipal fees (the so-called basic service level) should be prepared, but this is only to be developed towards October 1, 2026.
The regulation answers some of the challenges that we have strongly called for in order to translate the political intentions into practical frameworks. However, there are certainly still some challenges and shortcomings, including the decision not to simplify eco-modulation and compensation applications.
CEO