VANA calls for more communication and involvement regarding the implementation of the PPWR

VANA also emphasises the need for rapid and clear communication from authorities about requirements, especially amended definitions that may have implications as early as August 2026. Finally, VANA points out that the revision of the statutory order on packaging should be carried out in dialogue with relevant stakeholders, that an authorised representative should be an option and not a requirement for EU companies, and that the allocation model should be simplified so that quantities can be transferred when switching producer responsibility organisation (PRO).

VANA's main points

• National implementation: Minimise administrative burdens for businesses by using exemptions and flexibility where possible.
• Clarity about rules is crucial for stable packaging prices: VANA has adjusted prices for Q4 2025 and 2026 based on political announcements and calls for this to be reflected in the revision of the statutory order on packaging — with the involvement of relevant stakeholders.
• Equal competitive conditions and simpler administration for PRO's: This is central, together with more guidance and control against freeriders, so the system delivers real environmental effects.
• Communication of requirements: The authorities communicate requirements as quickly as possible, especially changed definitions that can have direct implications for companies already from August 2026.
• Approval scheme for PRO's: VANA supports this, but it should be designed in close dialogue so approvals happen quickly and smoothly. VANA points out that terms such as withdrawal notice periods and requirements like NIS2 compliance should be included to ensure equal conditions across the board.
• Authorised representative as an option: should not be a requirement for EU companies, since registration in Denmark does not presuppose establishing here, and such a requirement would be disproportionately administratively burdensome.
• The allocation model for household waste should be improved: The current model creates fragmentation, more contracts and a higher risk of errors and delays.
• Quantities must be able to be transferred when changing PRO's: Packaging (as opposed to electronics) has a different “time on market”, and flexibility is necessary for the system to function.

You can read the full consultation response under the heading "Miljøbeskyttelsesloven" here (only in Danish)