VANA submits a consultation response on supplementary provisions to the PPWR

At the same time, VANA points out that several elements in the consultation draft may have significant and undesirable consequences for both producers and producer responsibility organisations.

In the consultation response, VANA emphasises, among other things, the need for The Danish Environmental Protection Agency to quickly and clearly communicate the changes that will have a direct impact on companies, including changes taking effect as early as August 2026. It also points to a growing need for dialogue and guidance to ensure consistent implementation and reduce unnecessary administrative burdens.

VANA also highlights that companies are already in the process of adapting to the upcoming requirements in the PPWR. Therefore, national exemption options and flexibility should be used and communicated as early as possible so that the business community has better conditions for timely adaptation.

VANA also calls for clarity on a number of other areas, including reusable packaging, the triviality limit, rules on the authorised representative, the approval scheme, and the possibility of a more flexible allocation of the producer responsibility between parties in the value chain.

VANA's main points

• Definitions: Harmonisation of definitions can shift producer responsibility in the value chain. VANA therefore urges a rapid update of the guidance material to ensure the possibility of timely transition and reduction of administrative burdens.
• Collateral (guarantee): The change in the conditions for guarantee can have decisive consequences for producer responsibility organisations' existence. VANA therefore strongly urges retention of the existing model.
• Recycling targets: The draft over-implements the recycling targets and imposes an entirely unreasonable obligation on producers, which is why it is essential that The Danish Environmental Protection Agency maintains the current model.
• Reuse: New harmonised rules in the regulation replace large parts of Danish regulation, but do not resolve the uncertainty regarding the placement of producer responsibility for reusable packaging. VANA calls for swift and clear guidance on producer responsibility in open reuse systems.
• Triviality limit: The regulation harmonises the triviality limit to 10 tonnes. VANA seeks confirmation of the consequences for report and guidance.
• Authorised representative: The current requirements favour third-country companies. VANA supports a requirement for an authorised representative for companies outside the EU and requests clarity in the statutory order.
• Transfer of producer responsibility: The rules should allow flexible allocation of responsibility between parties. VANA requests confirmation that the regulation does not prevent this.

Read the full consultation response under "Emballagebekendtgørelsen" here (Only in Danish)