Important clarifications regarding producer fees in new consultation material on the statutory order on packaging
A new draft of the statutory order on packaging has been sent for supplementary consultation on October 28. The draft provides important clarifications regarding the municipal producer fees, which have a significant impact on the prices of producer responsibility organisations. However, there are still substantial uncertainties that VANA and our founders are actively working to have clarified by the authorities, ensuring accurate costs and fair conditions for businesses.
Important clarifications – but still critical points
The regulation concerns, among other things, the fee maximum that ensures that companies only pay for the necessary costs.
The municipal producer fees are the largest cost in VANA's prices.
Among the most significant changes and clarifications are:
Municipal producer fees: The municipal producer fees are the largest cost in VANAs prices. According to the proposal, municipalities must publish the fees for 2027 on February 1, 2027.
Fee maximum (benchmark model): There is now a basis for a maximum for the municipalities' producer fees in 2027 (the benchmark model), so we can factor in the economic consequences with greater certainty. However, the model does not cover all municipal costs and risks, in our assessment, far exceeding the political target of a maximum of 1.2 billion.
Post-adjustment: The municipal producer fees for the period from October 1, 2025, to December 31, 2026, must be recalculated based on the new maximum cost levels. Both the size of the additional payment and its significance for VANAs economy still need to be clarified. This depends, among other things, on the final determination of the rules for the fee maximum.
Distribution keys: The distribution keys determine what share of the collected waste is considered packaging waste, and thus how much of the municipalities' costs the producers must cover. VANA has long been pushing for the distribution key for wood to be downgraded, as it imposes disproportionately large costs on producers in our assessment. In the new draft, the packaging share for indoor wood collected at recycling centers is proposed to be reduced from 16 to 9 percent. This is an important step in the right direction.
Business compensation: In addition to the above, VANA is also pushing for regulation of key figures for business compensation, as the extent of compensation for commercial packaging remains uncertain and affects the overall costs.
VANA is reviewing the draft
VANA is now reviewing the draft of the statutory order more closely, with special focus on the economic consequences, pricing, and the critical points that still require clarification. We will return with an elaboration of the most important issues.
Read the consultation material on the Consultation Portal (In Danish) - the consultation deadline is November 11, 2026.