New statutory order on packaging: More rules must now be found in the EU's PPWR
The new statutory order on packaging, which has been awaited since the spring, is aligned with the EU PPWR and enters into force on October 15, that is, today. This means that several central rules and definitions must now be found directly in the PPWR, while the Danish order supplements with the national rules regarding producer responsibilty for packaging.
With the new statutory order on packaging, which was issued by the Danish Energy Agency at the end of September, a number of Danish provisions are therefore removed from the order itself, because the rules now apply directly through the EU's PPWR, which has been in effect since August 12, 2026.
At the same time, a new approval scheme is introduced for producer responsibility organisations, which will henceforth be referred to as producer responsibility organisations.
The most important change for you as businesses is thus where you need to find the rules and definitions – not how you should handle your ongoing obligations under producer responsibility.
Read more about the statutory order on packaging and other relevant legislation
Find definitions in the PPWR
One of the most important changes you should be aware of is that several definitions no longer appear in the Danish order. This includes terms such as producer, manufacturer, importer, distributor, and end user, which are now found in Article 3 of the PPWR.
It is especially important to distinguish between producer and manufacturer, as the two roles entail different obligations. The producer role pertains to extended producer responsibility, while the manufacturer role involves ensuring that the packaging meets the regulation's requirements.
Although provisions have been removed from the Danish order, it does not mean that the requirements have been eliminated, but rather that they can now be found in the PPWR.
Definitions and roles
As a member of VANA, you can see our previous webinar and accompanying slides on definitions and roles (only on the Danish page and in Danish) in our webinar library.
See previous webinars and slides in the webinar library
In addition, you can register for our upcoming webinar on the manufacturer's role and responsibility under PPWR, which will be conducted on 21/10 at 10:30-11:30 (only available on the Danish page and is conducted in Danish).
Register for the webinar on the manufacturer's role and responsibility under PPWR
New approval scheme for producer responsibility organisations
With the new statutory order on packaging, the Danish term for "producer responsibility organisations" is changed in accordance with the wording of the PPWR.
The order also introduces an approval scheme for producer responsibility organisations. This means that the organisations must be approved in the future and meet a number of conditions to be able to assume producer responsibility on behalf of their members.
Furthermore, approval requirements are introduced for producers who choose to meet their producer responsibility individually. Members of VANA do not need to comply with the new approval requirements.
The rules on registration, reporting, and eco-modulation remain unchanged
Although the new order contains a number of changes, the existing rules on registration, reporting, and eco-modulation remain unchanged.
Companies must therefore still register, report, and pay for their packaging quantities according to the applicable rules, just as the principles for eco-modulation continue as before.