The Danish Energy Agency's webinar provided useful clarifications – but central questions about responsibility in the value chain remain unanswered
On September 30, the Danish Energy Agency conducted a webinar on the environmental requirements in the PPWR.
VANA has continuously submitted examples to the authorities regarding the allocation of responsibility in the value chain. Several of these examples were fully or partially addressed in connection with the webinar, including examples about the end-user concept, distribution services, and situations where goods are handled by multiple actors before reaching the final recipient.
Important clarifications
Identification of packaging and manufacturer: It was specified that a web address may be sufficient as electronic contact information for identifying the manufacturer when the packaging is being checked.
Liability allocation with multiple parties: The Danish Energy Agency presented new examples of how liability can be allocated in value chains where the physical product is handled by multiple intermediaries. It was emphasised here that it is the agreement on the transfer of ownership that determines the first availability, not whether another company physically undertakes part of the handling.
Remaining unclear elements regarding responsibility placement
The webinar still left questions about when a company has "had packaging or a packaged product manufactured," and how that timing affects who is considered the manufacturer according to the packaging and packaging waste regulation.
VANA continues the dialogue with authorities on the questions that are not yet sufficiently clarified and will provide ongoing updates when there are clarifications.
VANA also conducts webinars
You can find our webinars, which among other things are about the PPWR, via the link below!
View webinar overview