VANA complains about new municipal allocation: Errors in the calculation method distort competition
VANA has complained to the Danish Energy Agency about the allocation of packaging waste for 2027-2028. The new allocation is based on serious errors in the calculation method that creates unequal competition conditions between the producer responsibility organisations. VANA's members are thus at risk of additional costs of a multi-million scope.
Dansk Producentansvar (DPA) has established the new allocation of packaging waste, which will apply from January 1, 2027, to the end of 2028. The new allocation was published at the beginning of October, but several parts of the calculation method produce, in our assessment, an incorrect and competition-distorting result. One of the issues that VANA highlights, regarding the under-collection of commercial waste, potentially leads to an additional cost of 90-95 million DKK over the two years that the allocation applies.
VANA has therefore complained to the Danish Energy Agency with a request to change DPA's decision and have the allocation recalculated. Alternatively, the decision should be sent back to DPA for renewed consideration.
We also urge the Danish Energy Agency to have an independent external expert review the allocation method to ensure fair competition conditions and to focus on preventing free riders from avoiding the bill.
VANA points out several methodological errors in the calculations
The allocation determines how large a share of the packaging waste each producer responsibility organisation must take over or finance in 2027 and 2028. The calculation therefore has a direct impact on the costs that the organisations – and ultimately their member companies – will have to finance.
VANA points out in the complaint, among other things, that:
Freeriders are not assigned collection responsibility retroactively for 2025-26.
New producers are only assigned collection responsibility 1-3 years after entering the market, and they are treated differently depending on their entry time.
A shortfall in the collection of household packaging in 2025 is penalised with an eightfold additional collection in the upcoming allocation period.
For commercial packaging, over/under collection is calculated even though the collection of the producer responsibility organisations does not factor into the calculations at all.
Discontinued producers, who have already been assigned collection responsibility, are also assigned producer responsibility going forward.
Producer responsibility organisations are assigned collection responsibility for producers who, in the upcoming allocation period, have switched to another producer responsibility organisation.
This means, in other words and overall, that collection responsibility and costs do not in all cases follow the producers and producer responsibility organisations that should bear the responsibility.
VANA calls for quick clarification
The new allocation comes into force on January 1, 2027. VANA has therefore asked the Danish Energy Agency to process the complaint as quickly as possible. Until the Danish Energy Agency has made a decision on the complaint, it is not clarified whether the allocation for 2027-2028 will be changed.
The allocation is crucial for VANA's ability to set prices, and VANA is therefore urging the authorities to address the complaint immediately. We are in ongoing dialogue with the authorities and are, of course, closely monitoring the handling of the complaint so we can inform our members as soon as there is any news in the case.
CEO