Packaging reporting

The eco-modulation must ensure cost neutrality for each individual material category, so that the companies in a material category do not pay more or less than the actual costs of waste treatment.

Find the Danish Environmental Protection Agency's guide to determining the environmentally graduated contributions (Danish)

Reporting

Companies must report actual quantities made available to VANA on an ongoing basis. There are two types of reporting:

• monthly (for companies with volumes above 8 tonnes per year)
• quarterly (for companies with volumes below 8 tonnes per year)

Monthly reporting (for companies with volumes above 8 tonnes per year)

Quarterly reporting (for companies with volumes below 8 tonnes per year)

Monthly reporting – companies with quantities over 8 tons

Companies must report the actual quantities made available on the market during the previous month on a monthly basis by the following material categories:

• cardboard – two rates (red/green)
• paper – two rates (red/green)
• ferrous metals – two rates (red/green)
• aluminium – two rates (red/green)
• glass – two rates (red/green)
• flexible plastic – three rates (red/yellow/green)
• rigid plastic – three rates (red/yellow/green)
• rigid PET – three rates (red/yellow/green)
• foam plastic – three rates (red/yellow/green)
• food and beverage cartons – three rates (red/yellow/green)
• wood – not eco-modulated
• textile – not eco-modulated
• porcelain – not eco-modulated
• cork – not eco-modulated
• ceramics – not eco-modulated
• other – not eco-modulated.

Have a look at an example of the complete report model

Example of Eco-Modulated Reporting

The Member Portal opens for reporting in the categories you have registered.

*Contact-sensitive packaging is except eco-modulation. Therefore, the base price of the material classification is to be paid. Read more about contact-sensitive packaging.

To determine whether you should report in red, yellow, or green, you must use the design requirements in Annex 14 of the regulation and the Danish Environmental Protection Agency's guidance. Find them here.

Changes to Reports and Reporting

If you discover an error in the annual report to Dansk Producentansvar (DPA), or subsequently obtain documentation that the packaging has been made available outside of Denmark, you can correct the report under certain conditions:

• The changes must be made collectively with the next annual report
• You may only make corrections for the previous calendar year
• The change must be due to an error or transfer abroad. This must be documented
• All corrections must follow the rules for the original report

Documentation for Transfer Abroad (Export):

If there are changes to quantities that have already been reported to Dansk Producentansvar (DPA), you must send a digital declaration to DPA, completed by the company that handled the transfer. VANA is in the process of clarifying how this should be implemented in practice by our members and is awaiting the formulation of the digital declaration from DPA.

Companies that directly make packaging available outside of Denmark do not need to report these quantities.

VANA has urged that companies with documentation and knowledge that the packaging will be exported abroad in a later stage should not need to report either.

The Danish Environmental Protection Agency has issued a statement that does not confirm the above, thus requiring that reporting must happen, even if there is knowledge of later exports. The reporting can then be adjusted later in DPA.

As this will have significant implications, both administratively and financially, VANA is working on a pragmatic solution outside of DPA that ensures it will be manageable for our members.

For companies with quantities below 8 tonnes (administrative triviality limit)

Companies that make less than 8 tonnes of single-use packaging available in a calendar year can choose to report only the total weight of the single-use packaging made available, divided into household and commercial packaging.

The reporting must be done quarterly.

If you wish to report on the individual material categories instead of the total packaging category, you can certainly do that. In that case, the reporting occurs under the same conditions as if you make available over 8 tonnes of packaging – i.e., monthly reporting, payment, and eco-modulation of the packaging.

Data collection based on design requirements

There are no official requirements for your data collection process or how you structure your data. However, it is your responsibility to ensure that you have all the necessary packaging data to report correctly to the authorities and allocate your packaging quantities to either the red, yellow, or green level.

You can structure your data and collection process to meet the reporting requirements in a way that makes the most sense for your specific company. The design requirements of the eco-modulated fees determine the level of detail needed for the data to be collected.

Reporting options with VANA

You can report your data to VANA in 3 different ways. If you are using an external partner, you should be aware that they can support your reporting choice via file upload (CSV) or API integration.

VANA's Member Portal
In VANA's Member Portal, you can fill in your data in the fields corresponding to the material categories you have registered for each reporting period.

Transfer via file upload
Data can be imported to VANA's Member Portal via a CSV file. The template for the CSV file must be downloaded from your reporting page in the Member Portal, as it is specifically designed for the material categories you have registered. You cannot use your own file formats or change the setup of the downloaded template, as this will cause the transfer to fail.

The template can be downloaded from November 1, when the first reporting period opens in the Member Portal. You can see an example of a CSV file here (NOTE: The file cannot be used for upload when reporting opens).

Transfer via API integration
If you have built your own data collection system, for example through your own business or financial system, it is possible to integrate with VANA's portal via an API solution. If you wish to use this solution, you must contact VANA's Member Service to obtain an API key for the integration - instructions can be found in the Member Portal under the "API" tab, where there is also an option for technical support.