Reporting of reusable packaging
Companies that make reusable packaging available for the first time must register with the authorities (Dansk Producentansvar) and report the quantities made available.
Reused packaging is subject to reporting requirements the first time they are made available, with the aim of going through a number of trips or cycles by being refilled or reused for the same purpose. If you choose to report reused packaging through VANA as a producer responsibility organisation (PRO), VANA will handle the registration and reporting to the authorities.
Webinar on reusable packaging
On November 25th, we will hold a webinar on reusable packaging for our members. The webinar will cover, among other things, definitions, when we are talking about reusable packaging, how it is determined who has the producer responsibility for reusable packaging, and the requirements for reporting.
Annual reporting of reusable packaging (2025 quantities) in 2026
Companies with producer responsibility for reusable packaging must report the following in 2026:
- Available quantities of reusable packaging in 2025 in the material categories mentioned in Appendix 6 of the statutory order. See the categories below (there is no need for eco-modulation).
- Collected quantities of reusable packaging waste in 2025 in waste fractions mentioned in Appendix 7 of the statutory order. See the fractions below.
Material categories (Appendix 6): cardboard, paper, ferrous metals, aluminium, glass, plastic, food and beverage cartons, wood, textiles, porcelain, cork, ceramics, other.
Waste fractions (Appendix 7): cardboard waste, paper waste, metal waste (including ferrous metal waste and aluminium waste), glass waste, plastic waste, food and beverage carton waste, wood waste, residual waste, hazardous waste.
Payment
Companies that make reusable packaging available pay:
- for the collection and treatment of the reusable packaging they have taken back
- fee to Dansk Producentansvar (DPA) for registration in the producer register (if the company is not already registered)
- administration fee to Dansk Producentansvar (DPA) based on the quantity of reusable packaging placed on the market
- administration fee to the Danish Environmental Protection Agency based on the quantity of reusable packaging placed on the market.
No payment to VANA
There is no payment to VANA for the handling of packaging related to the reporting. VANA does not invoice the reported quantities of reusable packaging.
Deadlines
The VANA member portal will open for reporting of reusable packaging at the beginning of 2026. More information will follow.
Obligations for businesses with reusable packaging
Obligation to ensure waste treatment
As a business, you must ensure proper waste treatment in accordance with the rules for genuine recycling and pay for the waste treatment of the reusable packaging that you take back when it is no longer reused and becomes packaging waste.
You are probably already doing this today when you dispose of used reusable packaging.
Obligation regarding awareness raising measures
As a company, you are obliged to ensure that end users of the producer's packaging are informed in sales and informational material, including in user manuals or at the point of sale, about where and how the end user can dispose of packaging waste in the take-back scheme.
Obligation to take back reusable packaging
Companies that are subject to producer responsibility for reusable packaging are obliged to take back their reusable packaging when it can no longer be reused and becomes waste.
Return can occur in one of the following ways:
- The company collects the packaging waste from the end-user.
- The end-user delivers the packaging waste to the company or to a location or area designated by the company.
Only quantities of packaging waste corresponding to the company's available quantities for the relevant calendar year can be taken back.
The company cannot request compensation for commercial packaging waste that originates from the company's available packaging.
Uncertainty - placement of the producer responsibility for reusable packaging
However, there is still ambiguity regarding the more complex reuse systems, where reusable packaging changes ownership, crosses borders, and is part of more open systems.
VANA has urged the Danish Environmental Protection Agency to elaborate on their guidelines. Currently, it is Dansk Producentansvar (DPA) that has the authority to make decisions in cases of doubt about the placement of producer responsibility.