Reporting 2025 - Eco-modulation

It is a requirement that the costs that companies have to cover from 1 July 2025 are eco-modulated. This means that companies pay less for packaging that can be reused or recycled.

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

Legislation about the design requirements for the eco-modulated fees are expected in June 2024, but the Danish Environmental Protection Agency (EPA) has published their recommendations for design requirements.

Read more about the specific design requirements here (only in Danish). 

Bonus/malus model

The EPA's recommendation is a bonus/malus model, where the companies, who market packaging with low recyclability, must pay a larger part of the costs.


The Producer Responsible Organisation (PRO) must give each producer, who markets one or more packagings in the high leve,l a malus (extra cost) in the shape of 35% of the individual producer's calculated operational costs for waste management of all of its products which are in the high level (red). 


The PRO must use the additional income from the malus for red-level packaging in a given material category to cover the operational costs for waste management of green-level packaging within the same material category.

For the material categories where there is a yellow level, the individual producer pays the actual operational costs for the waste management of the packaging.

Read more about the requirements which apply in other countries here.

The EPA's recommendation for material categories and levels

Companies must report data on packaging made available in 12 material categories (fractions).

Each material category is divided into different levels (rates).

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Sign up for our newsletter if you want to know more about the producer responsibility for packaging and what your company needs to be ready with before 2025? Then we will keep you updated when there is news about producer responsibility and the deadlines you have to meet. (Danish only)