Extended producer responsibility for packaging

The Danish Producer Responsibility (DPA) ensures that companies that sell products with packaging in Denmark take responsibility for it when it becomes waste. This means that companies must pay for the handling of both disposable and reusable packaging and ensure that the packaging is reused or recycled where possible. For single-use packaging, membership of a collective scheme is mandatory, while for reusable packaging it is optional. The DPA manages the registration of companies, collects information on packaging volumes and collects administration fees to ensure responsibility is distributed correctly. The aim of the scheme is to reduce the amount of packaging, promote reuse and recycling and make packaging greener.

At Dansk Transport Emballage A/S (DTE), we are working hard to ensure a smooth and transparent transition to the new extended producer responsibility for packaging, which comes into force on October 1, 2025. We want to inform you about what Extended Producer Responsibility is, how DTE handles the legislation and what it means for your collaboration with us.

Please note that the rules for extended Producer Responsibility are still under development. The Confederation of Danish Industry and other industry organizations are in dialogue with the Danish Environmental Protection Agency, and there may be changes towards the entry into force on 1 October 2025 and beyond.

Who is responsible for reporting?

We have analyzed all our packaging to determine who bears the producer responsibility and thus has to pay fees. The assessments are based on the Danish Environmental Protection Agency's guidelines, which state, among other things:

"If packaging is to meet the requirements of being designed or manufactured under the trader's own name or trademark, this generally requires the trader to have his own name or trademark on the packaging - regardless of whether other trademarks are visible."

Based on this, we distinguish between:

• Generic packaging -also called standard products - here the producer responsibility lies with DTE.
• Non-generic packaging -packaging with the customer's name, trademark or any special product customizations - producer responsibility lies with you as the customer.

Environmental classification rules and fees

Our systems are updated to handle environmental gradients. These can be found in technical data sheets and invoices.

• For generic packaging, we re-invoice fees based on weight (kg). The fee is shown as a separate line on the invoice per product, labeled "EPR fee".
• Non-generic packaging with Producer Responsibility at the customer is not subject to a fee, as you are responsible for reporting and payment.

Special cases

There are certain types of packaging where responsibility is unclear and requires additional information:

• Composite units(e.g. lid and base): If one part is printed with a name or trademark, the customer is responsible for the entire unit.
• Labels, tape, labels or stamps with name/trademark affixed to the packaging by you or your customers: Producer responsibility lies with you or the customer. (Note again the "top/bottom" case)
• Micro businesses with fewer than 10 employees & an annual turnover below DKK 15 million, also for printed packaging. We need to know whether you are a Micro company or not - at the latest when placing your next order.

Note: Micro companies are exempt from reporting. DTE takes care of that. However, Micro companies will be charged the environmental fee as it applies to other companies.

If we do not receive other information from our customers/you by the time your next order is placed, we will assume that the producer responsibility for all products (without logo, image, text or other customizations) lies with us.

What are the rules for exporting packaging?

There is still uncertainty about the handling of packaging that is exported and thus not covered by producer responsibility in Denmark. We recommend following statements from VANA, the Danish Environmental Protection Agency and DPA (Danish Producer Responsibility).

If you export generic products on which we have imposed EPR fees, we will credit these fees. We realize that this involves extra administration, but it is the best solution under the current legislation.

Is it possible to transfer responsibility?

Legislation does not allow producer responsibility to be transferred between parties. The only way you as a customer can take over responsibility is by having your name, logo or trademark imprinted, customizing the product - or by affixing a label or tag with this information on the packaging.

Information from you

For correct billing and reporting, we need to know whether the packaging will primarily become household or commercial waste. Therefore, please indicate this with each order placement.

We also need your input on packaging that falls under the special cases and in particular, as mentioned above, whether you are to be considered a Micro enterprise. Please send this information to your contact person at DTE or to [email protected] no later than September 30, 2025 or at the latest with your next order.

Do you have any further questions?

Please contact us if you have any questions or need clarification. You can fill out our contact form or call us on +45 74591680.

Sincerely yours

Dansk Transport Emballage A/S