Extended producer responsibility (EPR) introduces new requirements for all companies that make packagings or single-use plastics available on the Danish market new meaning economic and administrative responsibility burdens.

The aim of EPR is to reduce the consumption and disposal of various packagings. Therefore, the companies must register as a producer under the EPR-scheme and a fee must be paid for the products made available in Denmark; the fee is meant to cover the costs of the relevant waste management.

The rules entail obligations to registration, fee payments, and reporting requirements – a considerable administrative burden for many companies.

We are ready to help you gain an overview, ensure correct registration, and optimize the handling of producer responsibility.

When are you considered a producer?

A company is considered to be a producer if it is the first to make packagings, single-use plastics, or filled packagings available on the Danish market. This applies regardless of whether the goods are self-produced or imported. Whether a company is considered the first to make a product available on the Danish market depends, among other things, on the product flow and whether the products are generic or not.

As the main rule, there are no exemptions or de minimis thresholds. However, micro-enterprises may be exempt from the producer responsibility for packaging in certain situaitons. A micro-enterprise is defined as a business employing fewer than 10 people and having an annual turnover not exceeding DKK 15 million. Micro-enterprises are not exempt if they import or manufacture the packaging themselves. For single-use plastics, no exemptions apply.

Examples of covered products

Packagings in this context must be understood in a very broad sense, and covers all types of materials, e.g.:

Packagings: cardboard boxes, plastic and paper bags, stretch film, cans, pallets, disposable tableware, wrapping paper, glass bottles, containers of various sorts, etc.

Single-use plastics: food containers, beverage cups, plastic films, lightweight carrier bags, wet wipes, tobacco filters, and balloons.

Municipalities, public regions, and other public entities

Municipalities, and public entitites that make certain products available in Denmark are also subject to producer responsibility. Municipalities etc. may be subject to producer responsibility if, for example, it distributes goodie bags to new residents, with the municipality’s name or trademark printed on the bags; candy wrappers with the municipality’s logo or trademark; stickers with the municipality’s logo or trademark adhered to a product such as a gift box/bag, etc. A municipality, etc. may be exempt from producer responsibility for packaging if it qualifies as a “micro-enterprise.” The assessment is based on the municipality’s/region’s CVR number, not on SE numbers.

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