Are you on top of EPR in Denmark?
by Aaron Sarah at 14:12 in Packaging, Emerging
Denmark is the one of the final countries in the EU to implement Extended Producer Responsibility (EPR) for packaging. Whilst EPR does not officially come into force in Denmark until July 2025, companies are facing obligations from 2024. So this begs the question, is your company on top of these regulations?
Who is covered?
The EPR regulations in Denmark mean that any company that places their packaged products on the market in Denmark will be responsible for the financing and management of the waste that is created. Overall, it is estimated that approximately 40,000 companies will be obligated by EPR in Denmark. This also includes companies established outside of Denmark that make their packaged products available to end users via distant sales.
Obligation to register and report in 2024:
Despite EPR not officially coming into force until July 2025, covered companies face obligations from 2024. The obligation in 2024 is to register and report to Dansk Producentansvar (DPA), which is the non-profit organisation established to administer the national register and Danish legislation on producer responsibility. Companies will be required to register and report forecast data to the DPA between 1st April and 31st August 2024. The DPA will use this data to assign municipalities in Denmark to Producer Responsibility Organisations (PROs). Apart from a one-off registration fee to the DPA, companies will not be required to pay a fee on this report.
There are some exceptions to this report. Companies that have less than 10 people and that have an annual revenue of less than 15 million Danish Krone will be exempt, unless they are importing filled packaging into Denmark. Companies that also expect to place less than 8 tonnes onto the Danish market in 2024 have the option to submit a simplified report that is not split by materials but just reports on the total expected amount and the distribution of weight between household and commercial waste streams.
Reporting from 2025:
During 2024, companies not wanting to individually comply with EPR, will need to select and join one the PROs that has been assigned in Denmark. This will then mean from July 2025 companies can report their packaging data to a PRO.
As per the regulation, the costs that the companies incur on reports made from July 2025 will be environmentally graded. The environmentally graded system that has been recommended by the Danish Environmental Protection Agency is similar to the one currently used in Sweden. This means packaging that has design elements that make it harder to be recycled such as inks/barriers will be assigned a higher 'red' fee through malus than packaging that is designed to be recyclable, such as packaging that avoids glued on labels and is uncoloured etc, which will be given a 'green' fee. There will also be a standard 'yellow' fee in-between for some material types.
Next steps:
If your company places packaging onto the Danish market and you are unsure about what you should do next in terms of the registration/reporting obligation in 2024 and obligations from 2025, then please contact us at Lorax EPI today and we will gladly assist you with your EPR compliance in Denmark and around the world.
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