Danish EPR Guide: Who Has Producer Responsibility for Packaging?

When do you have producer responsibility?

In Denmark, you have producer responsibility if your business places packaging on the Danish market.

This includes:

• Selling packaged products in Denmark
• Importing goods into Denmark (with packaging)
• Shipping products to Danish customers (for example, e-commerce packaging such as boxes and fillers)

There is no minimum threshold to be covered. Even small amounts of packaging can mean you are responsible.

In simple terms, if your business is the first to put packaging into circulation in Denmark, you are likely responsible.

Who is considered a producer?

The term producer does not only refer to manufacturers. In EPR, it means the company that first makes packaging available on the Danish market.

This typically includes:

• Danish companies selling packaged goods
• Importers bringing packaged goods into Denmark
• Webshops shipping products to Danish customers
• Brand owners selling products under their own name

For example, if you import products from abroad and sell them in Denmark, you are considered the producer, even if you did not manufacture the product or packaging yourself.

What is the de minimis threshold?

The de minimis threshold applies if your company places less than 8 tonnes of packaging per year on the Danish market.

It is important to understand that:

• You are still covered by EPR, even below the threshold
• The threshold only affects how you report, not whether you are responsible

What does Total packaging mean?

If you are below the 8-tonne threshold, you can report your packaging as Total packaging.

This means:

• You do not need to split packaging into material types such as plastic, paper, glass, or metal
• You only report the combined total weight

This option makes reporting much simpler for smaller businesses.

What is a micro company?

A micro company is typically defined as a business with:

• Fewer than 10 employees
• Annual turnover below €2 million

Being a micro company does not automatically mean you are exempt from producer responsibility, but in some cases, you may not be responsible.

When you may be exempt

You can be exempt from producer responsibility if:

• Your packaging is produced by a Danish supplier, and
• The supplier places the packaging on the market under your name or brand

In this case, the Danish supplier often carries the responsibility.

When you are still responsible

You will typically still have producer responsibility if:

• You import packaged goods into Denmark

Even as a micro company, you are then considered the one placing packaging on the market, and therefore responsible.

What this means in practice

Responsibility depends on how your products and packaging enter the Danish market, not just your company size.

A simple rule of thumb is:

• Using a Danish supplier means you may be exempt
• Importing packaging or goods means you are likely responsible

Because of this, it is important to double-check your setup, even if your business is very small.

Important: Micro companies and the de minimis threshold are different

These two concepts are often confused, but they are not the same.

• A micro company is defined by company size (employees and turnover)
• The de minimis threshold is based on packaging volume (8 tonnes per year)

You can be a micro company above the threshold, or a large company below it. Each rule applies independently.

What do you need to do?

If your company has producer responsibility in Denmark, there are a few key steps you need to follow.

• Register with DPA, join a collective scheme, and track your packaging accurately
• Report correctly and pay EPR fees based on volume and material requirements

The detailed checklist is below.

Step-by-step checklist

If your company has producer responsibility in Denmark, follow these steps:

1. Register with DPA

You must register with Dansk Producentansvar (DPA), which is the official authority for producer responsibility in Denmark.

2. Join a collective scheme

Most companies choose to join a collective compliance scheme.

These schemes:

• Handle recycling obligations on your behalf
• Help with reporting
• Charge fees based on your packaging volumes

https://producentansvar.dk/en/products-and-responsibility/organising-your-producer-responsibility/compliance-schemes/

3. Track your packaging

You need to keep records of how much packaging you place on the market.

If you are below 8 tonnes per year, reporting total weight is sufficient. If you are above the threshold, you must break it down by material types.

4. Report your data

You must report your packaging data to two places.

To DPA, you report once per year.

To your collective scheme, reporting frequency depends on your volume:

• Monthly reporting if you are above 8 tonnes per year
• Quarterly reporting if you are below 8 tonnes per year

5. Pay EPR fees

You will pay fees to your collective scheme based on your packaging volumes and, if applicable, material types. These fees fund the collection and recycling of packaging waste.

Final thoughts

Danish EPR rules apply to more companies than many expect, especially due to e-commerce and international trade.

The key things to remember are:

• Responsibility depends on your role in the supply chain, not just your company size
• Micro companies are not automatically exempt
• The 8-tonne threshold affects reporting requirements, not whether you are covered

If you are unsure whether the rules apply to you, it is always a good idea to review your setup carefully. Getting it right early can save both time and cost later on.