Introduction

As Extended Producer Responsibility (EPR) laws vary by country, the goal of our series is to demystify the nuances of EPR in specific markets. Earlier in the year, we launched our EPR series by focusing on the UK: EPR, Eco-Modulation and RAM. Today, we’ll take a deep dive into EPR in Denmark. 

The significant regulatory framework aligns with the EU directives, especially the PPWR model. The previous tax-based system was a weight-based tax on certain types of packaging, with the goal of reducing material use. This approach was not as comprehensive, as it excluded many types of commercial packaging and did not directly connect fees to the costs of collecting and recycling waste.

This guide aims to break down the complex, moving parts of Denmark’s new system into clear, actionable information, so brand owners understand what they need to do to stay compliant.

Keep reading to learn more about the new EPR system in Denmark, how eco-modulation works, and the steps your brand needs to take to stay compliant.

EPR Denmark

What is the institutional context of EPR in Denmark?

There are three main organisational levels involved in the Danish EPR system that oversee the Danish EPR scheme:

• Danish Environmental Protection Agency (Miljøstyrelsen): This body acts as the policymaker and ultimate regulator.

• Dansk Producentansvar (DPA): This is the regulatory authority and overseer of the system.

• VANA (and other Producer Responsibility Organisations (PROs)): These are the collective schemes responsible for the operational implementation of the EPR system. Vana is the largest PRO and determines fees based on operational costs, excluding administrative expenses.

The new system is codified in the Emballagebekendtgørelsen (Packaging Order - BEK no. 323 of 20/03/2025). This regulation replaced earlier regulations and includes a producer register, provisions for managing packaging waste, and requirements for producers regarding the takeover and management of packaging waste.

When do the payment obligations begin?

Legal obligation begins: 1 July 2025 

From this date, producer responsibility for packaging officially applies in Denmark. Any packaging your company places on the market from July through September 2025 will be subject to EPR fees. You are legally and financially responsible for everything sold in this period.

First accrual period (Q3 2025): 1 July – 30 September 2025 

This is the first quarter in which fees will accumulate based on the packaging you put on the market.

First invoicing period begins: 1 October 2025 

Producer Responsibility Organisations (PROs), such as VANA, will start issuing invoices every quarter. The invoices sent in October will cover the costs for the packaging your company placed on the market during Q3 2025.

Who is obligated to report packaging data?

Producers are obligated to register within the system. The EPR fees, as determined by a collective scheme like VANA, are based on whether packaging is for household or commercial use. Companies distributing a total of eight tonnes or more of packaging materials into the Danish market per year must report the weight for each material fraction. 

Companies distributing less than eight tonnes have the option to report and be billed on a fraction-by-fraction basis or on average.

Registration and Reporting Obligations

Who must register, report and by when?

All companies defined as "producers" must register. This includes anyone who fills and packages products in Denmark, importers of packaged goods, and even foreign companies selling packaged goods directly to end-users in Denmark (e.g., e-commerce).

All companies placing packaging on the Danish market must register in the publicly accessible Danish Producer Register, maintained by the Danish Producer Responsibility (DPA). 

All companies placing packaging in Denmark must register with the DPA at least 14 days before placing packaged products on the Danish market. 

Once registered, all producers are required to report their packaging volumes:

• Over eight tonnes annually: companies must submit a detailed report, broken down by packaging material type and weight.

• Under eight tonnes annually: companies may submit simplified reporting, limited to total weights only. These companies are still required to pay fees.

The reporting deadline is March 31st each year, covering the packaging volumes placed on the market in the previous calendar year. All quantities must be reported in kilograms (kg).

It is crucial to distinguish this official annual deadline from your operational reporting. While the legal report to the DPA is annual, your chosen PRO, such as VANA, will require you to report your packaging data much more frequently—on a monthly or quarterly basis—to calculate your regular fee payments.

Who do producers report packaging data to?

Reporting is done to PROs, which then submits the data to the DPA register/authorities.

How is the recyclability of packaging evaluated under eco-modulation?

Packaging is assigned to modulation levels depending on how it meets or fails certain design criteria:

Three-level materials (e.g., plastic, glass, metal, paper):

• Green level: Meets all “green” criteria and none of the “red” criteria -> receives a fee discount.

• Yellow level: Meets yellow/green criteria, but not red -> pays the base fee.

• Red level: Meets one or more “red” criteria -> incurs a 35% surcharge.

Two-level materials (e.g., aluminium, steel, other materials, composite, other):

• Green level: Meets green criteria, no red criteria -> base fee applies.

• Red level: Meets one or more red criteria -> 35% surcharge.

What is the fee structure?

Fee structure: The surcharges paid for red-level packaging are used to finance the discounts given to green-level packaging within the same material category.

Minimum fee: All packaging must pay a minimum of 20% of the operational costs.

Penalty for missing data: If required documentation is not provided, the packaging is automatically placed in the red category, incurring the highest fee.

Component-Based Assessment

Packaging components are classified as separate, integral, or main based on how they attach to the primary packaging unit.

For example, a rigid PET bottle is assessed based on whether its caps, labels, or sleeves can be separated and recycled with the main body of the bottle.

Who is Affected?

The eco-modulation system applies to companies that place more than eight tonnes of packaging on the market annually.

Exemptions are in place for small producers and certain medical packaging.

Important Note for 2025

For the current reporting period in 2025, green-level and yellow-level packaging will pay the base price. Any potential bonus for green-level packaging will be paid in June 2026.

Financial Obligations

What are the fees involved?

Producers have financial obligations to several bodies:

To VANA (Waste Management Organisation):

• Waste handling fees: These fees are determined by VANA and published quarterly, with current fees applicable from 1st October 2025.

• Annual base contribution: This is 1,000 DKK, though it has been reduced to 500 DKK for 2025.

To the Danish Environmental Protection Agency (EPA):

Supervisory fee: This fee covers compliance monitoring, waste content analysis, and awareness campaigns.

The 2025 rate is 0.025 DKK per kg of packaging waste, based on 2024 reported quantities.

To Dansk Producentansvar (DPA):

• Administrative fee: This fee covers responsibility distribution, reporting guidance, and coverage determinations.

• Registration fees: These are required for initial registration and annual renewals, though the amount and timing have not yet been published.

Client FAQs

Question 1

How come that while companies are required to report yearly on previous year's packaging, VANA requires monthly reporting?

Answer

The difference is due to the distinct needs of VANA, the Producer Responsibility Organisation (PRO), as a separate entity from the Danish authorities. VANA's operational requirements for managing waste and recycling processes for its members necessitate more frequent data collection. More frequent reporting is required for the following reasons:

• Improved accuracy: More regular reporting results in more precise data collection.

• Enhanced forecasting: Frequent data helps VANA to better plan for the required collection and recycling capacities.

• Streamlined invoicing: It enables a more consistent and predictable invoicing cycle for EPR fees.

While the legal reporting obligation to the Danish authorities is annual, your contractual agreement with VANA requires adherence to their more frequent schedule to maintain compliance through their scheme.

Question 2

Where does the responsibility lie for FMCG multinational companies not registered in Denmark?

Answer

It all comes down to whether the company falls within the definition of a ‘producer’. 

Once a company does, it must register and take on the related responsibilities. In simple terms, the obligation lies with the entity that first places the packaging on the market. This means the company that initially makes the product available for distribution, consumption, or use in Denmark.

Question 3

What if we do not have specific information about attributes like colour of our packaging? Are we automatically classified in the red category?

Answer

Essentially, this shows the importance of increasing data quality for accurate reporting. The system is designed to penalise packaging that disrupts recycling and reward packaging that is easy to recycle. It works on a principle of "guilty until proven innocent." 

You must be able to actively demonstrate and document that your packaging meets the specific "design for recycling" criteria to fall into a yellow or green category. Without the respective data points this demonstration is not possible which in turn means that the default is the most expensive red category.

Recyda’s Software: EPR Compliance in Denmark

We’re excited to share that our software now includes full support for EPR Denmark. 

This enables you to seamlessly calculate, report and declare EPR for Denmark through one centralised platform, making it easier than ever for producers to evaluate and report the EPR requirements of their packaging in alignment with these obligations.

The benefits of this development include:

Simplifying compliance - The Danish EPR system introduces detailed packaging rules that can be difficult to interpret correctly. Our software translates these requirements into clear guidance, helping companies comply without the risk of costly errors or penalties.

Time and Resource Optimisation - Our intuitive system removes the stress of relying on time-consuming Excel sheets by automatically assessing all your packaging components. Our platform automates forecasts, fee calculations, and reporting. This not only saves teams hours of work but also reduces the likelihood of mistakes.

Bridging the gap between company data and legal requirements - Many companies struggle to match their internal packaging data to what regulators demand. Our in-house experts interpret the Danish rules and build them into the software, ensuring declarations are aligned with legal expectations.

Future-proofing reporting - EPR rules are not static; they continue to evolve and expand across Europe. With Recyda’s system, companies don’t have to constantly monitor regulatory changes themselves, the software adapts as rules shift, providing confidence that compliance processes remain up to date.

Reducing costs through portfolio-wide insights - Beyond compliance, our software enables companies to analyse their packaging portfolio. This means identifying ways to make packaging more recyclable and ultimately lowering EPR fees in the long term.

All in all, our platform enables you to efficiently evaluate your whole portfolio simultaneously, helping you report EPR reporting and compliance accurately and avoid over- or under-reporting.