11. June 2025
As part of its regular series on Extended Producer Responsibility (EPR) in Europe, RIGK takes a close look beyond Germany’s borders. The aim is to keep customers and partners informed about current developments in other countries – especially regarding obligations for the packaging industry. RIGK strongly welcomes the fact that countries such as Denmark are now taking the next step towards full implementation of EU requirements: Harmonised rules support cross-border resource protection and make it easier for companies to meet their responsibilities.
Until recently, Denmark followed its own path: instead of a comprehensive EPR system, packaging regulation for decades was based on a packaging tax. EMBAL Act introduced levies on specific single-use packaging – including non-deposit beverage containers, carrier bags, and PVC food films. However, commercial packaging was excluded.
With the implementation of the EU Packaging Directive, that is now changing fundamentally: Denmark is transitioning from this tax-based approach to a comprehensive EPR system, which will enter into force on 1 July 2025. The legal basis is Act No. 807 of 9 June 2020, amending the Environmental Protection Act to establish EPR obligations for all packaging types.
Since 1 April 2024, all producers placing packaged products on the Danish market must be registered with the Danish Producer Responsibility Register (DPA). The registration deadline for companies already active in Denmark was 30 June 2024. The registration fee is 1,000 DKK (€134), or 500 DKK (€67) for companies already registered in other categories (e.g., electronics or batteries) (AHK Denmark).
The first packaging volume declaration for 2023 was due by 30 September 2024. Companies placing less than 8 tonnes of packaging per year report only a total volume. Above 8 tonnes, a detailed breakdown by material type (e.g., plastics, glass, paper) and packaging type (primary, secondary, tertiary, or service packaging) is required (DPA guidelines).
As of 1 July 2025, companies must ensure that their packaging is collected and recycled. This can be done individually – with appropriate documentation – or via a recognised collection system. Currently registered systems with the DPA include:
Household packaging will continue to be collected by municipalities, which will now be compensated by the systems – expected to gradually reduce waste fees for residents. Commercial packaging will remain in the hands of private waste operators, who are also expected to receive future compensation from the systems. Further details are pending (Emballageretur).
Foreign companies not registered in the Danish CVR company register must fulfil their EPR obligations through an authorised representative in Denmark. (DIHK_Approach to packaging in europe)
With the full implementation of its EPR system, Denmark is making a significant step towards the EU-wide harmonisation of packaging regulations. This brings greater clarity for internationally active companies – and for the environment: greater responsibility. RIGK strongly supports this development and remains available as a trusted partner for information, implementation, and knowledge exchange.
Further information:
Leon Becker
Customer Relationship Manager / Funding Projects Manager
+49 611 308600-21
becker(at)rigk.de
