EPR Registration with Authority
Required. The producer must register in the Danish Producer Responsibility (DPA) producer register no later than 14 days before making the packaging available.
EPR Scheme / PRO
Competing PROS
Are PROs legally required to have a not-for-profit objective?
No.
Authorised Representative
Required for producers established outside Denmark
AR applicable date
Applicable throughout 2026 under Denmark’s packaging producer-responsibility framework. The PPWR’s general application date is 12 August 2026; Denmark’s national registration and authorised-representative mechanism was already operating before that date.
Packaging Covered
Household packaging (B2C)
Industrial packaging (B2B)
Packaging Categories: Normal Packaging, Packaging sorted as hazardous, Packaging sorted as residual
De-minimis Threshold
No general quantity-based de-minimis exemption from packaging EPR registration. The 8-tonne threshold is a simplification threshold, not an exemption: producers below 8 tonnes per calendar year may use simplified quantity reporting and are generally outside mandatory fee modulation unless they request modulation.
Small Producer / SME Rules
Under 8 tonnes/year, simplified annual reporting may be used (total weight, with the required household/commercial split) and mandatory eco-modulation generally does not apply unless the producer requests it. There is no general SME exemption from registration. Danish EPA guidance also notes that PPWR micro-enterprise rules do not remove all obligations; in particular, a micro-enterprise importing packaging or packaged products and then making them available in Denmark remains within producer responsibility.
Reporting Frequency (depending upon volume)
8 tonnes/year: Monthly reporting. < 8 tonnes/year: Quarterly reporting through most collective schemes. In addition, an annual statutory report is submitted to DPA.
Reporting Period
Calendar year/previous-year reporting.
Applicable?
Yes
Effective Date
The Danish packaging EPR fee-modulation framework became operational in 2025 and continues in 2026 under BEK no. 1146 of 29 September 2025. Packaging collective schemes use modulated fees from 2025.
Criteria
Annex 14 uses design-for-recycling criteria and assigns packaging/material subcategories to fee levels: three levels (green/yellow/red) for some categories and two levels (green/red) for others. If a required design criterion cannot be documented, the packaging is placed in the red level. Red packaging is subject to a 35% surcharge on the calculated operational waste-management cost; surcharge revenue is used to reduce contributions for better-performing packaging within the same subcategory, subject to the statutory minimum contribution rules.