Extended producer responsibility for packaging: what you need to do

If you sell products in packaging, there is a good chance you are already subject to the rules on extended producer responsibility (EPR) for packaging. Unfortunately, many small and medium-sized business owners only find out when a letter arrives from the authorities.

What is extended producer responsibility for packaging?

Extended producer responsibility (EPR) is a principle that makes producers and importers accountable for what happens to a product after the consumer has used it. For packaging, this means that your business is responsible for ensuring that the packaging you place on the market is actually collected and recycled.

The rules originate from the EU Packaging Directive and have been implemented in Danish law through the Environmental Protection Act and associated statutory orders. From 2025, requirements have been tightened and more types of businesses are now directly obligated.

The core of the legislation is straightforward: whoever places the packaging on the market pays for its disposal. This is typically financed through a collective scheme that you register with and pay a fee to, based on the volume of packaging you use.

Who is covered?

The overarching criteria are straightforward. Your business is covered if it:

• produces, fills, or imports packaging for the Danish market,
• sells packaged goods to end users (including through an online store), or
• uses packaging in a service (for example, takeaway containers or shipping cartons).

A minimum threshold applies for the smallest businesses, but it is lower than many people assume. From relatively modest quantities of packaging you are already required to report and pay. Even if your business is small, the likelihood is high that you are included if you sell physical goods in Denmark.

If you import goods from abroad in packaging and resell them domestically, the rules apply in full. The same is true if you are an e-commerce retailer shipping parcels to Danish consumers.

What types of packaging are covered?

The legislation casts a wide net. The following packaging materials are typically covered:

• paper and cardboard (shipping boxes, wrapping paper, cartons),
• plastic (plastic bags, blister packs, film, plastic bottles),
• glass (bottles and jars for food and beverages),
• metal (cans, aluminium foil, lids),
• wood (pallets, crates, boxes), and
• composite materials (for example, milk cartons with plastic coating).

It is not only outer transport packaging that counts. Sales packaging (the packaging the consumer sees in the store) and service packaging (for example, a coffee bag) are also included in your calculation.

What do you need to do?

Here is a practical checklist for business owners:

1. Map your packaging. Go through all the types of packaging your business uses or imports, and record the materials and quantities in kilograms per year.

2. Assess whether you exceed the minimum threshold. Check the applicable limits in the statutory order. If you are unsure, it is safer to assume that you are covered.

3. Register with a collective scheme. Most businesses register with an approved collective producer responsibility scheme (for example, DPA-System). The scheme reports and settles on your behalf.

4. Calculate and report your packaging volumes. You typically need to report once a year. The calculation is based on the volumes you placed on the market during the previous calendar year.

5. Pay the fee charged. The amount is calculated based on material types and quantities. The more packaging you use, the higher the fee.

6. Keep documentation. Retain invoices, weight documentation, and reports for at least five years. The authorities may request them.

Make sure to track changes in your packaging volumes from year to year. If your business grows, you can quickly move into a different category and end up paying more.

What happens if you do not comply?

Failure to register or inaccurate reporting can result in fees and, in serious cases, fines. The Danish Environmental Protection Agency and the approved producer responsibility schemes have the ability to audit businesses, and non-compliance is recorded. This is not an area you want to overlook, as regulatory attention in this field has increased significantly in recent years.

Frequently asked questions

Do the rules apply to me even if I only sell online? Yes. E-commerce retailers are fully covered when they ship goods in packaging to Danish consumers. Shipping packaging (cartons, filling material, tape) counts toward your total.

Do I have to organise the collection of the packaging myself? No. You register with a collective scheme that organises and finances collection and recycling. Your contribution is the fee you pay to the scheme based on your packaging volumes.

When do the rules take effect? The tightened EPR rules for packaging have been phased in from 2024 to 2025. If your business has not yet registered, you should do so as soon as possible to avoid falling into arrears.

Let Legiant keep track of it for you

The rules on producer responsibility for packaging are updated regularly, and it can be difficult to keep up when you already have a lot on your plate. Legiant automatically monitors the legislation and statutory orders relevant to your business and notifies you whenever something changes. You no longer have to spend hours scanning the Environmental Protection Agency's website and can focus on running your business instead. Try Legiant for free and see which rules apply to you specifically.