Who is obligated?
Based on the final legislation published in March 2024, all parties who place items on the market are subjected to the EPR obligations, regardless of the sales technique used.
This means all manufacturers, distributors and importers are to register with the Danish Authority and a PRO before the end of August 2024. This includes producers importing packaging for their own usage. Distance sellers have to register according to the same deadline, however, an authorized representative is needed in order to comply.
What is to be reported?
- All packaging is in scope of the legislation, regardless of the usage. This means that primary, secondary and tertiary packaging has to be reported under the law regardless of the origin of the waste: households or industrial.
- Packaging subjected to a DRS – deposit return system- is excluded.
- All producers placing more than 8 tonnes of packaging on the market per year, are to report on a detailed level: main material with a sub division in the plastics materials.
- Producers below the threshold are to report on the total quantity placed on the market per year.
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Source: ERP Denmark
Roos Mijnen
Environmental Compliance Specialist