EPR COMPLIANCE GUIDE
Denmark
This document provides an overview of your obligations under the Danish Extended Producer Responsibility (EPR) system for packaging. It outlines who is responsible, which packaging types are covered, applicable fees, and how Embacollage supports you in staying compliant.
EPR for Packaging in Denmark
What You Need to Know
From 1 January 2025, Denmark is introducing Extended Producer Responsibility (EPR) for packaging, in line with EU legislation. This means companies placing packaging on the Danish market will be legally responsible for its collection, recycling, reporting, and the related costs.
Below we explain what this means for your company and the steps you need to take to stay compliant:
1. What is Extended Producer Responsibility (EPR)?
Extended Producer Responsibility (EPR) is a legal framework that holds companies accountable for the packaging they place on the Danish market. If you use or distribute packaging in Denmark — especially with your own brand or logo — you are considered a “producer” and must fulfil certain obligations.
If you order packaging from our standard collection (without your branding), Embacollage is considered the producer, and we take responsibility for compliance with all EPR obligations.
Under EPR, producers are responsible for:
- Registering with the Danish Producer Register (DPA)
- Reporting packaging volumes and material types placed on the market
- Financing the collection, recycling, and disposal of packaging waste and sign up with acollective scheme
- Labelling packaging with sorting/recycling information (currently recommended)
The goal of EPR is to:
- Reduce packaging waste
- Encourage the use of recyclable materials
- Promote a more circular, sustainable packaging system
2. Who Is Legally Responsible for Packaging under EPR Rules?
Under Danish EPR law, the “producer” is the company that places product packaging on the Danish market or fills service packaging with goods for the first time and/or owns the brand printed on the packaging.
| Scenario | Who is Responsible (Producer)? |
|---|---|
| Packaging with your brand/logo | You – You are responsible as the brand owner |
| Packaging with Ebacollage's brand/logo | Embacollage – We are responsible, regardless of use |
| Packaging for food/cosmetics/jewelry | You – You must ensure registration and address labelling |
| Transport Packaging left by a supplier at your premises | Supplier – If they import and place it on the market |
Important: If your logo, brand name, or design is printed on the packaging — you are legally the producer, even if Embacollage supplies it to you unfilled.
3. Are You a Microbusiness? Special EPR Rules May Apply
If your company has:
- Fewer than 10 employees, and/ or
- Annual turnover below DKK 15 million
… you are considered a microbusiness under Danish EPR rules.
As a microbusiness:
- You may be exempt from full producer responsibility
- But: You must declare this status to us in writing
- Otherwise, you will remain responsible for registration and reporting under EPR
If we (Embacollage) produce packaging with your logo and you are a microbusiness, we may be responsible for reporting that packaging — but only if we receive a signed declaration from your company confirming your microbusiness status.
We cannot assess each customer’s company size, so we rely entirely on your official confirmation.
Please complete and return the Microbusiness Declaration Form provided attached.
4. Which Packaging Types Are Affected by EPR?
EPR in Denmark applies to multiple categories of packaging depending on their use and the point of contact with the end-user.
The main categories are:
| Type | Description | Examples |
|---|---|---|
| Primary | Sales packaging (in direct contact with product) | Wrapping paper, boxes |
| Secondary | Multipack or grouped items | Carrier boxes, trays |
| Tertiary | Transport packaging | Shipping cartons, pallets |
| Service Packaging | Filled at point of sale or pre-sold empty | Coffee cups, food paper, paper bags |
| SUP Packaging | Single-use plastic items (requires extra attention) | Drinking cups, food containers |
5. EPR Fees & Charges – What Applies and Who Pays
EPR in Denmark involves several types of fees. The exact amount depends on your packaging type, volume, and your role under the law (producer or not). Below are the main cost elements.
5.1. Fixed Compliance Fees
| Cost Type | Details |
|---|---|
| DPA Registration Fee | DKK 1.000 for new registrants / DKK 500 for companies already registered in the DPA |
| Annual Administration Fee | Most coææective schemes charge approx. DKK 1.900 for annual membership (covering reporting for small volumes up to 200 kg). For standard products, this is included in the environmental fee. |
| Authorised Representative | Required for companies without a Danish CVR number. Costs vary depending on provider. |
5.2. Environmental Fees – Overview & Responsibilities
Environmental fees are calculated per kilogram of packaging, based on the packaging material and recyclability. Who pays depends on whether the packaging is standard or customized:
- For standard packaging from Embacollage’s collection, Embacollage is the producer and includes these fees per order on your invoice.
- For customized packaging, the brand owner is responsible for calculating and paying the fees directly to their selected collective scheme — unless they are a microbusiness, in which case Embacollage may handle this on their behalf.
5.3. Environmental Fee & Price Table for Embacollage’s Standard Collection
For packaging from Embacollage’s standard assortment, Embacollage is the producer. Fees are calculated based on weight, material type, and reporting category. These costs are added per order and shown transparently on the invoice.
Price Table – Reference Overview (DKK/kg, excl. VAT)
5.4. Environmental Fee – Customized Packaging
If you use customized packaging (e.g. with your logo or design), you are considered the producer and must manage your own EPR obligations.
If you qualify as a microbusiness, Embacollage may offer to calculate and pay the environmental fees on your behalf. These costs will then be added to your invoice transparently.
6. Recommended Labelling for Sorting & Recycling
While not yet mandatory for all packaging types (except certain single-use plastics), authorities recommend using standard recycling codes and sorting instructions to support proper waste separation.
| Material | Recommended Code | Example Label |
|---|---|---|
| Kraft/Paper bags | ♻ PAP 22 | "Sort as paper" |
| Cardboard boxes | ♻ PAP 20 | "Cardboard – sort correctly" |
| Coated paper | ♻ PAP 21 | "Sort as paper – coated" |
| LDPE plastic | ♻ LDPE 4 | "Plastic – soft" |
| HDPE plastic | ♻ DHPE 2 | "Plastic – hard" |
| Compostable plastics | ♻ OTHER 7 | "Compostable – DIN EN 13432 certified" |
We can pre-print these codes and sorting instructions on your packaging — just let us know.
Nordic pictograms and EU-wide labelling rules are being finalized and expected soon.
7. EPR Requirements for Foreign Sellers and Online Stores
You need an Authorized Representative if:
- You're based outside Denmark AND
- You sell directly (B2C or B2B) to Danish customers
8. Non-Compliance Risks
- Fines up to €25,000
- Legal ban from selling in Denmark
- Removal from marketplaces (Amazon, Zalando, etc.)
9. Final Compliance Checklist – What You Must Do
1. Register with the Danish Producer Register (DPA)
- Danish companies: require MitID Erhverv
- Foreign companies: must appoint an Authorized Representative (e.g. a collective scheme partner)
2. Report your estimated yearly packaging volumes:
- By material and weight (paper, cardboard, plastic types, glass, metal, etc.)
- Household vs. B2B use
- If you are under 8 tonnes per year, you can report the totals only
3. Select a collective scheme to manage your obligations (collection, recycling, reporting)
4. Label your packaging appropriately (see below)
We’re here to support you with compliant packaging, labelling, and advice. If you have any questions — or if you'd like us to include recycling symbols on your packaging — just reach out.
