Who is the end user of packaged products?
Whether you are the end user of a product affects who assumes producer responsibility for the packaging. It is therefore important to understand how the term “end user” is defined in the Packaging and Packaging Waste Regulation (PPWR).
What does end user mean?
Under the Packaging and Packaging Waste Regulation (PPWR), an end user is a person or business that receives a product for its own use and does not subsequently make that product available on the market in the same form.
The key consideration is whether you are the final user of the product. When assessing whether you are an end user, you should therefore focus on the product itself and not on the packaging surrounding it.
In short, you are the end user of a product if you use it without reselling it or otherwise making it available on the market in the form in which you received it.
What does this mean in practice?
If you import packaging or packaged products into Denmark for resale, you are not the end user of the products. As a general rule, you will therefore assume producer responsibility for all packaging associated with the products, including transport packaging.
Example: If you purchase paprika from abroad and resell it as a spice, you are not the end user of the product. This is because you make the product available on the market in the same form in which you received it.
If you purchase products from a supplier outside Denmark for use within your own business, you are considered the end user of those products. In that case, producer responsibility for the packaging generally rests with the non-Danish supplier.
Example: If you purchase paprika from abroad and use it as an ingredient in the production of salami, you are the end user of the product. The paprika is used in your own production process and is not made available on the market in the form in which you received it.