Who has producer responsibility for packaging?
Are you unsure whether you have producer responsibility for packaging? The rules depend on the type of packaging and your role in the value chain. Get an overview and find out whether the responsibility lies with your company.
Determining who has producer responsibility for packaging can be challenging. However, the main rule is simple: your company has producer responsibility if you are the first business to make the packaging or the packaged product available on the Danish market.
Producer responsibility means that the responsible company must finance and ensure the management of the packaging once it becomes waste. Therefore, the company that manufactured the packaging is not necessarily the one that bears the responsibility. Producer responsibility depends, among other things, on the type of packaging and on who makes the packaging available on the market. It is therefore important to understand the rules for the different packaging types.
Foreign companies may be subject to producer responsibility in Denmark if they sell packaged products directly to Danish end users. This applies to sales to both consumers and businesses when the customer is the end user of the product.
Main rules for the different packaging types
Who bears producer responsibility depends on the type of packaging:
Transport packaging: You have producer responsibility if you make the empty transport packaging available on the Danish market for the first time.
Service packaging: You have producer responsibility if you make available empty packaging intended to be filled at the point of sale, such as coffee cups or pizza boxes.
Sales packaging: You have producer responsibility if you fill empty packaging with a product or import and subsequently make available on the market already filled sales packaging.
Multipack packaging: You have producer responsibility for the multipack packaging if you assemble or pack multiple sales units in a shared package and resell them.
There are exceptions to these main rules. These include packaging made available under your own design, name, or trademark, as well as special rules for micro-enterprises. Such exceptions may affect whether producer responsibility lies with your company or another business in the value chain.
Exceptions and key concepts
When Do You Make Packaging Available on the Market?
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Do you have producer responsibility as a micro-enterprise?
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What you need to know when purchasing goods from abroad
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What you need to know as a packaging distributor.
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See illustrations showing which companies have producer responsibility.
On the website of the Danish Environmental Protection Agency, you can view illustrations showing how different types of packaging move through the value chain and where producer responsibility is assigned. These illustrations help you understand which companies are subject to producer responsibility.
View the Danish Environmental Protection Agency’s illustrations.