Annual reporting

Definition of weight applies to electronics and batteries:
You must always compute and report quantities in kilograms. This means the weight of the entire product (finished article) in the form it is sold to the user, including electronic accessories but WITHOUT batteries and accumulators (to be reported separately), packaging, and manuals.

If the battery is incorporated into an appliance the weight of the battery and that of the electrical equipment are stated separately. For batteries containing liquids (electrolyte) the weight is stated including liquid.

Vehicles in units
Reporting of vehicles is done in units.

See also the current reporting

Also called

marketed, sold…

The definition of “placed on the market” is:

transferring or making available to a third person with or without remuneration, including leasing. Equipment placed on the Danish market.

As a registered business you must report every year how much your business has placed on the market, i.e. sold in Denmark, in the previous calendar year. Quantities placed on the market must be reported in kilograms broken down on the categories you are dealing in, including whether the equipment is sold for professional use or whether end-users are private households. For batteries, you must also indicate the chemical substance group.

Refund for re-export

The Order allows for a refund for re-exported quantities.

If a quantity of products sold on the Danish market in a given year by a business subject to producer responsibility is subsequently and in the same year exported out of Denmark by another business, it is possible for the producer who originally registered the quantity in question in DPA to register the re-exported quantity. Documentation must be presented for the re-exported quantity.

Form used in cases of re-export

DPA will then give a refund for the re-exported quantity in our calculation of fees, financial guarantee, and allocation.

Re-export means a quantity of equipment sold on the Danish market that is exported out of Denmark by a subsequent level in the sales chain in the same year

Producers producing or importing products in view of professional use as well as automotive and industrial batteries may enter agreements with a subsequent level in the distribution chain about transfer of the duty of management when the product has reached its end of life. Under the reporting system this is called “quantities subject to transfer of responsibility”. Note that the producer responsibility in itself cannot be transferred.

So, you may agree with the end-user of the electrical equipment or the automotive or industrial batteries that he/she takes over obligations regarding collection and environmental treatment when the product reaches its end-of-life stage. Details on how to enter such agreements and how specifically to comply with the take-back duty are not described in the Orders. It is up to the parties to find the most suitable solution. This may, for instance, be stipulated in the purchase contract.

As an item under producer responsibility your business must make sure that waste electronics for professional use and/or end-of-life automotive and industrial batteries are treated at environmentally approved facilities. In addition, there are minimum requirements for recovery, reuse, and recycling that must be complied with.

All producers and importers have the duty (but not the right) to take back their products when they reach their end of life. If you sell products that may be used in private households your business is included in a calculation carried out by us in DPA. The calculation is called “allocation scheme” and concerns the pickup of end-of-life electronics and portable batteries that citizens discard at the municipal recycling centre.

Important to report any products you take back

The quantities of waste electronics collected from the municipalities and/or the quantities you take back yourself must be reported: your business is credited with the quantities taken back in relation to the quantities you have sold on the Danish market.

When end-of-life electronics and end-of-life batteries and vehicles are collected and treated there are certain requirements and environmental targets for how to manage this waste. In this connection, the following terms are used for treatment options; note that landfilling (disposal on a landfill) is the least desired.

NOTE! Incineration and landfilling of batteries are not allowed.

Treatment options:

• Recycling
• Incineration with energy recovery
• Disposal (landfill or incineration without energy recovery)

Recycling + incineration = recovery.
The rates for recovery and recycling are reported to the EU Commission in order to see whether environmental objectives are met in Denmark.

In the reporting you must state which recycling facilities you – or your collective scheme – have used.

Since your reported quantities are subsequently used to calculate fee rates, to report to the EU Commission, and to calculate whether we have attained the targets, it is important that they are as accurate as possible. There are different criteria for the control and validation of reported quantities; requirements relating to electronics cover either an auditor’s attestation or a management’s statement.

Regardless of the above, all registered businesses must digitally authenticate the report themselves once it is completed – and no later than 31 March.