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Products and responsibility

Annual reporting

Reporting, taking place in the period 1 January to 31 March, can be compared with your annual tax return based on product volume, and not money. In the following we give a general introduction to the common purpose and principles for the report for all product areas. Please note that those of you who deal in portable batteries are subject to special requirements.

Portable batteries and SKAT

Portable batteries and SKAT

Imported portable batteries must be registered and reported through SKAT (the Danish Tax and Customs Administration)

See particular issues relating to portable batteries
Reporting for vehicles is slightly different

Reporting for vehicles is slightly different

Read more about reporting for vehicles: Danish motor vehicles register, DUS, and car breakers’ reporting

See particular issues relating to vehicles

Annual reporting takes place in the period from 1 January – 31 March

Every year in this period all registered businesses must report quantities in kilograms placed on the market (i.e. quantities of electrical products sold on the Danish market), along with products taken back and treated during the previous calendar year, if any. Compliance schemes usually report to DPA on behalf of their members.

IMPORTANT!!! If you do not attend to the annual reporting, your business will be deleted from the register. In such case it is no longer legal to place this type of products on the market in Denmark, just as the business cannot be searched out by dealers, customs duties, authorities, tendering organisations, etc.

DPA – data collector

DPA has been set up to establish systems supporting the monitoring of the targets set up in the directives and associated national law, giving at the same time producers the best opportunities for contributing actively to the attainment of those targets in their commercial activities.

Old products are new resources

The overall purpose is to enable environmental authorities in Denmark and the EU to survey material flows from end-of-life electrical equipment, batteries, and vehicles. The aim is to attain the best possible utilisation of valuable resources contained in the huge amounts of waste from this type of products. Another purpose is to monitor product flows to avoid illegal waste shipments and inappropriate and environmentally harmful disposal methods.

Kalender

Key terms - nice to know:

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 compliance 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.

Your data and environmental targets

The information you report to DPA is used for many statutory purposes. However, your reporting is also important to your own business.

Requirements for publication of your environmental performance

As from 2021 a number of minimum requirements have been introduced for businesses subject to producer responsibility.  One of these requirements is that you must publish how your business complies with the environmental targets for take-back and recycling of your end-of-life products.

Find your environmental targets

Once you have made your reporting and signed the declaration you can go to the menu item “Annual report” in the DPA producer register; here you can see the calculation of the rate of recycling and recovery that the system has made based on your reporting. The rates obtained are compared with the current EU targets so you can see whether you comply with the current environmental targets.

Shortcuts

Information pages for the current reporting

See specific information page to be used for this year’s reporting

Guidelines for Registration and Annual Reporting

Step-by-step document : Guidelines for registration and reporting 2022.

Authentication of quantities

See the guidelines for auditor’s attestation and management’s statement regarding electrical products

Refund for re-export

Document describing rules about refund for re-export

Changes and additions to reported quantities and data

See guidelines regarding changes and additions to reported quantities and data

EU requirements for reporting

Read the EU Commission’s and EUROSTAT’s statutory documents and guidelines on requirements for Member States’ reporting

Statistics and Environmental targets

See the environmental targets set up by the EU