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Products and responsibility

Reporting

For selected product areas there is a statutory requirement that producers report data on product quantities to DPA. Requirements for data differ from one product area to another, so it is important that you keep yourselves informed about the rules. In the following we give a general introduction to the purpose and principles for reporting.

Portable batteries and SKAT

Portable batteries and SKAT

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

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

What does reporting mean?

In certain periods every year all registered businesses must report quantities put on the market, taken back and treated for the previous period. Collective schemes usually report to DPA on behalf of their members.

DPA – data collector

DPA has been set up to establish systems supporting the monitoring of the targets set up in EU directives and associated national law. We give 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 products covered by producer responsibility. The aim is to attain better utilisation of valuable resources contained in the large amounts of waste from these products. Furthermore, the purpose is to monitor product flows to avoid illegal waste shipments and inappropriate and environmentally harmful disposal methods.

Kalender

Key terms in reporting:

Packaging
Packaging is reported in kilograms.

Single-use plastic products (including tobacco product filters)
Reporting of single-use plastic products depends on category:

  • Food containers in kilograms
  • Packets and wrappers in kilograms
  • Beverage containers in kilograms
  • Cups for beverages in kilograms
  • Lightweight plastic carrier bags in kilograms
  • Wet wipes in units
  • Balloons in units
  • Tobacco product filters in units

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
Reporting of vehicles is done in units.

See also the current reporting

Quantities put on the market

Also called quantities made available.

‘Make available’ is defined as the supply of, for instance, empty packaging, or filled packaging in view of distribution, consumption, or use on the Danish market as part of a commercial activity, be it with or without remuneration.

As a registered business you must report every year how much your business has put on the market, i.e. sold in Denmark, in the previous period (typically a quarter of a year or a calendar year). Quantities put on the market must be reported in kilograms or units broken down on registered categories.

Reduction quantities (refund for re-export)

For a few product areas legislation makes it possible to reduce quantities put on the market with quantities exported by a subsequent level in the sales chain.

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.

Transfer of responsibility (for electronic equipment and batteries)

Producers or importers 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 two 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.

Read more here: https://producentansvar.dk/documents/ansvarsoverdragelse-af-tilbagetagningspligten-for-weee-og-bat/

Quantities collected or taken back

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 put products on the market 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 products that citizens discard at the municipal recycling centre.

Reporting must cover quantities of electronics, batteries, packaging, and fishing gear collected and taken back.

Important to report any products you take back

The quantities of waste 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.

Environmentally treated quantities (electronics and batteries)

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 scheme – have used.

Authentication of your report (electronics and batteries)

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 must report to DPA is used for the following statutory purposes as described under the links below, but your reporting is also important to your own business.

Requirements for publication of your environmental performance

There are a number of minimum requirements 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.

Deactivation

If you do not report

Important! If you do not attend to the annual reporting, your business will be deactivated, i.e. inactivation from the register. In such case it is no longer legal to put 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.

Inactivation

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

Read the guidelines with a step-by-step review of the reporting procedure for electronics, batteries, and vehicles.

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