Skip to content
Search
Frontpage
What you need to know as a packaging distributor.

What you need to know as a packaging distributor.

Learn when you are considered a packaging distributor, when you may be subject to producer responsibility, and the requirements and obligations associated with the role.

What is a distributor?

You are considered a distributor if you make packaging or packaged products available on the market without being the manufacturer or importer.

Typically, you are a distributor when a product is manufactured in another EU country and you are the first company to make it available on the Danish market. As a distributor, you are part of the supply chain that passes packaging or packaged products on to other businesses or end users, without being the manufacturer or importer yourself.

You may have producer responsibility as a distributor

Being a distributor does not necessarily exempt you from producer responsibility. For packaging, companies acting as manufacturers, importers, or distributors may be subject to producer responsibility if they are the first link in the Danish value chain to put packaging or packaged products on the market.

You will typically have producer responsibility if you:

  • Purchase packaging or packaged products from another EU country and sell them in Denmark.
  • Purchase packaged products in one EU country and sell them directly to end users in another EU country. In these cases, you may become subject to producer responsibility in the EU country where the end user is located.
  • Have packaging manufactured according to your specifications or have your name or trademark applied to the packaging.
  • Modify the packaging, for example by repackaging the product in new packaging.

Manufacturer, Importer, or Distributor?

Are you unsure which role your company has? On the website of the Danish Environmental Protection Agency, you can learn more about the differences between manufacturers, importers, and distributors, and gain an overview of the rules and obligations associated with each role.

Learn more about these roles on the Danish Environmental Protection Agency’s website.

How to comply with the rules as a distributor

  1. Register your company if you are subject to producer responsibility.
    If your company is subject to producer responsibility for packaging, you must register it in the Danish producer register. If you do not have producer responsibility yourself, you must ensure that the producer of the packaging is registered.

  2. Verify that the packaging complies with the applicable requirements.
    Before making the packaging or the packaged product available on the market, you must ensure that the packaging complies with the applicable requirements. Among other things, you must verify that the packaging bears an identification number and that the contact details of the manufacturer and, where relevant, the importer are provided.

  3. Do not make packaging available on the market if it does not comply with the applicable requirements.
    Do not make packaging available on the market if it does not comply with the applicable requirements. If you have reason to believe that the packaging does not comply with requirements relating to PFAS, hazardous substances, or other applicable sustainability requirements, you must not make it available on the market until the non-compliance has been rectified.

  4. Take action if you identify non-compliance.
    If you become aware that packaging does not comply with the applicable requirements, you must take appropriate action. This may include suspending sales, ensuring the packaging is withdrawn from the market, or notifying the relevant authorities.