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Packaging obligations in Denmark (2026)

Draft

Verified on: 2026-09-01

EU frameworkPPWR (EU) 2025/40, applicable since 12 Aug 2026

NationalMiljøbeskyttelsesloven (Environmental Protection Act) in conjunction with the Emballagebekendtgørelse (Statutory Order No. 1146 of 29 Sep 2025 on extended producer responsibility for packaging); register kept by Dansk Producentansvar (DPA)

Denmark only switched its packaging producer responsibility fully on as of 1 Oct 2025 (one of the last EU countries) – the system is new and was built with the PPWR in mind. One register (DPA) covers household AND commercial packaging; membership of a collective scheme is MANDATORY for packaging (no pure self-fulfilment). Household packaging is collected by the municipalities, whose costs the producers reimburse via the collective schemes (allocation model). Below 8 t of packaging/year there is only a SIMPLIFIED declaration (one aggregate category instead of a material breakdown) – not an exemption. Since 12 Aug 2026 the PPWR producer definition also applies: what matters is who commissioned/specified the packaging, no longer the physical brand imprint. Single-use plastic products (engangsplast) run through the same DPA register but are not separately covered here.

Packaging producer responsibility: DPA registration & collective scheme (Denmark)

Anyone first making packaging or packaged goods available on the Danish market – including foreign online sellers selling directly to Danish end customers – must register in the Danish producer register (DPA), MUST be a member of a collective scheme and must report the actually placed packaging volumes each year. EU/EEA sellers without a Danish establishment selling at a distance always need a bemyndiget repræsentant (authorised representative) with a Danish CVR number.

Authorised representative
Companies established in another EU/EEA state that sell directly to end users in Denmark (including online retail/distance selling) MUST appoint an authorised representative in Denmark: a legal person established in Denmark and actively registered in the CVR. Procedure: create the registration in the DPA register and send a request to the authorised representative – if they do not accept within 7 days, the request lapses and the registration is not approved. For non-EU/EEA companies, the national authorised-representative requirement applies, per DPA, only to batteries; without a Danish CVR number, however, registration for distance selling is in practice likewise only possible via a Danish authorised representative (also note Art. 45 PPWR).
Cross-border
Denmark is strict on market access: the registration must be in place BEFORE making packaging available (per the Miljøstyrelsen FAQ, applied for no later than 14 days in advance), and without an approved registration plus collective scheme membership, selling is not allowed. The obligation falls on whoever first makes the packaging available in Denmark – for direct shipping from abroad, that is the seller, not the Danish customer. Marketplaces have demanded proof of registration EU-wide since 12 Aug 2026 (Art. 45(4) PPWR). Important for reporting: actual annual volumes count; below 8 t/year the simplified declaration in one mixed category suffices.
Costs
One-off registration fee plus an annual volume-based DPA fee (rates approved annually by the environment ministry; calculator at producentansvar.dk); on top of that, the contributions of your chosen collective scheme (per kg, eco-modulated by recyclability). Actual amounts vary by scheme – compare offers.
Deadlines
System fully in force since 1 Oct 2025 (full cost responsibility, mandatory collective scheme). Registration before you start selling (per the Miljøstyrelsen FAQ, applied for no later than 14 days in advance). Annual reporting of actual volumes in the 1 Jan – 31 May window for the previous year (so 2026 volumes by 31 May 2027). Since 12 Aug 2026 the PPWR producer definition applies (commissioner/specifier instead of brand imprint).

Typical steps

  1. Determine which packaging you first make available in Denmark (product, secondary, transport and shipping packaging; reusables separately).
  2. Choose a collective scheme and become a member – mandatory for packaging; approved schemes include VANA, Emballageretur, ERP Denmark, Emballage Indberetning and RLG RENE (list at DPA).
  3. Create the registration in the DPA register via the self-service portal id.dpa-system.dk (foreign companies use username/password instead of MitID) – no later than 14 days before you start selling.
  4. Without a Danish establishment (EU/EEA, distance selling): appoint a bemyndiget repræsentant with a Danish CVR number; make sure the request is accepted within 7 days.
  5. State the expected volumes per packaging category when registering; from the following year, report the actual volumes in the 1 Jan – 31 May window (simplified below 8 t/year).
  6. Document your DPA registration number and store it with the marketplaces you use.

Providers for this obligation

Sources: Dansk Producentansvar – Packaging (Producentenansvar für Verpackungen, Inkrafttreten 01.10.2025) (accessed 2026-09-01) · Dansk Producentansvar – Authorised representative (Pflicht für EU-/EWR-Fernverkäufer, CVR-Anforderung, 7-Tage-Annahmefrist) (accessed 2026-09-01) · Dansk Producentansvar – Compliance schemes (Pflichtmitgliedschaft für Verpackungen; Liste der Kollektivordnungen) (accessed 2026-09-01) · Dansk Producentansvar – Registration (Self-Service id.dpa-system.dk, Gebührenstruktur, Fernabsatz-Angabe) (accessed 2026-09-01) · Dansk Producentansvar – Packaging legislation (Bekendtgørelse nr. 1146 vom 29.09.2025, Registrierungshistorie ab 2024) (accessed 2026-09-01) · Miljøstyrelsen – FAQ Producentansvar for emballage (Registrierung 14 Tage vor Marktbereitstellung, Meldefenster 01.01.–31.05., 8-t-Vereinfachung, Produzentendefinition ab 12.08.2026) (accessed 2026-09-01)

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Legal information, not legal advice. The linked official sources prevail; data marked “draft” has not been finally verified.