Who must register for packaging EPR in Denmark, and how

Reviewed on 29 September 2026 against the current Danish packaging order, Bekendtgørelse nr. 1146 of 2025. This is general information about Regulation (EU) 2025/40 and Denmark's national EPR scheme, not legal advice. Thresholds, fees, penalty amounts and go-live dates come from national law and PRO schedules that change, treat every figure as needing a fresh check, and confirm anything you act on with the national authority or qualified counsel.

The register and what it involves

Producers register with Dansk Producentansvar (DPA / DPA-System); the Danish EPA (Miljøstyrelsen) is the overarching authority. You register, paying a registration fee, at least 14 days before you first make packaging available (s21), and a producer of single-use packaging must be enrolled in a collective scheme by the time it registers (s80). Fees comprise a DPA admin fee, an EPA admin fee, and the waste-management fee.

The dates that apply now

The rules in force are Bekendtgørelse nr. 1146 of 29 September 2025, which has applied since 1 October 2025 (s121). Producer responsibility and fees began on 1 October 2025 (a per-kilo waste-management fee plus eco-modulation), and the first allocation period runs from 1 October 2025 to 31 December 2026 (s37); later periods each run for two calendar years. A new producer registers at least 14 days before first supply (s21). Each year, producers report the previous calendar year’s quantities to DPA by 1 June (s27(1)); if you start supplying after that deadline, you report an expected quantity for the current year when you register (s27(3)).

The Authorised Representative and de-minimis

A producer established in another EU state or outside the EU counts as the Danish producer only for distance sales directly to Danish end users (s2 no. 36(c)). The order defines a representative as a person established in Denmark and authorised to act for a producer that is not (s2 no. 39), and the producer register records one (ss21 to 23). DPA’s guidance describes appointing one as required for non-established producers, but the order itself speaks only of the producer’s “eventuelle repræsentant” (any representative it may have), which reads as optional. The Danish texts point different ways, so confirm your position with DPA.

The EU rule covers the same ground. Since 12 August 2026, Article 45(3) of Regulation (EU) 2025/40 has required a producer that makes packaging available directly to end users in a member state where it is not established to appoint an authorised representative for EPR there, and selling direct to Danish end users is exactly how a foreign business becomes a Danish producer. If you supply Danish resellers who pass the goods on unchanged, you are not the Danish producer and Article 45(3) does not catch you. A proposal to suspend Article 45(3), COM(2025) 982, stalled when the Council ended negotiations on it in April 2026 and left it out of its 24 June 2026 mandate.

The 8 tonnes/year figure is not an exemption. Below it you are still registered and liable, but you may report one total weight for the year, split only between household and commercial packaging (s27(7)), and your collective scheme does not eco-modulate your fee (s87(2)). It is a reporting simplification, not an exemption from obligation.

Reporting and penalties

Reporting is annual: the previous calendar year’s quantities in kg, by material and split household/commercial and single-use/reusable, due by 1 June (s27(1) and (5)), simplified under 8 t (s27(7)). A producer that starts after the 1 June deadline reports an expected quantity when it registers (s27(3)). Failing to register, report or join a collective scheme is punishable by a fine (s120), and the order sets no fixed amount; an intentional or grossly negligent breach that harms or endangers the environment, or is committed for economic gain, can carry up to two years’ imprisonment (s120(2)).

How onerous is it?

High. Every producer registers and reports whatever its size, single-use packaging means joining a collective scheme, fees above 8 t are eco-modulated, and the scheme is only in its first allocation period. A foreign business selling direct to Danish end users should plan on a Denmark-established representative, since Article 45(3) requires one and DPA’s guidance expects it.

Frequently asked questions