On the 24th August, the Danish WEEE & batteries collective scheme ERP Denmark has communicated a summary of the current status of the implementation of the new Danish packaging EPR regulation which comes into force on the 1st January 2025.
According to ERP Denmark, around 42000 companies are effected by the new legislation and an annual cost budget of 2,35 Billion DKK (approximately 315 mio EURO) are to be allocated to the responsible producers from now on in order to be paid by them.
The legislation is still not finalized, but it can already be said, that
- the first actor in the distribution chain in Denmark will be held responsible for registration
- both b2c and b2b packaging distance sellers need to register with an Authorised Representatie (AR)
- the registration at the Danish register dpa-system has to happen in Q1 2024 until the 31st March 2024
- voluntary take overs for registrations of the obliged producers will not be accepted by the dpa-system
- a forecast report for 2024 has to be provided also within Q1 2024
- a scheme has to be chosen within Q1 2024
- a threshold level of 8 tons per year applies, a scheme participation below this volume is voluntary, but requires the fulfillment of ambitious criteria of an individual take back system
- the registration fee structure will be made up of a registration one time charge, a general contribution fee, gradual contribution fees and for the schemes of a membership fee. ERP has communicated not to apply an additional membership fee for existing WEEE and battery participants in the ERP Denmark scheme.
The reporting details for producers below the threshold level of 8 tons is not finalized. Also the requirements for the information to users is not communicated yet. It is expected, however, that Denmark will introduce sorting instructions on the basis of pictrograms.
It will be interesting to see, if those pictograms may pick-up the pre-work that has been provided by the French authorities (Triman-marking).
Source: ERP Denmark, https://erp-recycling.org/en-dk/contact/