Emballageretur raises questions about the basis for the new allocation of packaging waste
Who should be responsible for which packaging waste, and therefore pay for its collection and treatment?
This is what Danish Producer Responsibility must determine when packaging waste is allocated among the collective schemes for the next two years.
Danish Producer Responsibility has submitted a draft of the upcoming allocation for consultation, and Emballageretur has now submitted its response.
In its consultation response, Emballageretur highlights three issues that could have unintended consequences for the allocation: changes among the producers represented by the collective schemes, the financial implications of waste fractions that are collected together, and the use of data from 2024 and 2025.
“The allocation determines which waste volumes and costs we are responsible for on behalf of our members. It is therefore important that the basis for the allocation reflects, as accurately as possible, the actual circumstances during the period covered by the allocation,” says Rikke Halkjær Kristensen, Subject Matter Expert at Emballageretur.
At the same time, Emballageretur welcomes the fact that the allocation model provides greater support for assigning combined waste fractions and shared transfer facilities to the same producer responsibility organisations.
Producers may switch collective schemes. New producers may begin placing products on the market, while others may stop. At the same time, the allocation of packaging waste applies for a two-year period.
This means that the companies and packaging volumes represented by a collective scheme may change during the allocation period.
“A lot can happen in two years. Producers can switch schemes, and companies can enter or leave the market. That is why it is important to examine what these changes mean for an allocation that remains in place for an extended period,” says Rikke Halkjær Kristensen.
Emballageretur is therefore calling on Danish Producer Responsibility to test the calculation model against a range of scenarios. These include situations in which a producer switches collective schemes, starts placing a product on the market or stops doing so, as well as how the timing of such a change affects the allocation.
In its consultation response, Emballageretur points to significant movement between collective schemes in practice and argues that these changes could therefore have a noticeable impact on the upcoming allocation.
Another issue arises when different types of packaging waste are collected together.
In several municipalities, Emballageretur has been allocated the plastic fraction even though plastic is collected together with food and beverage cartons. Emballageretur has only very limited reported volumes of food and beverage cartons and has therefore not itself been allocated this fraction.
“We are allocated the plastic, but because it is collected together with food and beverage cartons, we also incur costs for handling that part of the waste. The problem is that the reimbursement we can receive from the scheme with financial responsibility does not necessarily cover the actual costs,” says Rikke Halkjær Kristensen.
According to Emballageretur, the issue is not limited to an individual scheme. Financial settlements between the producer responsibility organisations are based on standardised rates rather than actual costs.
According to Emballageretur, this may result in some schemes gaining a financial advantage while others incur a financial loss.
Emballageretur is therefore calling either for a more consistent allocation of mixed waste fractions or for a model that provides better compensation for the actual costs incurred.
One option proposed by Emballageretur is a financial clearing house, where schemes could report documented costs for activities carried out on behalf of other schemes, allowing those costs to be allocated accordingly.
Read more about Emballageretur’s proposal for a financial clearing house here.
The third issue concerns data from 2024 and 2025.
On 12 August 2026, the scope of producer responsibility changed as part of the implementation of the Packaging and Packaging Waste Regulation (PPWR). Emballageretur therefore questions whether the data used from 2024 and 2025 adequately reflects the allocation of responsibility that applies following the change.
“In 2024, we saw reporting errors where Danish companies reported packaging volumes that, under the rules in force at the time, should have been attributed to foreign companies. Some of these reports were subsequently corrected, reducing the volumes reported by the Danish companies,” says Rikke Halkjær Kristensen.
Based on dialogue with members and other market participants, Emballageretur also believes that the volumes removed from the Danish companies’ reports may not have been reported to the same extent by the foreign companies that were responsible under the rules in force at the time.
According to Emballageretur, the underlying data may therefore contain so-called free-rider volumes.
If such volumes are included directly or indirectly in the calculation of the so-called take-back factors, this could affect the upcoming allocation.
The take-back factors form part of the calculation used to allocate responsibility for packaging waste among the collective schemes.
“The key question is whether the historical data provides an accurate picture of the companies and packaging volumes on which responsibility will be allocated in the upcoming period. That is what we would like to see clarified,” says Rikke Halkjær Kristensen.
Against this background, Emballageretur is seeking clarification as to whether Danish Producer Responsibility has carried out the necessary assessments and made any relevant adjustments in light of the changes to the scope of producer responsibility that took effect on 12 August 2026.