Municipal fees are a lottery for producers
Emballageretur has collected and analysed publicly available data on municipal fees for the so-called drop-off collection schemes — the term used when citizens bring waste to places such as recycling centres.
In relation to Extended Producer Responsibility for packaging, municipalities are entitled to charge a fee for drop-off collection schemes and send it to the Producer Responsibility Organisation that has been allocated the municipality for the relevant waste fraction.
In the analysis, Emballageretur has examined fees for metal, plastic and paper across all 98 municipalities. In total, the fees amount to DKK 45.7 million annually.
The analysis shows that there is almost no correlation between waste volumes and the fees charged. This is a problem because PROs are allocated municipalities based on the waste volumes represented by their members. The lack of correlation between fees and volumes creates major differences in the invoices that PROs receive — and pass on to their member companies.
“This affects all Producer Responsibility Organisations and their members. You may be lucky and get off cheaply within one waste fraction, but then be hit hard within another. For companies, it is a lottery, and they have no influence over whether they win or lose. That was certainly not the intention when Extended Producer Responsibility was introduced, and it creates uncertainty around the implementation,” says Morten Harboe-Jepsen, CEO of Emballageretur, which is part of Retur.
It is voluntary whether municipalities charge fees for drop-off collection schemes for plastic and metal or not, and Emballageretur’s analysis is solely intended to show the differences in what municipalities charge.
Of the total amount of DKK 45.7 million, the fee for plastic accounts for DKK 43.8 million. This means that municipal practice in relation to this waste fraction has a major impact. Around 20 municipalities have chosen not to charge a fee, while Denmark’s second-largest municipality, Aarhus, charges a fee of DKK 5,429,870. By comparison, Odense Municipality charges DKK 3,307,000 for plastic, while Bornholm charges DKK 1,142,944.
For metal, Aarhus is the cheapest municipality a PRO can be allocated. In fact, the fee is negative, meaning that the PRO receives DKK 75,980 from Aarhus Municipality. At the opposite end is Fredensborg Municipality, where the fee for metal is DKK 215,326.
The final waste fraction in the analysis is paper, where there are also significant differences. For example, Hedensted Municipality charges DKK 391,308, while the neighbouring municipality of Horsens charges DKK 20,094.
“The analysis shows us that municipalities take very different approaches to fees for drop-off collection schemes. Do they charge a fee or not? And if they do charge a fee, the big question is how they calculate it. We do not know, and there is no clear logic. But it goes without saying that you would rather collect paper waste in Horsens than in Hedensted, and metal waste in Aarhus rather than in Fredensborg. That is unsustainable,” says Morten Harboe-Jepsen.
Morten Harboe-Jepsen believes that, when it comes to fees for drop-off collection schemes, it is therefore necessary to introduce uniform methods for how municipalities calculate their fees.
As there will always be natural differences in municipal costs due to organisational, demographic and geographical factors, it is also necessary to introduce a national equalisation model. Under such a model, all municipalities would report their costs, and an average would be calculated on that basis.
This average would then be used as the standard rate when calculating fees for the PROs. As a result, the fee would in future have only one variable: volume. The national equalisation model should be administered by an authority-controlled body — a so-called Financial Clearing House.
According to Morten Harboe-Jepsen, these two adjustments would solve the current problem revealed by the analysis and create equal conditions for everyone.
“For several years, we have pointed out that if the implementation of Extended Producer Responsibility for packaging does not take municipal differences into account and equalise them, it will lead to unequal and unreasonable cost fluctuations for the PROs and their member companies. To make our handling as cost-effective as possible, we need transparency and long-term planning. That is why the incoming Minister for the Environment must step in and correct these problems with retroactive effect,” says Morten Harboe-Jepsen.
The authorities are currently correcting errors and shortcomings in several aspects of the implementation of Extended Producer Responsibility for packaging, but fees for drop-off collection schemes have not been included in this work. This means that no solution is expected in the legislative amendment currently under consultation.
Retur is Denmark’s largest family of Producer Responsibility Organisations and helps companies comply with their statutory Extended Producer Responsibility obligations in Denmark.
Retur consists of the Producer Responsibility Organisations Elretur, Emballageretur, Batteriretur, Fiskeriretur and Tekstilretur. Together, the schemes cover Extended Producer Responsibility for electronics, packaging, batteries, fishing gear and textiles.
Through its PROs, Retur supports thousands of companies in managing their products and packaging when they become waste — from registration and reporting to practical handling. The purpose is to ensure as much reuse and recycling as possible, as well as environmentally responsible disposal when reuse is not possible.
Retur is non-profit and builds on more than 20 years of practical experience with Extended Producer Responsibility. The organisation has access to specialised professional knowledge and collaborates with Nordic and European Producer Responsibility Organisations with a focus on supporting a more circular economy.
In 2025, Retur established Denmark’s first reuse facility for electronics, Electronic Reuse and Recycling, in collaboration with HJHansen Recycling. The facility focuses on reuse and preparing electronic products for further recycling. Retur is also behind the information campaign “F*cker med batterierne” featuring actor Bodil Jørgensen.
Contact Camilla Falkenberg, Press and Communications Manager at Retur and Emballageretur, by phone at +45 43 14 08 94 or by email at cf@retur.dk.