New analysis highlights challenges in producer responsibility, but is missing a central element
Dansk Erhverv has published an analysis warning of rising prices and identifying a number of structural challenges in producer responsibility for packaging.
It is positive that there is growing attention to how the system works in practice. Several of the issues described in the analysis are well known, and through its work on the development and implementation of producer responsibility, Retur has continuously contributed to the discussion of how the organisation can be strengthened.
Producer responsibility is a central tool in the green transition. But it requires stable frameworks, transparency, and a cost distribution that reflects the true economics of the system if it is to work in practice.
In its analysis, Dansk Erhverv identifies three preconditions:
It is difficult to disagree. The challenge lies in how these principles are translated into concrete mechanisms that actually work in a system with many actors and intersecting economies.
The three preconditions are accompanied by six recommendations. Below, we review them and offer Retur's perspective on what is needed to create a better-functioning system.
Along the way, we also highlight a central element that does not feature in the analysis, but which is critical to a full economic understanding of the system.
The analysis recommends swift political clarification of the so-called 'benchmark model' — that is, the standardised price and cap on municipal fees that was sent for consultation earlier in 2026 but was not passed before the general election.
In Retur's assessment, this is the most pressing task in the system — recognising that, with a new government, a new minister, a new ministerial portfolio for waste, and an imminent summer recess, this is not something we expect to see resolved before autumn at the earliest.
Without clarification, we as a producer responsibility organisation are compelled to factor uncertainty about future retroactive adjustments and potential additional costs into our prices. This makes it more difficult for businesses to budget and plan.
Retur has highlighted the absence of stable economic frameworks as one of the greatest challenges in the implementation of producer responsibility from an early stage. Political clarification cannot wait much longer.
Read more: The government cuts producer responsibility fees: Here is the overview
The analysis calls for payment obligations to reflect actual packaging volumes on the market to a greater extent, rather than the projected figures on which the system was originally based.
This is an issue that stems from the system's original design.
When municipalities and waste volumes were allocated between the producer responsibility organisations, this was done on the basis of budget figures and a definition that has since been revised. At the same time, parts of the responsibility have shifted from Danish businesses to foreign producers, where registration rates are still developing.
"There is a discrepancy between what was originally reported under the definition of producer responsibility at the time, and what is being reported today. This is to be expected — there is nothing mysterious about it," says Morten Harboe-Jepsen, CEO of Retur, to CleantechWatch, published in June 2026.
During the development of the framework for producer responsibility for packaging, Retur recommended a more frequent allocation model - an annual one - as is the case for producer responsibility for electronics and batteries.
An annual model would have made it possible to correct for market changes more quickly and ensure more dynamic and accurate distributions.
The final model adopted a two-year allocation period.
When Dansk Producentansvar carries out the next allocation on the basis of actual data, we expect that some of the current imbalances will be reduced.
Read more: Does allocation affect the price of producer responsibility?
The analysis recommends greater transparency in municipal fees.
This is one of the most significant structural problems in the system.
For this reason, Retur has repeatedly proposed, since 2023, the establishment of a financial clearing house that can ensure all businesses pay the same price per kilogram of packaging within an authority-controlled system that subsequently distributes the funds to municipalities.
The purpose is straightforward: equal conditions should not depend on which municipalities a given producer responsibility organisation happens to have been allocated.
The need for a financial clearing house became clear when Retur mapped municipal fees earlier this year. Our analysis of plastic packaging from recycling centres revealed significant variation:
Differences of this magnitude cannot be explained by geography or logistics alone. At the same time, the allocation to producer responsibility organisations is based on waste volumes - not on price levels.
In practice, this means that two businesses with an identical packaging basis can face different costs solely as a result of which municipalities their producer responsibility organisation has been allocated.
"This affects all producer responsibility organisations and their members. You may be fortunate in one fraction and unfortunate in another. For businesses, it is effectively a lottery, and they have no influence over the outcome," says Morten Harboe-Jepsen.
A national equalisation principle - administered through a financial clearing house - would shift the fee from geographical chance to a volume-based model. This would create more uniform conditions and a more transparent financing structure.
Municipalities would have their tasks funded, businesses would be treated equally, and competition would be fairer.
Read more: Municipal fees are a lottery for producers.
The other side of the economic reality of producer responsibility concerns how the transition feeds through into the overall waste economy — and therefore into what households pay.
Producer responsibility was introduced to shift part of the financing of waste management from households to the businesses that place packaging on the market. Municipalities are therefore partly financed through producer payments rather than solely through households' waste collection fees.
This is a concrete reallocation of financial responsibility within the waste system, which in principle should also be traceable in households' overall payment for waste.
In practice, that connection is not visible in the overall figures. Municipal waste finances are reported as a single combined unit, in which it is not clearly apparent how producer payments and households' waste collection fees affect one another.
This means that the overall effect of the reform - including the potential reduction in household payments - is not directly readable in the way the system's finances are communicated and reported.
As a result, a central part of the system's economic logic becomes difficult to follow: what is being shifted from households to producers, and how this actually feeds through into the overall payment and the citizens' increased purchasing power.
Taken together, both issues point to the same underlying problem in producer responsibility: that the economic shifts in the system are real, but not fully visible in the way waste finances are currently reported. This applies both to businesses' costs and to households' overall payment.
The analysis recommends a simpler model for export packaging, so that businesses are not required to register and pay for packaging that is demonstrably exported.
It already follows from the legislative basis for producer responsibility that businesses are only required to pay for packaging placed on the Danish market that becomes waste in Denmark.
Retur's system is therefore designed to handle this through ongoing registration and subsequent correction of data ahead of the final annual reporting to Dansk Producentansvar, so that documented exports can be incorporated into the corrections.
This does not, therefore, raise a matter of principle regarding the choice of model, but rather a question of accurate documentation and data quality in reporting.
The analysis highlights the need to reduce the problem of businesses that do not meet their registration and payment obligations.
This directly affects the businesses that do comply with the rules, and thereby the legitimacy of the system.
Retur's experience from other producer responsibility organisations shows that actively identifying, informing, and registering businesses that should be part of the system requires a concerted effort from both authorities and producer responsibility organisations.
Earlier this year, Retur entered into an agreement with Temu on producer responsibility for packaging, with support from the Danish Environmental Protection Agency. This type of concrete cross-sector collaboration and initiative is essential if the free-rider problem is to be reduced in practice.
Retur continues to work to ensure increased compliance in cooperation with relevant actors.
Finally, the analysis recommends a simpler model for the refund of packaging that becomes waste at businesses themselves.
The principle is sound, but simplification must not come at the expense of documentation.
Refund arrangements handle significant funds on behalf of the member businesses of producer responsibility organisations. High standards of documentation and control are therefore essential to ensure correct and accurate distribution of funds.
The goal should be a model that is both straightforward to use and robust in its financial administration.
In autumn 2025, Retur's subsidiary organisation Emballageretur, together with ERP Denmark, launched Affaldsanmodning.dk - a digital platform that makes the application process simple for businesses while ensuring the documentation necessary for correct payment.
The platform ensures that we receive the necessary documentation without placing a significant administrative burden on individual businesses. Our solution complies with the rules. It works. We receive a large number of applications and pay out compensations to Danish businesses and waste collectors on a daily basis. We request adequate documentation before making payments — not because we wish to make the process difficult, but because the alternative is to pay out members' funds blindly. And that is not an option for us.
Read also: Retur and ERP Denmark warn: Current practice for business compensations opens the door to fraud.
The analysis identifies a number of well-known challenges in producer responsibility that Retur has continuously addressed since the system was introduced. This underlines a fundamental point: that the effectiveness of the system depends not only on its design, but to a significant degree on its implementation.
Producer responsibility for packaging represents a comprehensive systemic shift that is still being bedded in. In this situation, stability is a precondition for the system to function in practice.
There is a need for clearer direction and greater predictability in implementation. Ongoing adjustments and unresolved frameworks create uncertainty for businesses, producer responsibility organisations, and municipalities alike - and make it more difficult to translate intentions into operational reality.
It is therefore essential that the fundamental mechanisms of the system are allowed to settle, so that all actors can work within a known framework. Experience shows that complex systems such as producer responsibility are not strengthened by frequent changes, but by stable delivery and targeted adjustments where necessary.
Retur supports the ambitions behind producer responsibility, but there is a need to maintain an implementation trajectory focused on operation, learning, and stabilisation rather than continued fundamental change.