The debate on Extended Producer Responsibility (EPR) for packaging has received considerable media attention in recent weeks. Many of you have followed the debate, and several companies have contacted Emballageretur for clarification on what it means for their business. This article provides an overview of the key terms used in the debate.
We know that the current debate may create uncertainty. The rules are complex, and media coverage does not always provide the full picture. One central theme has been that companies may be affected differently depending on which Producer Responsibility Organisation (PRO) they are members of.
To make it easier to navigate the debate, we have compiled a brief overview of the most important principles and terms below.
Read more: Comparing prices between Producer Responsibility Organisations – what you need to know
Before EPR takes effect, the PROs need funds to pay municipalities, collection, treatment, administration and other costs from day one.
Municipalities are expected to charge more than DKK 1 billion annually in producer fees. No PRO has liquid funds of that scale, which is why an advance contribution is charged to members.
In Emballageretur, the advance contribution was charged in August 2025.
It is a one-off payment that secures the necessary liquidity to pay on time – and it will be repaid.
It is important to emphasise that an advance contribution and financial security are not the same thing.
Legislation requires a PRO to provide financial security on behalf of its members.
The purpose is to ensure that operations can continue during a transition period if a PRO goes bankrupt or ceases operations. The security covers collection and treatment costs until a new PRO can take over.
In Denmark, the requirement is set at three months of expected costs.
Emballageretur has, of course, provided financial security on behalf of our members.
From 1 October 2025, responsibility for household packaging waste will transfer to producers, while municipalities will continue to collect waste from households.
Municipalities charge an annual producer fee to cover collection and treatment.
The fee must be paid in advance, as municipalities have ongoing costs for employees and subcontractors.
This is what we at Emballageretur refer to as an advance contribution. In practice, it corresponds to advance payment of approximately three months of costs, and the payment must be made in cash – not as financial security.
Municipal fees have proved to vary significantly from municipality to municipality.
The Danish Environmental Protection Agency is working to introduce standardised calculation methods, expected from Q1 2026 at the earliest.
This may mean that some fractions become cheaper, while others become more expensive.
There have been proposals to postpone the advance payments by three months, but this has not yet been decided. Until the legislation is changed, the current rules apply, and municipalities can therefore charge payment from 1 October 2025.
If municipalities adjust prices downwards, the benefit will apply to all companies – regardless of PRO.
Together with ERP Denmark, Emballageretur warned the authorities and the political parties behind the agreement on EPR for packaging about the challenges caused by differences in municipal pricing as early as April 2023.
We pointed this out again in October 2024, when one of our spot checks showed that municipal costs per household could vary by as much as 79 per cent – a figure that has now proved to be even higher.
At the time, we also proposed a solution – a financial clearing house – which could have solved several of these problems.