Extended Producer Responsibility for electronics generally applies to the company that first places electrical and electronic equipment on the Danish market. This includes manufacturers, importers, companies selling under their own brand, and foreign companies selling directly to Denmark through distance sales.
What matters is your company's role in the value chain and whether you are the party that first brings the equipment onto the Danish market.
If your company manufactures or imports electrical or electronic equipment and places it on the Danish market for the first time, you are typically covered.
If you sell equipment under your own name or trademark, you will often be considered the producer under the legislation, even if another company has manufactured the product. The same applies to foreign companies selling directly to Danish customers via e-commerce.
If your company has a product manufactured by another company and markets it under your own name, you will typically be considered the producer.
Extended Producer Responsibility (EPR) does not only apply to classic consumer electronics. It applies to all products that depend on electric current or electromagnetic fields in order to function correctly.
In practice, this may include products with a motor, electronic control or a display, built-in light sources, electrical measuring or control units, a cable, power supply or charging function. What matters is the function of the product — not what the product is called, or which industry it is sold in.
The rules include exemptions. The most important include certain motorised vehicles, ships, aircraft and trains, military equipment and equipment for national security, space equipment, large-scale stationary industrial tools, large-scale fixed installations, mobile non-road machinery for professional use, certain types of medical equipment and business-to-business research and development prototypes.Batteries and accumulators are not covered as electronics. They are regulated separately under battery EPR.
Danish Producer Responsibility administers the producer register, supervises compliance and can issue formal decisions on matters such as scope, categorisation and registration.
You must register with Danish Producer Responsibility (DPA) no later than 14 days before you market electronics for the first time. Among other things, you need to have company information, product categories and your choice of PRO ready.
You must report quantities placed on the market and product categories to Elretur according to the deadlines that apply to your membership. Elretur uses the data in the further reporting to DPA.
You must finance the collection and treatment of electronic waste and ensure correct marking and information about separate collection.
Your company has the legal responsibility for registration, data and documentation. Danish Producer Responsibility administers the register, receives reports, supervises compliance and issues formal decisions. Elretur handles the practical obligations in the PRO on behalf of its members - including reporting, collection, treatment and documentation of waste management.
Elretur is Denmark’s largest Producer Responsibility Organisation for electronics, with more than 20 years of dedicated experience.
Through a single Retur membership at just DKK 1,500 per year, your company gets a clear and coordinated setup for managing its obligations for electronics, batteries, packaging and textiles.