The fee you pay for packaging does not only depend on quantities and materials. Packaging design and documentation also matter. Here you get an overview of how eco-modulation works and what it requires from you in practice.
Last updated: 14/10/2026. Based on BEK nr. 851 af 28. september 2026 and the Danish Environmental Protection Agency’s guidance, version 2A.
The easier your packaging is to recycle, the less you pay in fees. This is the basic idea behind eco-modulated fees: a mandatory model that links the design of your packaging directly to your costs.
Each item of packaging is placed in one of three levels, depending on how easy it is to recycle:
The additional revenue from red-level packaging is used to reduce the fee for green-level packaging within the same material. It is therefore a redistribution between producers — not an additional authority fee. Green-level packaging will, however, always pay at least 20% of the operational costs.
Whether your packaging is placed in the red, yellow or green level is determined by specific design requirements for each material and by whether you can document that the packaging meets those requirements.
If you cannot document that the packaging meets the design requirements, it is placed in the red level.
You can find the exact criteria for each material in annexes 1–10 of the Danish Environmental Protection Agency’s guidance.
If you place 8 tonnes of packaging or more on the market in one year, your packaging must be placed in the green, yellow or red level. The packaging design determines the level, but only if you can document it. Without documentation, the packaging ends up in the red level.
If you place less than 8 tonnes on the market, you are not required to eco-modulate. You may still choose to do so, and it can pay off if you can document that your packaging is in the green level.
Eco-modulation does not apply to all types of packaging, and the requirements differ depending on the material type. Some materials are divided into three levels, while others are divided into only two levels. There are also materials that are not eco-modulated.
Certain types of packaging are exempt from eco-modulation, even though they are still covered by Extended Producer Responsibility. This applies to packaging for medicinal products, contact-sensitive packaging for medical devices and contact-sensitive packaging for infant formula, baby food and foods for special medical purposes. Ordinary food packaging is not exempt, but it is exempt from the requirement for recycled plastic.
To achieve the green or yellow level, you must be able to document that the packaging meets the relevant design requirements. If documentation cannot be provided, the packaging is placed in the red level.
The documentation typically comes from your packaging supplier and may include product data sheets, material specifications, test results and certificates. The work is often most extensive when the data foundation is first established, but documentation must be maintained continuously when packaging, suppliers or product ranges change. You must be able to present the documentation to the authorities or your Producer Responsibility Organisation at any time.
If packaging consists of several materials or components, whether the parts can be separated and how they work together may affect eco-modulation.
In some cases, the packaging must be assessed as one complete unit. In other cases, individual components must be assessed separately if they can be separated and affect the packaging’s material category or design requirements.
This means that eco-modulation is not only about knowing the total weight of the packaging. You must also be able to document which materials and components the packaging consists of, and how they form part of the complete packaging.
Eco-modulation is not only a question of compliance. It is also a management tool, because packaging design and cost are linked directly. If you work systematically with packaging choices and documentation, it can affect both your fees and the recyclability of your packaging.
With the Packaging and Packaging Waste Regulation (PPWR), requirements for packaging design will gradually become stricter towards 2030. Companies that already work systematically with packaging data and supplier documentation will therefore be better prepared for the coming requirements.