Date: November 11th 2026
Emballageretur has submitted a consultation response to the draft revised Danish Packaging Order.
We believe the proposal falls short of the political ambitions to simplify the rules, reduce administrative burdens and ensure a level playing field. On the contrary, several of the proposed changes risk exacerbating existing challenges.
In our consultation response, we focus in particular on:
Postponing the new rules
We recommend extending the current Packaging Order and postponing the entry into force of the revised rules until 1 July 2027. This would allow time to develop more thoroughly considered and long-term solutions.
Municipal fees without an effective cap
Our calculations show that municipal producer fees could reach DKK 1.4 billion in 2027. The proposed benchmarking model does not cover all fees and risks turning the fee cap into a standard rate. We recommend an overall cap on all municipal producer fees.
Unequal competitive conditions for producer responsibility organisations
The costs incurred by producer responsibility organisations (PROs) depend on which municipalities they are assigned, rather than solely on their own efficiency. We recommend full cost equalisation between PROs to ensure a level playing field.
Drop-off collection schemes and differences in municipal fees
There are significant differences in municipal fees for drop-off collection schemes, which are not covered by the benchmarking model. We recommend consistent benchmarks and fee caps for both kerbside collection and drop-off collection schemes.
Retrospective fee adjustments and earlier fee notifications
Clear rules are needed for retrospective adjustments to municipal fees, which we recommend should not be implemented until 2028. Municipal fees should also be announced earlier to give producers greater predictability regarding their costs.
Rethinking compensation for commercial packaging waste
Although compensation for commercial packaging waste is not formally covered by this consultation, we highlight the need for a simpler model with better data, adequate controls and a cap on compensation payments.
Better data sharing and less administration
We welcome improved access to municipal waste data but warn against new administrative requirements under Section 52. Retur already spends 30–40 hours per week responding to municipal data requests. We recommend a shared digital solution for data exchange.
Municipal responsibilities and waste quality
We call for clearer responsibilities and stronger enforcement of requirements for municipalities. Producers and PROs should not face sanctions for municipalities' failure to fulfil their obligations, and the quality of collected packaging waste must be ensured.
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Emballageretur calls for the proposed rules to be further developed in dialogue with producer responsibility organisations. We are ready to contribute our practical experience from operating extended producer responsibility schemes.
Read the full consultation response from November 2026 here.