Producer responsibility for packaging in 2026: who is covered, and what does it cost?

By Packwise · Updated November 10, 2026

Producer responsibility for packaging means that companies placing packaging on the Danish market pay for its collection, sorting, and recycling. The scheme has been in effect since October 1, 2025. The cost depends on the volume and the design of the packaging, which is categorized as green, yellow, or red. Red is the most expensive.

What is producer responsibility for packaging?

Extended producer responsibility for packaging is a Danish scheme that shifts the bill for packaging waste from municipalities to the companies that place the packaging on the market. The idea is simple: whoever puts the packaging on the market pays for what happens to it afterwards.

The rules are set out in the Packaging Order (Executive Order no. 1146 of September 29, 2025), and the scheme entered into force on October 1, 2025. The government has set a cap on the total amount producers must pay at a maximum of 1.2 billion DKK (Ministry of the Environment, 2025). How much your company pays depends on both the volume and the design of your packaging.

Who is covered by producer responsibility for packaging?

You are typically covered if your company makes packaging or packaged products available on the Danish market for the first time. This applies to, among others:

• Manufacturers and brandsthat package their own products, e.g., cosmetics, dietary supplements, or cleaning agents.
• Importersthat bring packaged goods in from abroad.
• Webshopsthat sell and ship goods to Danish customers.

As a producer, you must register with Danish Producer Responsibility (DPA), be a member of a collective scheme (a producer responsibility organization), and report annually how much packaging you have placed on the market, broken down by material (Beierholm, 2025). The producer responsibility organization collects the fee and ensures that the packaging is handled.

If you are in doubt about whether your company is covered, ask the DPA or your producer responsibility organization.

How much does producer responsibility cost? Green, yellow, and red

The fee is calculated based on how many tons of packaging you place on the market for each material, and the cost of managing that waste. Furthermore, the fee is eco-modulated. This means that packaging is placed into one of three levels based on how easy it is to recycle (Danish Environmental Protection Agency, 2025):

• Green: packaging that is easy to sort and recycle. It receives a discount.
• Yellow: packaging in the middle. It pays its own operating costs.
• Red: packaging that is difficult to recycle. It pays an additional 35% on top of the operating costs.

The extra money from red goes toward lowering the fee for green packaging within the same material category. It is, therefore, a system where poor design pays for good design.

Plastic and beverage cartons have all three levels. Glass, paper, cardboard, steel, and aluminum only have green and red. The most important thing to know: If just one criterion is red, the entire packaging is red. And if you cannot document a criterion, it also counts as red.

What results in green, and what results in red?

Each material has its own design criteria. Here are the most important ones for the materials used most frequently in cosmetic and pharmaceutical packaging.

Two things are particularly important for cosmetics, dietary supplements, and medicine:

• The requirement for 20% recycled plastic does not apply to contact-sensitive products. This includes, among other things, cosmetics, dietary supplements, pharmaceuticals, and food contact materials. The exemption applies to rigid plastic, flexible plastic, and foam plastic, but not to rigid PET.
• Lids and pumps count with the bottle, unless you can document that they are separated. This typically requires a test where the part must fall off in at least 70% of cases during use, transport, or sorting. A pump with a metal spring can therefore drag an otherwise green bottle down into the red category.

Producer responsibility and PPWR: how are they connected?

Extended Producer Responsibility and the EU Packaging Regulation PPWR are often confused, but they each have their own specific role:

• PPWR determines how packaging must be designed and documented before it can be sold in the EU. From 2030, all packaging must be recyclable in class A, B, or C.
• Extended Producer Responsibility determines who pays for the packaging once it becomes waste, and how much.

They pull in the same direction. Packaging made from a single material without difficult colors or barriers is typically green in the Danish fee structure and also stands strong when the PPWR's recycling requirements take effect. A good design choice today saves money both now and in the future.

How to get started

1. Find out if you are covered. If you place packaging or packaged goods on the Danish market, the answer is usually yes.
2. Register and choose a producer responsibility organization. Registration takes place with the DPA, and the organization handles fees and reporting.
3. Map your packaging. For each piece of packaging, note the material, weight, and all components such as lids, pumps, labels, and seals.
4. Find your level. Go through the criteria for each material and see what pulls it down into the red category. Often, it is a single detail like a black color or a metal spring.
5. Gather documentation. Ask your supplier for material specifications. Without documentation, the packaging will be placed in the red category.
6. Design your way out of the red. Mono-materials, NIR-sortable colors, and lids made of the same plastic are often enough to move the packaging up to green.

Frequently asked questions

Who is covered by producer responsibility for packaging?

Companies that make packaging or packaged products available on the Danish market for the first time. This typically applies to manufacturers, brands, importers, and webshops selling to Danish customers. They must register with the Danish Producer Responsibility (DPA), be a member of a producer responsibility organization, and report their packaging volumes every year.

What is the cost of extended producer responsibility for packaging?

The price depends on how many tonnes of packaging you place on the market for each material type, as well as the operating costs for waste management. The fee is eco-modulated: green packaging receives a discount, yellow pays its own costs, and red pays a 35 percent surcharge. You can get the specific price from your producer responsibility organization.

What is the difference between green, yellow, and red packaging?

The levels indicate how easy the packaging is to sort and recycle. Green meets all requirements regarding material, color, components, and documentation. Red has at least one issue, such as black plastic, PVC, or metal parts, or it lacks documentation. Yellow falls in between and applies only to plastic and beverage cartons.

Are small businesses also covered?

Yes, extended producer responsibility applies regardless of size, but there are exemptions. Producers who place less than 8 tonnes of packaging on the market per year do not have their fees eco-modulated unless they specifically request it. Ask your producer responsibility organization which rules apply to your specific business.

Do you want to know if your packaging is green, yellow, or red, and what it takes to move it up a level? Book a non-binding meeting with our packaging specialists.

About the author:Packwise are packaging specialists with extensive experience in cosmetic and pharmaceutical packaging. We advise brands on choosing packaging solutions from the concept phase through to production.

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