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Micro-enterprises are exempt from producer responsibility, except when importing

4.6.2024
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Iben Stanhardt
Beauty
Logistik og transport
Healthcare
Detailhandel og foodservice
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The executive order on the registration and reporting of packaging entered into force on April 1, 2024, at the same time that Danish Producer Responsibility (DPA) opened for the registration of companies that make packaging or packaged products available on the Danish market.

An updated version of the Registration Order has now been released, which affects micro-enterprises. It entered into force on May 20, 2024, thereby repealing the previous order.

We have gathered the most important updates and tips for you here.

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Micro-enterprises and producer responsibility for packaging

In the Registration Order, a micro-enterprise is defined as having:

  • Fewer than 10 employees (and)
  • an annual turnover of less than DKK 15 million.

If you are a micro-enterprise and have packaging manufactured by a Danish supplier, you are not producer-responsible for this packaging. This applies even if the packaging is marketed under your own brand.

This applies to sales, multi-pack, and transport packaging, as well as service and reusable packaging.

In these cases, the producer responsibility falls to the Danish packaging manufacturer.

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Rules for importing packaging

If, as a micro-enterprise, you instead import packaging from abroad—regardless of whether the packaging manufacturer is established inside or outside the EU—you, as the importer, will assume producer responsibility for the packaging that you are the first to make available on the Danish market.

The Environmental Protection Agency has created this visual example of when producer responsibility falls to micro-enterprises. Find more examples in the Environmental Protection Agency's guide.

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Get help structuring your packaging data

Remember that companies subject to producer responsibility must report their expected 2024 packaging volumes to the DPA no later than August 31, 2024.

You can get help structuring your packaging data by using the packaging calculation tool, which is part of our free starter kit.

Download a free starter kit

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You can also find useful information and links to the legislation behind producer responsibility for packaging on our dedicated page on the subject.

Read more about producer responsibility

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If you want to create your own product photos, we can also help you get certified.

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GS1Trade Sync is a data pool for product data exchange that your trading partners can access.

GS1Trade Sync streamlines data exchange between trading partners because data only needs to be entered in one place. This increases the quality of product data and creates value for you - and the entire value chain.

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GS1Trade Packaging is a packaging data system that gathers your packaging data in one place. The system ensures efficient collection, structuring, and declaration of packaging data, and makes it easy to exchange packaging data with other companies.

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GS1Trade Exact

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GS1Trade Exact ensures the quality of your product data. All physical products are checked against the data registered in GS1Trade Sync.
With this service, you get verified and quality-assured data that benefits the entire supply chain.

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GS1Trade Transact handles the digital receipt of orders and the sending of documents to your customers. You can choose whether to integrate it with your financial system or access it online.

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GTIN (also known as EAN) stands for “Global Trade Item Number” and is the number sequence shown beneath a barcode symbol.

GTIN (EAN) is a global standard used to uniquely identify digital and physical products, allowing the barcode to be scanned anywhere in the world throughout the supply chain.

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A GLN (also known as EAN) allows you to uniquely identify physical, functional, legal, or digital entities. This can include the sender, receiver, buyer, seller, supplier, manufacturer, delivery location, billing location, store, or internal departments.

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