Before the EPR scheme begins on 1 October, we will collect an advance payment in August 2025. This payment is necessary to ensure that the legally required expenses we must cover on your behalf can
be paid on time from day one.
During the start-up phase, advance payment is required because several of our partners – including the municipalities – demand payment before their services commence. For example, municipalities must be paid three months in advance for the collection of packaging waste.
The advance payment covers your company’s proportionate share of the expected start-up costs. It is calculated based on the amount of packaging your company has reported in Returportalen as of 31
May 2025.
The expenses covered by this payment include municipal collection and handling of household packaging waste, handling and reimbursement of commercial packaging waste, financial guarantees,
and administrative services such as data processing and communication.
The advance payment covers the same costs that your environmental fee will later finance once the scheme is up and running. You can read more about the environmental fee and other related payments in the attached overview.
As your collective scheme, it is our responsibility to ensure that all payments are handled as fairly and transparently as possible. Emballageretur is a non-profit organisation and will only collect what is necessary to fulfil the financial obligations we undertake on your behalf.
The invoice will be issued on 18 August 2025, with a payment deadline of 30 days from receipt.
It is important to emphasise that this is not an additional charge. The advance payment is a one-off payment, and the full amount will be reimbursed to you over time.
Reimbursements will be made in instalments on a quarterly basis, beginning from June 2026. Repayment of the advance payment will be completed by 31 December 2026. We are currently preparing a repayment plan and will provide more information as soon as it is finalized.
Before producer responsibility for packaging enters into force on 1 October 2025, all PROs must ensure that they can cover the mandatory payments to municipalities, collection, treatment, administration, etc. from day one.
It is estimated that municipalities will charge an annual fee, which in total is expected to exceed DKK 1 billion. Although the amount will be distributed among the Producer Responsibility Organizations (PROs), none of them were established with liquidity at that scale. Since the PROs are also organized differently, the solution for paying the producer fee will vary from PRO to PRO.
At Emballageretur, we are a non-profit organization, and in August 2025 we charged our members an advance payment. The advance payment ensures that we can pay the mandatory costs on behalf of you and our other members on time, in accordance with the Packaging Order. Several other PROs have chosen the same solution.
It is important to emphasize that an advance payment and a financial guarantee are not the same. The advance payment provides the PROs with the necessary liquidity to pay ongoing costs from day one – and in the case of Emballageretur, it is a one-off payment that will be reimbursed.
It is important to emphasize that an advance payment and a financial guarantee are not the same.
Under producer responsibility, a PRO is required to provide a financial guarantee on behalf of its members. The purpose is to ensure that the PRO can continue to meet its obligations towards authorities and the market, even if the scheme were to go bankrupt or cease operations.
The guarantee thus functions as insurance covering the costs of collection and treatment during a transitional period, so that operations continue until a new PRO can take over the members’ obligations.
In Denmark, it is stipulated that a PRO must provide a guarantee equivalent to 14 days of expected costs. Emballageretur has, of course, provided this guarantee on behalf of our members.
The advance contribution covers the same costs that will later be financed through the environmental contribution, but is invoiced earlier because some expenses must be paid in advance from the start.
It is therefore not an extra cost, but an advance payment which you will be reimbursed.
The advance contribution will be reimbursed in instalments, quarterly, starting from 1 June 2026.
Repayment of the advance payment will be completed by 31 December 2026. We are currently preparing a repayment plan and will provide more information as soon as it is finalized.
All PROs are subject to the same legal requirements and payment obligations in connection with the launch of extended producer responsibility.
From 1 October 2025, the responsibility for household packaging waste will transfer to producers. This responsibility will be handled by the collective schemes. Municipalities will continue to collect waste from households, as they always have, but they will now charge an annual fee to cover the costs of collection and treatment.
The fee must be prepaid, as municipalities have ongoing expenses for staff and subcontractors. The PROs must therefore collect payment in advance from producers so that the funds are available when the invoice is due. At Emballageretur, we refer to this as the advance payment. In practice, it corresponds to prepayment of approximately three months of costs, and the payment must be made in cash – not in the form of a financial guarantee.
Downward adjustment of municipal fees
There has been considerable debate about municipal fees, as they have proven to vary widely from one municipality to another. The Danish Environmental Protection Agency is currently developing standardized calculation methods for municipalities so that prices will in future be calculated on a common basis. The new guidance is expected to take effect no earlier than Q1 2026. Concretely, this may mean that some fractions become cheaper while others become more expensive compared with current figures.
There have been various statements from business organizations, PROs, companies, and politicians regarding a possible three-month postponement of prepayments to municipalities. However, it is important to emphasize that this has not yet been decided. Until legislation is changed, the current rules remain in force, and invoicing can therefore still take place from 1 October 2025.
If municipalities reduce their fees, the benefit will apply to all companies – regardless of which PRO your company is a member of.
How your advance payment is calculated
The advance payment is calculated separately for each material category and includes all costs associated with both household and commercial packaging.
As a member, you pay a share based on your percentage of the packaging volumes made available on the market within each material category.
The advance payment is calculated using the following formulas, applied to both household and commercial packaging, as there are different cost requirements associated with each:
As a member, you are charged the total advance payment amount covering both your household and commercial packaging volumes.
The advance contribution is based on the packaging volumes you reported in the Returportalen for 2024. If discrepancies exist between your reporting in Returportalen and to DPA, the volumes from Returportalen have been used.
The advance payment covers the following costs
Specifically, the advance payment covers the following costs
Why do we charge an advance payment?
The purpose of the advance payment is to ensure liquidity in Emballageretur from day one, as invoices may start arriving as early as October 1, 2025, including from municipalities and compensation claims from waste-generating companies. Additionally, members must provide a financial guarantee by September 3, 2025, to Dansk Producentansvar (DPA).
It is important to note that should any legal changes or other developments affect the need for the advance payment, adjustments will of course be made accordingly.
Our obligation as a collective scheme
As a collective scheme, we are obligated to ensure your timely payments and your compliance with the producer responsibility for packaging. That is why an advance payment is necessary until your first reporting period (October 1–31, 2025) takes place between November 1–15, 2025.
Following this reporting Emballageretur will issue an invoice for your reported volumes for October. From that point on, Emballageretur can begin generating the liquidity required to cover your obligations without the need for an advance payment.
The advance payment has already been split into two instalments – one in August and one in November 2025. It is not possible to request a different split or payment schedule. In order for Emballageretur to meet its financial obligations to municipalities and other partners, payment must follow the two predetermined invoices.
Calculating each company’s advance payment requires a clear overview of the total expected costs at the start of the system. As many different stakeholders are involved in the extended producer responsibility system, we had to wait for the necessary pricing information before we could determine the exact amount for each company.
If there are significant deviations between expected and actual costs, a regulation will be made in 2026.
The invoice will be sent on 18 August 2025.
The timing is based on when different parties – such as municipalities and operators – require payment.
Thereafter, ongoing costs will be covered through the monthly environmental contributions, which will be collected retroactively starting in November 2025.
The invoice has a payment deadline of 30 days from the date of receipt.
The advance contribution is calculated based on the actual 2024 packaging volumes that you reported by 31 May 2025.
We are aware that these volumes may involve uncertainty. Therefore, we will adjust the advance contribution in 2026 based on the volumes you report monthly from 1 October 2025 to 31 March 2026.
The adjustment will reflect the difference between the initial and actual reported amounts.
Prices are set by Emballageretur’s members, divided into member sections. The prices are determined based on purchased services and the scheme’s expected costs – and are discussed and approved by the members of each section.
If you would like more insight into how the pricing process works and wish to have a say in the decisions, we encourage you to participate in the next section meeting on 17 September 2025.
Please write to info@emballageretur.dk if you wish to attend.
Emballageretur