Annual reporting for reusable packaging 2025

Deadline: 30 April 2026

What must be reported?

If your company has placed Reusable packaging on the market in 2025, you must report:

  • the quantities of reusable packaging you have made available for the first time on the Danish market in 2025
  • the quantities of reusable packaging that were taken back and waste-managed via your take-back scheme in 2025

It is the difference between these two quantities that determines whether you will be charged for waste management.

Must be reported via Returportalen. Download the guide here.

You must report the quantities of reusable packaging that you have made available on the market for the first time for the purpose of completing a number of trips or cycles by being refilled or reused for the same purpose for which it was designed, during the reporting year.

The following categories must be reported:

Eco-modulated categories

Material category Green level (kg made available) Yellow level (kg made available) Red level (kg made available)
Residual Hazardous Ordinary Residual Hazardous Ordinary Residual Hazardous Ordinary
Rigid plastic
Flexible plastic
Foam plastic
Rigid PET
Beverage cartons
Material category Green level (kg made available) Red level (kg made available)
Residual Hazardous Ordinary Residual Hazardous Ordinary
Glass
Cardboard
Paper
Ferrous metals
Aluminium

Non-modulated categories

Material category Quantities made available (kg)
Residual Hazardous Ordinary
Wood
Textiles
Cork
Ceramics
Other

Combined reporting (only allowed when less than 8 tonnes annually)

Material category Quantities made available (kg)
Household packaging
Commercial packaging

Must be reported via Excel-sheet. The sheet must be completed and submitted to info@emballageretur.dk.

You must report the quantities of packaging waste collected through a take-back scheme during the reporting year.

Please note that establishing a take-back scheme is a requirement when registering reusable packaging.

The following waste fractions must be reported for the quantities taken back:

 

Made available in kg
Material category Residual Hazardous Ordinary
Glass
Rigid plastic
Flexible plastic
Foam plastic
Rigid PET
Beverage cartons
Cardboard
Paper
Ferrous metals
Aluminium
Wood
Textiles
Cork
Ceramics
Other

Are you unsure whether your packaging is reusable packaging?

Reusable packaging is packaging that is designed, manufactured and placed on the market to be used multiple times for the same purpose, and for which documentation exists showing that the packaging is actually reused in a return or rotation system.

For packaging to be classified as Reusable packaging, all three criteria must be met:

  • The packaging is designed for reuse and can withstand multiple use cycles
  • The packaging is placed on the market with the intention of reuse, for example through a return scheme or a rotation system
  • The packaging is actually reused in practice

If you are still unsure, you can read more about the definition and criteria for reusable packaging below.

Charges for reusable packaging in 2025

There is currently uncertainty regarding charges for reusable packaging, depending on whether a company chooses to report its reusable packaging quantities through a collective scheme or directly to Danish Producer Responsibility (DPA).

To ensure consistent and fair conditions for all companies, Emballageretur will therefore only charge an administration fee in 2025. This is done to avoid unequal treatment between companies, regardless of which reporting solution they choose.

The administration fee covers the costs associated with Emballageretur’s work, including the handling and transfer of company data, guidance and advisory services, as well as the operation and maintenance of relevant systems.

What data do you need to report correctly?

Below are the types of data you must/should record to ensure that you can document your reuse system, and therefore have the necessary data for reporting.

You must register the total quantity of reusable packaging (kg) that you make available on the Danish market for the first time in the reporting year.

This applies to packaging that you:

  • manufacture yourself, or
  • import into Denmark and place on the market for the first time

This forms the basis of your producer responsibility.

You must register how many reusable packaging units you send back into circulation as part of your business activities – for example through resale, distribution, or as part of your deliveries.

Register the quantity in kg based on:

  • number of units sent out × unit weight
  • dispatch data from logistics systems
  • scanning or tracking data (e.g. RFID/QR), if applicable

You must register the quantity of reusable packaging you receive back as part of the company’s activities.

This may include packaging that:

  • is returned by customers
  • is returned to warehouses, or
  • is collected by transport operators after use

This data is used to document circulation and to verify that the packaging is actually part of a reuse system.

You must register the quantity of reusable packaging that you waste-manage, for example because the packaging:

  • can no longer be reused
  • is damaged or worn out, or
  • is discarded through your take-back scheme

Important:
As a producer, you are financially responsible for your take-back scheme.

This means that:

  • you cannot apply for commercial compensation for these quantities, and
  • you must finance the collection, sorting, and handling of discarded reusable packaging yourself.

You must register the packaging that you export out of the country.

Calculate your quantities for reporting

Required data:

Opening balance: What is your stock level at the start of the year?

Closing balance: What is your stock level at the end of the year?

Quantities made available during the year: How many new reusable packaging units have you imported or manufactured and placed on the Danish market?

Quantities taken back during the year: How many reusable packaging units have you taken back and waste-managed after end-of-life?

Exported quantities during the year: How many reusable packaging units have you exported out of Denmark?