Welcome to our resource center for reporting actual packaging quantities made available in 2024. This page is provided to give you all the tools and information you need to complete your reports accurately and on time.
NOTE: Please note that you have previously reported the expected quantities for 2024 – now it is time to report the actual marketed quantities for 2024.
This reporting is mandatory, and the deadline for submission to Emballageretur is May 15 at 23:59 p.m.
📌 Note: You must report via Returportalen – this page is for information and reference materials only.
As a company, you are responsible for reporting all packaging volumes you have made available on the Danish market in 2024.
If you are unsure about what “making available” of packaging means, see DPA’s explanation here.
No types of packaging are exempt from reporting.
The reporting covers both:
Single-use packaging:
Packaging designed for one-time use before disposal or recycling.
Reusable packaging:
Packaging that is designed and placed on the market to undergo multiple trips or cycles by being refilled or reused for the same purpose.
See more about the difference between single-use and reusable packaging in our FAQ.
For both types of packaging, you must distinguish between:
Household packaging: Packaging where a private household is likely to be the end user.
Commercial packaging: Packaging that is not household packaging.
See more about the difference between household and commercial packaging in our FAQ.
The reporting is divided into the following material categories:
Cardboard
Paper
Ferrous metals
Aluminium
Glass
Plastic
Food and beverage cartons
Wood
Textile
Porcelain
Cork
Ceramic
Other materials
You must specify:
Whether the packaging is for household or commercial use.
Whether it concerns single-use packaging or reusable packaging.
For packaging that cannot be easily separated, report the total weight based on the primary material.
Indicate if the packaging should be sorted as hazardous waste or residual waste.
Note: If your total volume made available is under 8 tonnes, you may choose to report the overall quantity, divided into household and commercial waste. Read more in our FAQ
Please note: Once you have reported your volumes to Emballageretur via Returportalen, we will handle the registration of your data with DPA (Dansk Producentansvar).
You only need to report to Emballageretur – we will take care of the registration with DPA.
As a collective scheme, we are authorized by law to register and report quantities on your behalf. However, there are functions within DPA that we, as a collective scheme, currently cannot create or modify for you.
We can provide you with the ability to:
Add new material categories via Returportalen.
Report your quantities within already registered categories, including newly added ones.
We cannot:
Change reporting from total to category-specific reporting.
Remove categories.
Register you for reusable packaging.
We have currently identified some technical issues at DPA (Danish Producer Responsibility), which we have reported:
These errors may affect your company. We therefore recommend that you check whether you are impacted – especially if you experience problems with your registration or requests in DPA.
We have reported the known issues, but resolving them may require you to contact DPA directly, as the problems lie within their system.
If we have already identified that your company is affected, you will receive an email from us.
Identify all packaging you are responsible for throughout your value chain. Consider the source and end destination for each type of packaging.
Gather detailed data for all packaging you are responsible for. Prepare this data for reporting, including total weight and material composition.
As a member of Emballageretur, you have automatically been granted access to Returportalen. You should have received an email with a link to activate your user profile.
If the activation link does not work, it is often because your account has already been activated. In that case, simply request a new password via the login page. Click on “Forgot password,” and you will receive an email with the option to reset your password.
Remember to check that the email has not ended up in your spam or junk folder.
If you have neither received an activation email nor can gain access by resetting your password, please contact Emballageretur at info@emballageretur.dk for assistance.
No, once you have reported your volumes to Emballageretur via Returportalen, we will register your data with DPA (Dansk Producentansvar).
If your company’s total packaging quantities made available in 2024 are below 8 tonnes, you may be eligible to use a simplified reporting method.
This simplified method means that you:
Do not need to divide your packaging into individual material categories (e.g., cardboard, plastic, glass, etc.)
Instead, you only need to report:
The total weight of all your packaging made available
Divided into:
Household packaging
Commercial packaging
BUT – please note:
Even if your quantities are below 8 tonnes, it is not automatically possible to switch to the simplified reporting method if you have previously reported by material categories.
DPA (Danish Producer Responsibility System) has determined that:
If you want to switch:
From total reporting to category-based reporting, or
From category-based reporting to total reporting,
… this requires that:
Your current agreement with DPA is cancelled.
You then apply for the new desired reporting method.
This is a formal administrative process at DPA, which Emballageretur cannot influence.
Our recommendation:
If you have previously reported by categories, we recommend that you continue reporting in the same way as you are currently registered with DPA to avoid unnecessary administrative work.
If you wish to change your reporting method, it may be a good idea to wait and make the change before the next registration period.
To report your total actual packaging quantities for 2024, you must first identify which packaging you are responsible for within your value chain. This includes assessing any packaged products for resale and/or use in your own production, as well as packaged goods that you sell onwards — meaning those you make available on the Danish market.
Once you have mapped your responsibility, you can collect information about your packaging, for example, from your partners or suppliers.
NOTE: For this 2024 reporting, you do not need to know the exact composition of your packaging. You only need to specify the general material category, such as cardboard or plastic.
If your packaging consists of multiple material types, you must report it under the material category that constitutes the highest weight.
It is not possible for Emballageretur to change your status from total reporting to category-based reporting, or vice versa.
DPA states the following:
If a member needs to switch:
❑ from total reporting to category-based reporting, or
❑ from category-based reporting to total reporting,
then the existing agreement for all current categories must first be cancelled, after which you must apply for the new category or categories instead.
Therefore, we recommend that you continue reporting according to your current registration and wait to make any changes until the next registration period!
It is not possible for Emballageretur to change your status from category-based reporting to total reporting, or vice versa.
DPA states the following:
If a member needs to switch:
❑ from total reporting to category-based reporting, or
❑ from category-based reporting to total reporting,
then the existing agreement for all current categories must first be cancelled, after which you must apply for the new category or categories instead.
Therefore, we recommend that you continue reporting according to your current registration and wait to make any changes until the next registration period!
It is not possible for Emballageretur to remove categories you are already registered for in DPA.
If you wish to remove categories, you must log in to DPA and remove them yourself.
If you also want to deregister a category in Returportalen, you must notify Emballageretur so we can deregister it for you.
If you do not wish to completely remove or deregister a category, you can enter ‘0’ quantities in Returportalen.
We recommend that you report 0-quantities for categories in this reporting period to avoid errors.
The reporting is divided into the following material categories:
Cardboard
Paper
Ferrous metals
Aluminium
Glass
Plastic
Food and beverage cartons
Wood
Textile
Porcelain
Cork
Ceramic
Other materials
NOTE!
For quantities made available under 8 tonnes, you may choose to report the total quantity made available, divided into household and commercial waste.
When reporting packaging, you must distinguish between standard packaging, residual waste, and hazardous waste:
Standard packaging is packaging that—when it becomes waste—is expected to be sorted into material fractions for recycling and reuse.
Residual waste covers packaging where the material condition prevents recycling, but which is not hazardous and can typically be incinerated in a combined heat and power plant.
Hazardous waste refers to packaging contaminated by the product it contained—e.g., chemicals, paint, or spray cans. This waste may be harmful to health, environmentally hazardous, flammable, corrosive, or toxic.
If you have already registered your reusable packaging before the deadline on February 1, 2025, we expect that no further action is required.
It is currently unclear whether you need to report the actual quantities for 2024 for reusable packaging again. According to the legislation, it appears that you must, but there is some uncertainty, and DPA has not yet provided clarification.
However, if you have reusable packaging but have not registered the category in DPA, you must register the category in DPA along with the corresponding quantities.
Emballageretur cannot register the category for you in DPA.
The Danish Environmental Protection Agency’s clarification states:
Companies that have made available SINGLE-USE PACKAGING AND REUSABLE PACKAGING in 2024.
Companies that have made available both reusable packaging and single-use packaging before 31-12-2024, and who are already registered in DPA’s register for single-use packaging:
REGISTRATION OF REUSABLE PACKAGING:
You must reopen your registration with DPA and add reusable packaging as a packaging type.
For packaging that cannot be easily separated, you must report the total weight under the material that the packaging primarily consists of.
Definitions from the Packaging Order (BEK no: 323 of 20/03/2025):
Household packaging:
Packaging where a household is likely to be the end-user.
Commercial packaging:
Packaging that is not household packaging.
End-user:
Any natural or legal person residing or established in Denmark to whom packaging or filled packaging is made available, either as a consumer or as a commercial end-user in connection with their industrial or commercial activities, and who does not further make the packaging or filled packaging available on the market in the form in which it was supplied.
When determining whether your company makes available household packaging or commercial packaging, it is important to understand that it is not about who you sell to (B2B or B2C), but rather where the packaging ends up as waste.
It is the end-user—the place where the packaging is discarded—that determines whether it is household or commercial packaging.
For example:
If you sell your product to a wholesaler (B2B), and the wholesaler then sells it to a private consumer (B2C), the packaging will become waste at the consumer’s household. The consumer is responsible for sorting this packaging through municipal waste schemes. Therefore, in this case, it is considered household packaging.
If you sell a product to a company, for example shipped in a cardboard box, and the product is used in a business context, the packaging is considered commercial waste, since the cardboard box becomes waste at the company and is disposed of through their waste solution.
DPA states:
Reusable packaging is packaging designed to be refilled or reused for the same purpose multiple times. Typically, reusable packaging is part of a cycle where it is repeatedly delivered to the end-user and subsequently collected to be used again for the same purpose.
Reusable packaging is not packaging that a consumer may choose to reuse (e.g., a shampoo bottle that the consumer refills themselves).
Furthermore, reusable packaging is not packaging made from recycled materials.
Definitions in the Packaging Order (BEK no: 323 of 20/03/2025):
Single-use packaging:
Packaging that is not reusable packaging.
Reusable packaging:
Packaging that is conceived, designed, and marketed to undergo multiple trips or cycles during its lifetime by being refilled or reused for the same purpose.
When distinguishing between single-use packaging and reusable packaging, it is important to understand that it is not about whether the packaging happens to be reused several times in practice, or whether it is made from recycled materials.
What determines whether packaging qualifies as reusable packaging is:
Whether the packaging is designed to be used multiple times for the same purpose.
Whether there is a return system or scheme in place that ensures the packaging is actually returned and reused for the same purpose.
The producer of reusable packaging must ensure that, when the packaging is no longer reused and becomes packaging waste, it is taken back.
Examples:Reusable takeaway packaging, wooden or plastic pallets (e.g., EURO pallets), IBC containers, barrels and canisters with a return system, thermal boxes with a return system, transport boxes, etc.
If the packaging does not meet both of these criteria, it is considered single-use packaging—even if it is reused once or several times by the end-user.
Examples:
A plastic crate that is part of a return system and used repeatedly for transport is reusable packaging.
A cardboard box that is reused because the recipient decides to use it again is still single-use packaging.
In short:
Reusable packaging:
Designed to be used multiple times for the same purpose and included in a return system that ensures collection and reuse for the same purpose.
Single-use packaging:
Everything else—regardless of whether it is reused in practice or made from recycled materials. In principle, designed to be used only once and then discarded.
As a company, you must report the packaging volumes you have made available on the Danish market in 2024.
“Making available” refers to the first time packaging is made available to the end user in Denmark.
If you are unsure about the exact meaning of “making available”:
See DPA’s definition here: producentansvar.dk/en/documents/making-available
When reporting packaging, you must distinguish between standard packaging, residual waste, and hazardous waste:
Standard packaging is packaging that—when it becomes waste—is expected to be sorted into material fractions for recycling and reuse.
Residual waste refers to packaging where the material condition prevents recycling, but which is not hazardous, and can typically be incinerated in a combined heat and power plant.
Hazardous waste is packaging that has been contaminated by the product it contained—e.g., chemicals, paint, or spray cans. This waste may be harmful to health, dangerous to the environment, flammable, corrosive, or toxic.
If you are subject to producer responsibility in multiple countries, you can benefit from Retur’s co-ownership in PRONEXA, which acts as a one-stop-shop for producer responsibility across the EU, UK, Switzerland, and Norway.
If your company places packaging on the Danish market, you are very likely subject to producer responsibility for packaging. Several factors determine whether your company is covered, including whether your company is established in Denmark, another EU member state, or a third country.
Companies established outside Denmark can have producer responsibility in Denmark! To incur this responsibility, the company must meet the principle of ‘distance selling directly to an end-user.’
For example, if you purchase goods from a foreign company, that foreign company may hold producer responsibility for all packaging that becomes waste in your company.
If you forward the packaged products directly to your own customer or user, where the packaging first becomes waste there, then your company will be responsible for it—provided it is not under the customer’s/user’s own name and trademark.
If you are a company established in Denmark, you must also be aware that responsibility depends on the types of packaging you either produce or import.
A distinction is made between filled packaging, transport packaging, reusable packaging, service packaging, and primary production packaging.
No, producer responsibility does not cover the collection of commercial waste. You must therefore continue to have an agreement with a private waste contractor for the collection of waste at your company.
Emballageretur