Key change: Unpacker regulation
Previous obligation: When selling to distributors in Denmark, companies based outside Denmark were obliged to register and report transport packaging. The focus of the previous Danish regulation was on the end-user of the packaging. In future, the focus will be on the end-user of the product.
Example: A Greek company supplies tinned olive oil to a Danish shop. The tins are packed in cardboard boxes and shipped to Denmark on single-use pallets. The boxes and pallets become waste at the Danish shop.
- EPR obligation until 12 August 2026: the Greek seller was responsible for reporting the transport packaging in Denmark.
- EPR obligation from 12 August 2026: the shop that unpacks the goods, but is not the end user of the goods, becomes responsible for the transport packaging. The Greek seller is only responsible if the Danish purchaser is the end user of the product.
How does this affect my quantity reporting?
The changes to responsibilities also affect quantity reporting. Companies should check whether reported quantities will need to be included or excluded in future and keep the relevant supporting documentation to hand for inspections by the authorities.
Outlook across the EU
In Spain, too, the registration and reporting requirements for sales from abroad to Spanish distributors are set to change in a similar way. The Spanish decree, which is intended to amend the current Spanish Packaging Regulation accordingly, has yet to be published. We will inform you as soon as the producer obligations change following the publication of this decree.
If you have any questions or require packaging registration in Denmark, please contact us via consulting@take-e-way.de.
