Denmark: producer responsibility for assembled packaging
The Ministry of Environment has recently adjusted its interpretation of producer responsibility for packaging. The changes primarily concern who bears producer responsibility when a company purchases packaging elements from other producers and assembles them into a complete packaging.
Previously, producer responsibility was assigned to the producer of each individual packaging element. From now on, it shifts to the company that assembles those elements, puts its name and brand on the final packaging, and uses it for any of the following purposes:
Packing
Protection
Handling or presentation
If you produce packaging elements that another company then combines into a complete retail packaging, you will no longer carry producer responsibility for that retail packaging. Responsibility will lie with the company that brings together the different components and affixes its name and brand to the assembled packaging.
Labels containing information such as bar codes, addresses, or other statutory details are not considered part of the packaging itself and therefore do not fall under producer responsibility. By contrast, if you as a producer apply your own name‐ or brand‐labels to the packaging, you will automatically assume producer responsibility for the entire packaging—not just for the label.
