As outlined in the blog post on Denmark’s new EPR rules on packaging, the Danish framework introduces significant new obligations for producers from October 2025. However, this national regime is not the end point.
From August 12, 2026, EU-wide requirements under the Packaging and Packaging Waste Regulation (PPWR) apply directly. This means packaging must meet harmonized EU rules on recyclability, labeling, and restricted substances across all Member States.
For companies, early preparation is critical to avoid costly redesigns, compliance risks, and disruptions to cross-border sales.
What is changing from August 12, 2026?
Unlike earlier directive-based legislation, the PPWR is a regulation and therefore applies directly in all EU Member States. Any conflicting national rules must be adjusted accordingly.
National EPR systems, including the Danish system, will continue to operate. However, they must align with EU-level requirements on:
Packaging design
Recyclability criteria
Labeling standards
Core EPR principles, including cost allocation
This marks a shift from managing multiple national packaging regimes to preparing for a single, harmonized EU compliance framework.
What requirements apply under the PPWR?
A central element is the requirement that all packaging must be designed for recycling. Packaging must be capable of being collected, sorted, and recycled in practice, in line with EU-defined recyclability criteria. Packaging that does not meet these standards, or that contains restricted substances, will no longer be permitted on the EU market. For example, plastic food packaging containing PFAS above permitted thresholds for grease or water resistance will be banned.
In parallel, the Regulation introduces harmonized labeling requirements across the European Union. Packaging will be required to carry standardized information on material composition and disposal, replacing today’s fragmented national labeling systems. This is intended to improve consumer sorting and enable more efficient waste collection and recycling across Member States.
EPR remains a core principle under the new framework, but with increased harmonization at EU level. Producers will continue to finance the collection, sorting, and treatment of packaging waste through national systems. However, key principles such as cost allocation and incentives linked to recyclability will increasingly be governed by EU-level rules rather than national discretion.
Who is affected?
They carry the main responsibility for ensuring that packaging complies with EU recyclability and substance requirements. They must also ensure packaging data is available to support reporting and fee calculations across all relevant markets.
For companies active in multiple EU countries, this requires a more standardized packaging strategy and closer coordination between sustainability, procurement, and product teams.
Importers and distributors may qualify as producers under the Regulation if they are the first to place packaged goods on the EU market. This increases the need for due diligence, particularly where packaging design is controlled by non-EU suppliers.
Cross-border sales increase exposure under the PPWR. While harmonization reduces national differences, it also raises expectations around registration, reporting, and fee payment across multiple jurisdictions.
Packaging compliance can no longer be approached solely from a Danish perspective. All packaging must meet EU-wide requirements by default, regardless of where it is first placed on the market.
Several Member States have operated stricter EPR systems for years. Germany is known for detailed reporting and strong enforcement, while France applies eco-modulated fees to incentivize more sustainable packaging designs.
These approaches reflect the polluter pays principle, under which producers bear the environmental costs of their packaging.
Unlike countries that apply minimum thresholds for EPR obligations (for example, 50 tonnes in the Netherlands or 2 tonnes in Cyprus), Denmark applies EPR requirements to all packaging, regardless of volume.
How we can help your organization
Supplier engagement
Support in establishing processes to collect detailed packaging composition data from suppliers.System setup
Assistance in identifying and implementing IT tools for reporting, fee calculation, and eco-modulation.Knowledge building
Training sessions, webinars, and advisory support to help teams understand obligations, timelines, and practical next steps.
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