Textile EPR law in Denmark: None enacted

Denmark is not among the countries with enacted textile EPR legislation.

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What is Denmark EPR Batteries

Denmark's battery EPR framework is governed by Regulation (EU) 2023/1542 — the EU Battery Regulation — which applies directly in all EU Member States. The Regulation has applied in stages since 18 February 2024, with EPR and waste management obligations fully in force from 18 August 2025.

At national level, the Regulation is implemented through Statutory Order No. 986 of 20 June 2025, which defines national responsibilities for collection, registration, and reporting of batteries in Denmark. This statutory order replaced the previous Statutory Order No. 1453 of 7 December 2015 on batteries and accumulators, which transposed the former Batteries Directive 2006/66/EC.

The national producer register is managed by Dansk Producentansvar (DPA) — Denmark's central producer responsibility register covering batteries, electrical appliances, vehicles, packaging, and single-use plastics. The supervisory authority responsible for control and enforcement is the Danish Environmental Protection Agency (Miljøstyrelsen), which oversees compliance with both the EU Battery Regulation and Statutory Order No. 986 of 20 June 2025.

Battery producer responsibility has existed in Denmark for many years. The EU Battery Regulation significantly expands this responsibility — placing collection targets directly on producers rather than member states for the first time, and introducing new requirements for battery passports, carbon footprint declarations, and recycled content.

Does This Apply to E-Commerce & Online Sales

Yes. The EU Battery Regulation and Danish Statutory Order No. 986 of 20 June 2025 explicitly capture distance sellers and e-commerce operators. A company established abroad that sells batteries directly to Danish end users — whether as standalone batteries or incorporated into products — is subject to Danish producer responsibility.

Foreign companies established both within and outside the EU must register in the DPA producer register and designate an authorised representative in Denmark to comply with their obligations. It is not possible for a collective scheme to pre-register a foreign producer — the foreign producer must first select an authorised representative, who then completes the registration.

Online marketplaces are required under the EU Battery Regulation to verify that sellers on their platforms are EPR-registered in each country where they sell batteries.

Who is the "Producer" under Denmark EPR?

Under Regulation (EU) 2023/1542 and Statutory Order No. 986 of 20 June 2025, a company is subject to producer responsibility for batteries the first time it makes a battery available on the Danish market. Making available means any supply of a battery for distribution or use in Denmark in the course of a commercial activity. This covers:

1. Manufacturers established in Denmark who produce and sell batteries domestically under their own brand.
2. Importers bringing batteries into Denmark from non-EU countries for the first time under their own name.
3. Companies introducing batteries from another EU Member State into Denmark for the first time.
4. Private label owners whose brand name appears on batteries manufactured by third parties.
5. Distance sellers and online retailers established outside Denmark — whether in the EU or non-EU — who sell batteries or battery-containing products directly to Danish end users.
6. Economic operators who prepare batteries for re-use or repurposing — treated as producers for the second life of the battery.

Who Must Register for EPR Batteries in Denmark

All producers placing batteries on the Danish market must register in the DPA producer register (producentansvar.dk). Registration opened on 18 August 2025 under the new rules.

At registration, producers must:

• Report expected quantities placed on the market for the year of registration and the subsequent year (i.e. for 2025 and 2026 if registering in 2025)
• Register the battery chemistry of their batteries
• Select a collective scheme if they are a producer of portable batteries or LMT batteries — joining a collective scheme is mandatory for these categories

Producers of portable batteries and LMT batteries who do not join a collective scheme must apply individually for approval from the Danish Environmental Protection Agency. If a producer is a member of a collective scheme or has an authorised representative, the scheme or representative can apply for approval on the producer's behalf.

A one-off registration fee is payable to Dansk Producentansvar:

• DKK 1,000 for first-time registration
• DKK 500 for producers already registered under the former statutory order (Statutory Order No. 1453 of 7 December 2015) extending to new battery categories

Denmark EPR Battery Registration Threshold

Regulation (EU) 2023/1542 does not establish a minimum volume or turnover threshold below which producers are exempt from EPR obligations. All producers placing batteries on the Danish market must register and comply, regardless of size or volume.

The only exemption in the Regulation concerns batteries used in military or space equipment, which are outside the scope entirely.

For due diligence obligations, companies with annual net turnover below €150 million (as adopted under the Omnibus IV package, July 2025) may be exempt — but this does not affect EPR registration and reporting obligations.

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Batteries Covered (and Excluded)

Regulation (EU) 2023/1542 and Statutory Order No. 986 of 20 June 2025 define five battery categories, all within scope for EPR in Denmark:

Portable batteries Batteries weighing 5 kg or less that are not industrial batteries. Includes ordinary household batteries, batteries in consumer electronics, power tools, and toys. Producers of portable batteries must select a collective scheme.

Light Means of Transport (LMT) batteries Batteries providing motive power for electric bicycles, e-scooters, e-mopeds, and similar light electric vehicles. Producers of LMT batteries must select a collective scheme.

Automotive (SLI) batteries Starting, lighting, and ignition batteries used in vehicles.

Industrial batteries Batteries specifically designed for industrial use, or batteries that do not belong to any other category. Those above 2 kWh have additional requirements including battery passports from 2027.

Electric vehicle (EV) batteries Batteries used in electric cars and heavy electric vehicles.

Key exclusions:

• Batteries designed for military or space equipment — outside scope entirely
• Batteries in nuclear installations — excluded
• Second-life batteries where the operator performing re-use or repurposing becomes the new producer

Producer Responsibility Organization (PRO)

Denmark has an established PRO for batteries: Batteriretur. Batteriretur is a collective scheme for batteries operating across Denmark and manages collection, recycling, and reporting obligations on behalf of its members.

Joining a collective scheme is mandatory for producers of portable batteries and LMT batteries. For automotive, industrial, and EV batteries, producers may choose between joining a collective scheme or applying individually for approval from the Danish Environmental Protection Agency.

Batteriretur's services include managing collection infrastructure, reporting marketed quantities to the authorities, and guiding members through the transition to the new EU Battery Regulation requirements. Batteriretur informs its members about reporting requirements as they are confirmed by the authorities.

A list of all approved collective schemes in Denmark is published on the DPA website (producentansvar.dk).

EPR Registration in Denmark

The registration process for battery producers in Denmark is as follows:

1. Determine whether your business qualifies as a producer under Statutory Order No. 986 of 20 June 2025 and the EU Battery Regulation — i.e. whether you are making batteries available on the Danish market for the first time.
2. If established outside Denmark (EU or non-EU), appoint an authorised representative established in Denmark. A collective scheme cannot pre-register a foreign producer — the authorised representative must be designated first.
3. Register in the DPA producer register at producentansvar.dk. Report expected quantities placed on the market for the current and subsequent year, and register battery chemistry.
4. Pay the one-off registration fee: DKK 1,000 for new registrations, DKK 500 for existing producers extending to new categories.
5. For portable batteries and LMT batteries: select and join a collective scheme such as Batteriretur. The collective scheme or authorised representative applies for approval from the Danish Environmental Protection Agency on the producer's behalf.
6. For automotive, industrial, and EV batteries: either join a collective scheme or apply individually to the Danish Environmental Protection Agency for approval.
7. Submit annual reporting on quantities placed on the market and recycled, as required under the Regulation and Statutory Order.

Authorized Representative

Foreign companies established outside Denmark — both within and outside the EU — that sell batteries to Danish end users must designate an authorised representative in Denmark to comply with their producer responsibility obligations.

The authorised representative must be established in Denmark and is responsible for completing the DPA registration, selecting a collective scheme for portable and LMT batteries, applying for approval from the Danish Environmental Protection Agency, and managing annual reporting. The representative acts as the point of contact for Danish authorities.

A collective scheme cannot pre-register a foreign producer — the authorised representative selection must come first. This makes the appointment of an authorised representative the critical first step for any foreign battery producer entering the Danish market.

Important development: In December 2025, the European Commission proposed suspending the authorized representative requirement for EU-established companies until 2035. This proposal has not been formally adopted as of April 2026. For non-EU producers, the requirement is not affected and continues to apply.

What Data Must Be Reported

Producers registered in Denmark must report the following data:

• Expected quantities (kilograms) of batteries placed on the Danish market for the current and subsequent calendar year — reported at the time of registration and updated annually
• Battery chemistry for each battery category registered
• Actual quantities placed on the Danish market during the previous calendar year — annual reporting obligation
• Collection and recycling performance data, compiled and reported by the collective scheme on behalf of members

Reporting of marketed quantities for 2024 was due in Q1 2025 via SKAT (the Danish tax authority), under the transitional arrangements. Reporting of quantities for 2025 is expected to take place in Q1 2026, most likely via DPA, though this was not confirmed as of the scheme launch date.

First Reporting Period & EPR Reporting Deadlines

Battery EPR has been in place in Denmark for many years under the former statutory orders. The new EU Battery Regulation obligations and the new Danish producer register opened on 18 August 2025. Key dates:

• 18 August 2025: New producer responsibility rules enter into force. DPA opens registration under the new system. Producers must report expected quantities for 2025 and 2026 at registration.
• End of 2025: Deadline for existing producers to update registrations to the new five battery categories under the EU Battery Regulation.
• Q1 2025: Reporting of actual marketed quantities for 2024 submitted via SKAT (transitional arrangement).
• Q1 2026: Reporting of actual marketed quantities for 2025 — expected via DPA (to be confirmed).
• 1 January 2026 to 15 January 2026: Annual reporting window for portable batteries under the previous rules — Batteriretur confirms updated timelines for members.
• 18 February 2027: Battery passports mandatory for industrial batteries (>2 kWh) and EV batteries. Portable batteries must be removable and replaceable by end users.
• 18 August 2027: Due diligence obligations in force (delayed under Omnibus IV).

Labels & Marketing Claims

Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol covering at least 3% of the area of the largest side of the battery, up to a maximum of 5 × 5 cm.

Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb.

Capacity marking Portable and rechargeable batteries must display capacity information.

QR code From 18 August 2026, all batteries must carry a QR code. For LMT, industrial (>2 kWh), and EV batteries, this links to the Digital Battery Passport from 18 February 2027.

CE marking Mandatory from 18 August 2024.

Language requirements Consumer-facing information on batteries sold in Denmark should be provided in Danish where required under Danish consumer protection law.

Environmental claims All environmental and sustainability claims must comply with Danish consumer protection law and the Unfair Commercial Practices Directive. The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including Denmark.

EPR Eco Fees & Eco-Modulation

Denmark's battery EPR fee structure includes:

• One-off registration fee: DKK 1,000 (approximately €134) for new producers; DKK 500 (approximately €67) for existing producers extending to new categories
• Annual fee: payable per kilogram or tonne of batteries placed on the Danish market, set by the collective scheme and subject to annual review by the Minister of the Environment
• Collective scheme contribution: fees paid to Batteriretur or another approved scheme cover the costs of collection, sorting, and recycling

Under Regulation (EU) 2023/1542, eco-modulation — adjusting contributions based on battery environmental performance — is required across all Member States. Denmark's specific eco-modulation criteria under the new Regulation have not been separately published as of April 2026.

Risks, Penalties & Common Mistakes

1. Failing to register before placing batteries on the Danish market. The Danish Environmental Protection Agency is the supervisory authority and carries out control and enforcement. Companies that fail to meet registration obligations face risk of enforcement action including fines and market access restrictions.
2. Not appointing an authorised representative before attempting to register. A collective scheme cannot pre-register a foreign producer. The authorised representative must be designated first — attempting to register without one will be rejected.
3. Failing to join a collective scheme for portable and LMT batteries. Membership in a collective scheme is mandatory for these categories. Individual approval is only available for automotive, industrial, and EV batteries.
4. Missing the end-of-2025 deadline to update registrations to the new five EU Battery Regulation categories. Existing producers registered under the former statutory order must update their registrations by year-end 2025.
5. Assuming one EU registration covers Denmark. Battery EPR registration is national. Membership in a PRO in another EU member state does not fulfil Danish obligations.
6. Missing labelling requirements. The crossed-out wheeled bin symbol and CE marking are mandatory from August 2025. Labels must include Danish-language consumer information where required.
7. Missing the QR code deadline of August 2026. Companies should begin QR code implementation well in advance.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products contain batteries and whether they are being sold to Danish consumers — the obligation applies regardless of whether batteries are standalone or incorporated into devices.
2. If established outside Denmark, identify and appoint an authorised representative established in Denmark as the first step before any registration.
3. Register in the DPA producer register (producentansvar.dk), report expected quantities for the current and subsequent year, and register battery chemistry.
4. Pay the one-off registration fee of DKK 1,000.
5. For portable batteries and LMT batteries, join an approved collective scheme such as Batteriretur.
6. For automotive, industrial, and EV batteries, either join a collective scheme or apply individually to the Danish Environmental Protection Agency for approval.
7. Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, and capacity information as required from August 2025.
8. Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.

FAQ

Is battery EPR mandatory in Denmark?

• Yes. Battery EPR has been mandatory in Denmark for many years. From 18 August 2025, the new EU Battery Regulation (2023/1542) and Danish Statutory Order No. 986 of 20 June 2025 fully replaced the previous framework. All producers placing batteries on the Danish market must register with DPA, join a collective scheme (mandatory for portable and LMT batteries), and comply with collection and recycling obligations.

Do foreign brands selling online into Denmark need to register?

• Yes. Foreign companies — both EU and non-EU established — that sell batteries to Danish end users are subject to Danish producer responsibility. They must appoint an authorised representative in Denmark before registering. It is not possible to register without first designating an authorised representative, as collective schemes cannot pre-register foreign producers.

Is joining a collective scheme mandatory for all battery categories?

• Joining a collective scheme is mandatory for producers of portable batteries and LMT batteries. For automotive, industrial, and EV batteries, producers may choose between joining a collective scheme or applying individually for approval from the Danish Environmental Protection Agency. In practice, most producers join a collective scheme for all categories.

What is the registration fee for Denmark battery EPR?

• A one-off registration fee of DKK 1,000 (approximately €134) applies to new producers registering for the first time. Producers already registered under the former statutory order who are extending their registration to new battery categories pay DKK 500. Annual fees are also payable based on volumes placed on the Danish market.

Is there a minimum volume threshold below which registration is not required?

• No. The EU Battery Regulation does not establish a minimum volume or turnover exemption for EPR registration. All producers placing batteries on the Danish market must register and comply regardless of size or volume.