Reporting in the deposit system

Note: The information on this page is no longer valid as of January 2020.

The Danish deposit and return system is based on ‘the polluter pays’ principle. This means that an importer or producer pays fees for each item of packaging sold, supplied or otherwise transferred in Denmark.

Reporting refillable packaging sold to shops

If you sell beverages in refillable packaging, you must report your sales and return volumes. 

However, this only applies to sales to shops: commercial enterprises that sell beverages to consumers on which deposits are payable that are intended for consumption in places other than the place of purchase. This also applies to intermediaries with fixed places of business and a wide selection of groceries. 

Reporting through the portal 

Both sales and returns reports should be submitted via Dansk Retursystem’s portal by the 15th of each calendar month at the latest. This is the only place at which suppliers can report. 

Reporting of products in one-way packaging with primary marking

As a rule, if you have one-way packaging with primary marking, you must report your sales using detailed reporting on a monthly basis. 

This means that on the 15th every month you must report how much you sell of each product (GTIN number) to each of your customers. Dansk Retursystem then collects operating fees based on your actual sales. 

However, if you ONLY have glass bottles in your range of products, you may choose modified reporting.

Use the portal 

Reports should be submitted via Dansk Retursystem’s portal The portal ensures that you can submit reports that are necessary for your business once you have registered. 

We recommend that you read our manual on reporting, and contact our Finance Department if you have any questions about reporting. 

Reporting of products in one-way packaging with secondary marking

For packaging with secondary marking, you have paid the deposits when purchasing the self-adhesive deposit marks. Reporting is necessary to enable Dansk Retursystem to collect the correct fees. 

You can choose to pay an average operating fee by not reporting your actual sales. Alternatively, you may report at a detailed level and pay the fees based on your actual sales. Please note that the type of reporting you choose is binding for the current calendar year. 

No reporting 

Choosing “no reporting” may be advantageous if: 

  • you want to minimize administration; and 
  • the average fees payable for your specific mix of packaging types are lower than the fixed fees. 

If you choose “no reporting”, you pay average fees, the deposit amount and the production costs when you purchase self-adhesive deposit marks. You do not need to report your sales afterwards. 

“No reporting” eases the administrative burden for many companies, especially for importers and producers, but it also means that Dansk Retursystem cannot calculate whether you have paid too much or too little in fees. You therefore pay an average operating fee. 

This type of reporting may have disadvantages, however, if the average fees payable for your specific mix of packaging are considerably higher than the operating fees. In this situation, you may choose “detailed reporting”. 

Detailed 4-week reporting 

Choosing “Detailed 4-week reporting” may be advantageous if: 

  • the operating fees for your specific mix of packaging are lower than the average fees; 
  • you want Dansk Retursystem to calculate your fees regularly based on your actual sales; and 
  • you already have an IT system that can assist you in managing detailed reporting. 

For this type of reporting, you only pay the deposit amounts and the cost of producing the labels when purchasing the self-adhesive deposit marks. Every 4 weeks you must report to Dansk Retursystem how many items of packaging with secondary marking that you sell per product (GTIN number) to each of your customers. You then pay fixed fees based on the actual sales. 

Reporting duties for importers, producers, intermediaries and distributors

Companies must report their sales volumes for registered products and packaging to enable Dansk Retursystem to collect the correct amount for the deposits and fees and pay the handling payment to shops for preparing the one-way packaging. 

Given the commercially sensitive nature of the figures, reports are submitted to an independent auditing company that processes the data and forwards a summary of the figures to Dansk Retursystem. 

In addition, you must report the return volumes of refillable packaging so that Dansk Retursystem can also pay handling payments to shops for sorting and separating the refillable packaging. Dansk Retursystem already has the data it needs to pay the handling payment for preparing one-way packaging. 

In most cases, you must report your sales volumes at a detailed level. In specific cases, you may submit reports at a modified level, which involves you providing less information (read more below). 

In situations in which you may choose between different types of reporting, please note that the type you choose is binding for the current calendar year. If you want to change your type of reporting, this will only take effect in the coming year. Any application to amend the type of reporting must be sent to Dansk Retursystem by November 30th at the latest. 

Intermediaries and distributors 

Intermediaries and distributors can read more about their obligations in the Danish deposit and return system under intermediaries and distributors

Below, you can find an overview of the different types of reporting that your company may be obliged to do.

Transitional reporting arrangements 

Importers and producers with packaging registered before February 1st, 2014 may also be covered by transitional reporting arrangements.

In general about sales reporting

For sales reporting, you may choose between detailed or modified reporting of sales depending on your annual sales volumes. Please note that the type of reporting you choose is binding for the current calendar year. 

Detailed 4-week reporting

 Companies that sell, supply or transfer more than 20 million items of refillable packaging annually must report their sales in detail. 

This means that you must report your sales every 4 weeks for each individual customer – listed by name and address and allocated according to the three sales and return groups:

  • glass packaging; 
  • PET plastic packaging of 0.99 litres or less; and 
  • PET plastic packaging of 1 litre or more. 
Modified 4-week reporting

You may choose “Modified 4-week reporting” if you sell less than 20 million items of refillable packaging annually. 

Modified 4-week reporting requires less administration because you only need to report how much you sell to all shops (including distributors) and to all intermediaries – allocated according to the three sales and return groups. 

Modified reporting for products in one-way glass bottles with primary marking

If you exclusively use glass bottles in your range of products and your annual sales do not exceed 1 million items of one-way packaging, you may also choose modified reporting. 

Choosing “Modified 4-week reporting” for glass packaging may be advantageous if you want less administration by using modified reporting. Please note that the type of reporting you choose is binding for the current calendar year. 

Reporting level 

For this type of reporting, you must choose one of three levels of modified reporting: 

  1. Reporting total sales per deposit group and per material group: for example, the number of deposit A marks in glass packaging. The fees are calculated based on average fees. 
  1. Reporting of total sales per volume and per material type: for example, the number of 0.33-litre aluminium cans. The fees are calculated based on operating fees. 
  1. Reporting per customer group (shops, intermediaries other commercial enterprises) by volume for each material: for example, the number of 0.25-litre glass bottles for shops. The total fees are calculated based on operating fees. 

To choose the reporting level that suits you best, you can compare the cost of average fees with the cost of operating fees for your exact mix of packaging and then choose the reporting level with the lowest fees. 

Please note that a more detailed reporting level may require more administrative time. You should choose “Reporting level 1” if you want the reporting level with the least administration. 

Return reporting

For return reporting, meaning how many items of packaging are returned to you, you must always report at a detailed level every 4 weeks, per shop (including distributors) or per intermediary – listed by name and address and allocated according to the three sales and return Groups: 

  • glass packaging; 
  • PET plastic packaging of 0.99 litres or less; and 
  • PET plastic packaging of 1 litre or more. 

Based on your reporting of sales volumes, Dansk Retursystem can collect the correct fees and can pay the handling payment to your customers based on your reporting of return volumes. 

In addition, you must report your total sales volumes annually to enable Dansk Retursystem to calculate the return percentage. 

Mandatory annual reporting

All importers and producers must report their total sales and return volumes of refillable packaging once a year. Based on the figures reported, Dansk Retursystem can calculate the national return percentage for refillable packaging. 

Dansk Retursystem is also responsible for checking that that your overall return percentage for refillable packaging is 75% after 1 year – and a return percentage equivalent to one-way packaging of the same material after 2 years. 

You report directly to Dansk Retursystem using a form that we send you. 

Fixed standards for reporting

Importers, producers, and intermediaries that have to report their sales and return volumes need to follow a fixed standard. 

To assist you with reporting, we have produced several templates as Excel spreadsheets. 

Individual companies may decide whether to use the templates, but the formats must be followed for us to receive the information reported. We recommend that, for security reasons, all reporting data be encrypted before being sent by e-mail. 

Reporting periods 

From 2016, the reporting period follows the calendar month and should be made at the latest by the 15th from January onwards.