Appendix A: Denmark
A.1 Country Specific Remarks
Denmark's country-specific remarks are explained in the technical sections where relevant.
A.2 The Waste Management in Denmark
In Denmark, municipalities are responsible for handling household waste and they are obligated to sort the waste into the following ten fractions: glass, metal, plastic, paper, food and drink cartons, cardboard, textiles, food waste, hazardous waste and residual waste. The municipalities are also obligated to establish collection schemes for these fractions as a direct curb side pick-up service from all households. The ten fractions must be collected separately. However, the following combinations are permitted (Affaldsbekendtgørelsen, 2024):
- Paper and cardboard
- Metal and glass
- Metal and plastic
- Plastic and food and drink cartons
- Plastic, metal and food and drink cartons
Some municipalities have had issues setting up the new collection schemes, due to practical issues, such as waste containers being on back order or contracts with waste collectors, which cannot be changed in time. The last municipalities are expected to have collection schemes set up for all 10 fractions during 2025.
Other waste from households, such as construction waste and garden waste, is collected at municipally owned recycling centers. The municipalities operate about 320 recycling centers across Denmark where they primarily receive waste from households but also from smaller businesses. It is up to the individual municipality to determine which fractions should be available at recycling centers in order to ensure recovery of suitable waste materials from households. Denmark regards all waste from recycling centers as household waste, including construction and demolition waste. In this way, the Danish definition of household waste differs from the EU definition of MW.
The municipalities are also responsible for the collection and treatment of MW suitable for incineration from companies. The companies themselves are responsible for their MW suited for recycling. They are obligated to sort their MW in the same way as the curb side collections schemes for households and they have the same options for combination of fractions.
Finally, the municipalities have had the duty to classify all waste in the municipality. This also includes non-MW. However, from as of 1 January 2025 this practice has changed, which means that now the classification of waste is centralized at the Danish Environmental Protection Agency.
In general, all waste is collected by private waste collection companies. For recyclable household waste, the municipalities have tenders for the collection and treatment. In a few instances, household waste is collected by waste collection companies owned by municipalities – this practice changed starting from 2023 when all collection had to be done by tenders. Waste from municipal institutions (e.g. municipal administrations, schools, day-care centers, sports halls and nursing homes) may still be collected by companies owned by municipalities.
The companies, in charge of the treatment of waste, are obligated to report to the Danish Waste Data System and they must be registered in the Danish National Waste Register as only companies that are registered in the Waste Register are legally authorized to handle waste in Denmark (Bekendtgørelse om Affaldsdatasystemet, 2021).
A.3 Producer Responsibility Schemes in Denmark
Denmark has implemented extended producer responsibility on batteries, electrical and electronic equipment and, most recently, Single-Use Plastics, as of January 2025. The introduction of EPR on waste fractions, which are included in the measurement of MW, has not significantly affected the practical administration or data collection pertaining to statistics on MW. This is primarily because all waste actors are obligated to report waste data to the Danish EPA, regardless of whether the waste falls under an EPR scheme or not. Additionally, accordingly to the Directive 94/62/EC on packaging and packaging waste, Denmark partially introduced EPR on packaging by the end of 2024 and the rest will be implemented by 1 October 2025. Packaging waste will continue to be collected alongside non-packaging waste in separate waste fractions. The amount of packaging waste will be determined based on waste sorting analysis carried out on both MW and business waste.
A.4 Collection of Data on Municipal Waste in Denmark
A.4.1 The Danish Waste Register, the Danish Waste Data System and Waste Actors
The Danish Waste Data system is a comprehensive system designed to manage and record waste data in Denmark and has existed since 2011. It is a digital platform that facilitates the collection, processing, and analysis of waste-related data, providing insights for both government bodies, waste producers and waste management companies.
All entities involved in the handling of waste, including collectors, receivers, exporters, and importers, are obligated to report waste data to the Danish Waste Data System. Each report must include details about the waste's origin (meaning who generated the waste), type, quantity and treatment. Exporters are also required to specify the recipient of the waste and the percentages recycled. In the case of waste generated by companies and public institutions, the reporting should include the company/institution's CVR (Central Business Register/VAT no.) and P-number
The P-number (Production Unit Number) serves as a unique identifier for physical locations where economic activities are conducted.
Municipalities are only obligated to report to the Waste Data System, if they treat the waste themselves (e.g. composting garden waste at recycling centers) or export the waste directly.
During the waste flow different actors report the same waste since the responsibility of the waste changes from the collection of the waste to treatment. This does not present an issue regarding double counting since the data system is able to recognize whether the waste is already in the system. The first time the waste is reported (typically by a collector) it is seen as primary waste. When the same waste is then reported respectively by a sorting facility and by a treatment facility the waste is seen as secondary waste (see Figure A1). Only the primary waste is counted as generated waste. This is done by using the information from the Danish Business Register as described above.
Figure A1: Visualization of reporters to the Danish Waste Data System. Waste Flow (arrows). Reporters (collector and receiver) reports to the Waste Data System (dotted arrows)
Even though the waste data system gets several reports for the same waste during its flow, there are issues when it comes to tracking the waste streams. The waste codes may change throughout their journey from collection to final treatment, as the waste undergoes further sorting, pre-treatment and is mixed with waste from other sources. The change in waste codes is not necessarily an error, for example, when LoW codes from Chapter 19 are applied. However, this makes tracking specific waste streams through the waste system difficult.
The reporters also find it difficult to accurately indicate whether or not the waste is undergoing final treatment. The Danish EPA are planning a communication effort aimed at giving the reporters a better understanding of how to use the R/D-codes to indicate pre-treatment and final treatment.
The waste actors report annually to the Waste Data System. It is possible to report to the Waste Data System using a manual report, by uploading a csv template or directly transferring data from the waste actor/reporters’ system to the waste data system via an API.
The Danish Waste Data System sees an annual average of 800 companies reporting, which collectively describe waste from approximately 100,000 waste producers. Reports are made annually by March 1st for the previous calendar year and must be submitted electronically via the online platforms in the Waste Data System. The above is stipulated in the Danish Bekendtgørelse om Affaldsdatasystemet (2021).
Data reported to the Danish Waste Data System is managed by the Danish EPA. Before the data can be reported to Eurostat by the Danish EPA it is quality assured and remodeled by means of different data programs to achieve the correct delineation of MW. This is explained in the following sections.
A.4.2 Information Collected for Calculating the Generated and Treated Amounts of Municipal Waste in Denmark
The waste actors who report to the Danish EPA report the following information:
Type of waste | LoW codes and Danish waste code |
Quantity of waste | Weighed or estimated in ton |
Origin of waste |
|
Type of waste treatment | R/D-codes and Danish treatment codes |
Additional information | In addition, the Danish EPA collects NACE codes from the National Central Business register. |
A.4.3 Specifications on Generated Municipal Waste
For Denmark, the data reported as generated amounts equals the data for separately collected amounts. The separately collected amounts are solely the amounts reported to the Waste Data System as having been collected. All fractions, within MW, are separately collected. In the event that two fractions are collected in the same bin, the reporter is advised to report the two amounts separately.
When we need to determine how much waste is MW, we extract data from the Waste Data System delimited by LoW codes. However, when we need to determine how much waste has been treated, this is done using the Danish waste codes, as it is possible to determine the treatment of specific materials via them, which is actually not possible with LoW codes, as they are linked to the origin of the waste more than the material itself. We calculate final treatment percentages on the Danish waste codes, which we then transfer to the LoW codes. The connection between LoW codes and Danish waste codes can be seen in the table below.
Table A1: Overview showing the compliance between Denmark’s collected data and the data reported to Eurostat
Data reported to Eurostat / LoW codes | |||
National code | Description in the national data system | LoW code | Municipal waste |
E19/E19 | - Iron and metal | 20 01 40 | Metals |
H12/E12 | - Packaging metal | 15 01 04 | |
H12/E12 | - Packaging metal | 15 01 11 | |
E07/H07 | - Glass | 20 01 02 | Glass |
E11/H11 | - Packaging glass | 15 01 07 | |
E08/H08 | - Plastic | 20 01 39 | Plastics |
E13/H13 | - Packaging plastic | 15 01 02 | |
H05/E05 H06/E06 | - Paper incl. Newspapers - Cardboard | 20 01 01 | Paper and cardboard |
H09/E09 H10/E10 | - Packaging paper - Packaging cardboard | 15 01 01 | |
H02/E02 | - Food waste | 20 01 08 | Bio-waste |
H02/E02 H38/E38 | - Food waste - Bio-waste, where no other code is more accurate | 20 01 25 | |
H17/E17 | - Garden waste | 20 02 01 | |
H15/E15 | - Wood | 20 01 37 | Wood |
H15/E15 | - Wood | 20 01 38 | |
H30/E30 | - Packaging wood | 15 01 03 | |
E39/H39 | - Textiles | 20 01 10 | Textiles |
E39/H39 | - Textiles | 20 01 11 | |
E39/H39 | - Textiles | 15 01 09 | |
H40/E40 H41/E41 H42/E42 H43/E43 H44/E44 H45/E45 H46/E46 | - Light sources - Solar panels - Large WEEE - Equipment for temperature exchange - Small WEEE - Screens, monitors - Small IT equipment | 20 01 21 20 01 23 20 01 35 20 01 36 | Electrical and electronic equipment |
H48/E48 H49/E49 E50/H50 | - Portable batteries - Industrial batteries - Car batteries | 20 01 33 | Batteries |
H48/E48 H49/E49 E50/H50 | 20 01 34 | ||
H03/E03 H27/E27 | - Combustible waste, where no other code is more accurate - Bulky waste or alike | 20 03 07 | Bulky waste |
H01/E01 | - Residual waste | 20 03 01 | Mixed waste |
H36/E36 | - Mixed packaging waste | 15 01 06 | |
H26/E26 H29/E29 | - Hazardous waste, where no other code is more accurate - Other waste | 20 01 13*, 20 01 14*, 20 01 15*, 20 01 17*, 20 01 19*, 20 01 21*, 20 01 23*, 20 01 26*, 20 01 27*, 20 01 28, 20 01 29*; 20 01 30, 20 01 21*, 20 01 32, 20 01 41, 20 01 99, 20 02 03, 20 03 02, 20 03 03, 20 03 99, 15 01 05, 15 01 10* | Other |
A.4.4 Specifications on Treated Municipal Waste
On the basis of reports to Danish Waste Data System, the Danish EPA calculates treated amounts of MW. Both the quantities that have been collected for a certain treatment form is calculated and the actual amount that undergoes final treatment (see Table A2 below).
When reporting to the Danish Waste Data System, the reporter must state the intended treatment, for which the waste is collected, received or exported/imported. They must report both a Danish treatment code as well as the R/D-codes. In addition, the reporter must state whether the waste is undergoing a final treatment or not.
If the waste actor (the reporter) exports waste, meaning the recipient is a foreign company, the waste actor needs to report this and include information on the foreign company receiving the waste. The reporter is obligated to obtain information from the receiving foreign company on the distribution on waste undergoing the following final treatments: recycling, preparing for reuse, incineration or landfill (Bekendtgørelse om Affaldsdatasystemet, 2021).
Many waste actors do not understand the recovery and disposal codes, since there are many codes and the difference is not clear. The Danish treatment codes are more intuitive, which is why the quality of the Danish treatment code use is better. This does, however, present a problem in determining final treatment as the Danish treatment codes do not differentiate between pre-treatment and final treatment.
Since multiple actors report to Danish Waste Data System, the waste flow for a particular fraction of MW, the obligation to report both the Danish treatment codes and the R/D-codes inform the Danish EPA which treatment form the waste is collected for and the amount of the waste that has actually been finally treated. The combination of the treatment codes is used in the estimation of the total amounts of MW that have actually been recycled, incinerated, etc.
Table A2 below shows how the Danish EPA defines waste that is collected for different treatment operations and how waste is defined that is actually treated by different treatment forms. The treatment form ‘Other recovery’ is not defined, and no treatment codes exist for this form. MW collected for a treatment operation is defined according to the Danish treatment codes and the actual treated amounts are defined by a combination of the Danish treatment codes and the R/D-codes. For some of the subcategories, this is optional to report on, thus complete data do not exist – see explanation in Table A2.
Table A2: Overview showing the compliance between Denmark’s collected data on treatment options, the actual treated amounts and what is reported in table 1 and 2 as the treatment forms defined by EU
Waste collected for a treatment form | Actual treated waste amounts | Data reported to EUROSTAT in table 1 and table 2 | ||||||
Definition of treatment form | National codes | R/D-codes | Definition of treatment | National code, description in the national data system | R/D-code | Definition of category/treatment form | Comments | |
Collected for preparing for reuse | 10 prepairing for reuse | Actual amount prepared for reuse | 10 prepairing for reuse | R1, R2, R3, R4, R5, R6, R7, R8, R9, R10, R11, D1, D2, D3, D4, D5, D6 D7, D10, D11 and D12 | Preparing for reuse | Equals ‘Actual amount prepared for reuse’ | RECOVERY | |
Collected for recycling | 01 recycling | Actual recycled amount | R2, R3, R4, R5, R6, R7, R8, R9, R10 and R11 | Recycling material | Equals ‘actual recycled amount’ | |||
(of which Metal recycling from incineration bottom ash) | Data is not available | |||||||
Recycling composition and digestion | The amount of garden waste that is ‘actual recycled’ | |||||||
(of which Separate collection and recycling of biowaste at source) | Data is not available, since home compositing is not used widely | |||||||
Collected for incineration | 02 incineration, 07 incineration exemption from dues | Actual incinerated amount | R1 and D10 | Energy recovery | Equals ‘actual incinerated amount’ since all incineration facilities use energy recovery | |||
Collected for backfilling | 11 backfilling | Actual backfilled amount | 11 backfilling | R1, R2, R3, R4, R5, R6, R7, R8, R9, R10, R11, D1, D2, D3, D4, D5, D6 D7, D10, D11 and D12 | Other recovery | Equals ‘actual backfilled amount’ | DISPOSAL | |
Incineration | Data is not available, since all incineration facilities use energy recovery | |||||||
Collected for landfill | 03 landfill, 08 landfill exemption from dues | Actual landfilled amount | D1, D2, D3, D4, D5, D6 D7, D11, D12 | Landfilled | Equals ‘actual landfilled amount’ | |||
Other disposal | Data is not available | |||||||
As mentioned above, when reporting to the Danish Waste Data System the reporter must state whether a certain waste fraction undergoes final treatment or not. In practice, final treatment is indicated by clicking yes or no for final processing. Lots of waste handlers/actors do not understand the meaning of the term “final treatment” and the level of guidance varies across municipalities. Therefore, the Danish EPA assesses which facilities perform final treatment in Denmark. Final treatment facilities are understood to be facilities that carry out the final processing of all or part of the waste they receive. At the final processing (=final treatment), the waste ceases to be waste. The facilities are assessed on the basis of Danish Waste Data System reports and industry knowledge. The list contains for instance over 350 recycling facilities in Denmark.
A.4.5 Quality Assurance of the Data
The actors responsible for reporting to the Danish Waste Data System are responsible for the correctness of the reported data. The Danish EPA is responsible for supervising the reported waste data, which is why, when the Danish EPA receives the data, it undergoes a quality assurance process. The Danish EPA's quality assurance can be divided into three parts, of which the two first assurances are electronic and automatic, and the last one is manual. The data first undergoes an immediate quality assurance when the reporter tries to upload the csv file or presses submit in the manual report. The reporter will be notified about any errors before submitting. Secondly, the report undergoes a more thorough automatic validation overnight. If the system detects any errors, the entire report is rejected and the reporter is informed that the report has been rejected and on what grounds, so that the reporter can correct the errors and file the report again. After the reporting deadline, the third and final quality assurance takes place: a team in the EPA quality assures the data manually. The team reviews fluctuations in quantities at fraction, LoW Codes, company and treatment level and unlikely code combinations. If large fluctuations are detected, the reporting actor is contacted, and it is clarified whether there is a natural explanation, or an error occurred. Errors are often found by comparing specific data over an extended time period.
A.5 The Danish Delimitation on Municipal Waste
As all kinds of waste from industry and households in Denmark is reported to the national Waste Data System, the amount of MW needs to be delimited and determined. Since LoW codes and Danish waste codes are used in each reporting, these codes can be used to determine the amount of MW. Specifically, the LoW codes in Chapters 20 and 15 01 are used. However, the LoW codes reported to Danish Waste Data System are not sufficient to determine whether or not the waste is MW, since a lot of waste is reported using an MW LoW code, despite not being MW. This is mainly due to the fact that reporters find the LoW codes difficult to understand and overwhelming in number. The LoW codes in Chapter 20 have the simplest titles and are therefore used more often than they should. The Danish EPA is continually working on ways to make it easier for reporters to identify the correct LoW codes, and a lot of resources are spent on quality assurance to address this issue. However, the problem is so prevalent that the data undergoes a transformation process before it is reported to Eurostat. This is mainly done to eliminate non-municipal waste, but also to look for waste that should be reported as municipal waste but is listed incorrectly for various reasons. Finally, there are cases where non-municipal waste is correctly reported with an MW LoW code, e.g. non-municipal packaging waste like wooden pallets. These can be difficult to identify, but when it is possible, they should be excluded from the municipal waste reporting. The Danish EPA believes these issues with the LoW codes result in a significant overestimation of the total Danish MW.
In the data transformation, specific combinations of the company’s legal identification number and Danish waste codes/waste type are determined to be household waste in the Danish Waste Data System despite not being reported as such. The Danish EPA does this because it is a known issue for these specific reporters to report incorrectly on such code combinations.
In addition, the Danish EPA also determines some combinations of reported household waste codes by using the Danish waste codes in combination with a specific company number to be industrial waste because it is known that precisely these reporters are reporting incorrectly.
A.5.1 The Danish Method for Calculating Municipal Waste from Other Sources
In the data transformation, the Danish EPA uses the reported waste data under LoW Chapters 20 and 15 as a starting point and then uses the Danish waste codes to exclude non-MW from other sources according to the Danish interpretation. For instance, the Danish waste codes are used to exclude paper and cardboard from the paper and cardboard industry by deducting all "E05", "E06", "E09", "E10" (these Danish waste codes are non-household "paper incl. newspapers", "cardboard", "package paper" and "packing cardboard ") in combination with Industry Divisions 17 and 18 (which are the ID codes for the manufacture of paper/cardboard and paper/cardboard products).
Historically, waste analyses have been carried out on waste from other sources than households. On the basis of these analyses, our consultants have estimated that 90% of what is reported to the Waste Data System as waste corresponding to residual waste and suitable for incineration from other sources (except the service sector) have arisen in connection with production and other non-household-like activities. Only 10% of this type of waste are therefore included as MW for all industries apart from the service sector. This is the final exclusion of data.
A.6 The Danish Approach to the EU Methodology on Recycling
The estimation of the actual recycled amount of MW is made by the Danish EPA and it is calculated on the basis of reports to ADS. The calculation takes place in several steps (Danish EPA, 2022):
Data reported to the Danish Waste Data System is used to estimate the total amount of recycled MW. The collectors of waste and treatment facilities report the type of waste they have collected/received with the combination of the LoW codes and the “Danish waste codes”. As mentioned above, the treatment form of the waste is reported with the combination of the R/D-codes and the “Danish Treatment Codes”.
The actual recycled amount of MW needs to be summed up on the LoW codes, which MW consist of. The amount is not directly reported to ADS but needs to be estimated. For the estimation, the Danish waste codes is used. It would be optimal directly to use the LoW codes for MW, however, this is not possible since it is not feasible to trace the LoW codes through the waste flow: The LoW codes are based on the origin of the waste (the industry from which the waste originates). This means that the LoW codes change during the waste flow and therefore it is not possible to trace the LoW codes through the waste flow. In contrast, the Danish waste codes are based exclusively on material fractions, which explains why the waste can be followed through the waste flow.
The actual recycled amount of each MW fraction (LoW Codes) is estimated by multiplying the amount collected for recycling, which is reported to the Danish Waste Data System, with the calculated final treatment percentage:
Equation A1:
$$ {\scriptsize\text{MW actual recycled }(\textit{LoW})(\text{ton})=\text{ MW collected for recycling }(\textit{LoW})(\text{ton})\ast\overbrace{\frac{\text{Final treated by recycling } (\text{Danish waste codes}) (\text{ton})} {\text{Collected for recycling } (\text{Danish waste codes}) (\text{ton})}}^{{\textcolor{blue}{\text{Final treatment percentage \lparen Danish waste codes\rparen }}\textcolor{blue}{\%}}}} $$
- The final treatment percentage for the individual MW fractions indicates the percentage of the waste that is actually recycled as a proportion of the amount collected in the schemes for recycling.
- The final treated recycled amount (numerator in the formula) is calculated, as previously mentioned, on the basis of waste data reports to the Danish Waste Data System from facilities that have been assessed by the Danish EPA as final treatment facilities. If the waste is exported for recycling, the exporter reports the final recycled amounts to the Danish Waste Data System, which they are obliged to acquire information on.
- The amount of MW collected for recycling, including both LoW codes and the national waste codes, is directly reported to Danish Waste Data System as primary amounts.
- The actual recycled amount of each MW fraction thus contains both waste fractions collected from their intended waste scheme, as well as from missorting in other waste schemes, which are later sorted for recycling.
- The actual recycled amount of each MW-fraction is summed up, and then you have the total amount of all MW, which has been actual recycled.
When the Danish EPA calculates the total amount of recycled MW and the recycling rate, the amount prepared for reuse may either be included or excluded. In the report to Eurostat, the amount is reported separately. It is not possible to calculate the recycling rate of each MW-fraction since the total generated amount of each fraction is unknown. In fact, it is unknown since the missorted amount in the residual waste is not known. Only the collected amount of each MW-fraction is known.