Each year in the period from 1 January to 31 March producers and importers subject to producer responsibility must report quantities put on the market in the previous calendar year.

The producer is required to submit an auditor/management statement for all the years that are reported to the producer register, even if a zero quantity is reported.

Auditor’s attestation

For quantities put on the market  the reported figures must in certain situations be submitted to DPA-System with an auditor’s attestation.

Deadline for auditor's attestation to DPA-System is 31 May unless the the producer/importer operates with an accounting year other than the calendar year.

Management's statement

Companies are exempt from the requirement for auditor's attestation and must submit a management's statement instead if they comply with the following criteria:

1. The company has an annual turnover not exceeding DKK 1 million in electrical equipment subject to producer responsibility.


2. If the company, during the previous two years, has not exceeded 2 of the following criteria:

  • A balance sheet not exceeding DKK 4 million
  • A net turnover not exceeding DKK 8 million excl. VAT
  • An average number of full-time staff during the financial year not exceeding 12

The reported figures may be accompanied with a management's statement authenticating the reported quantities.

The mangement's statement must also be filled in electronically on the DPA-System website after login.

Producers’/importers’ own responsibility

Producers or importers are responsible for ensuring that figures are attested by an auditor or accompanied by a management’s statement.

Last edited: 03/07/2020

Further information:

Note: there is no duty of attestation of batteries.

Guidance for digital auditor’s attestation and management’s statement 

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