For producers placing electrical or electronic products on the market in Denmark it is a requirement that the quantities placed on the market and reported are authenticated no later than 31 May by an approved auditor or the company’s management.

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.

Only producers of a certain size are subject to the requirement for submission of an auditor's attestation. Companies are exempt from the requirement for auditor's attestation and must instead submit a management’s statement if they comply with the following criteria:

1. The company has an annual turnover on the Danish market 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.

Management’s statement

The management must confirm the accuracy of the reported quantities of electrical and electronic equipment placed on the market no later than 31 May. The management’s statement is signed in the producer register on the DPA-System website, using NemID. It is important that the management of the company authenticates the management’s statement.

Auditor’s attestation

It should be the same auditor as the one doing the accounts of the company that submits the auditor's attestation. In addition, the auditor must be approved as stipulated in the Auditor General’s Act. The same requirements apply to auditors whether they are from Denmark, another EU country or from a non-EU country.

Deadline for auditor’s attestation is 31 May unless the company operates with an accounting year other than the calendar year. In this case a management’s statement must be submitted no later than 31 May confirming temporarily the reported quantities and stating when the auditor's attestation will be completed. Deadline for the auditor’s attestation is no later than five months after the end of the accounting year.

The auditor's attestation is completed in the producer register on The producer or his authorised representative sends an invitation from the register to the auditor who will then receive access information for completion of the auditor's attestation.

Last edited: 06/07/2020

Further information:

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

Criteria for exemption from requirement for auditor's attestation

Authorised representative and attestation of quantities

Only when quantities placed on the market are reported to the producer register will you have access to auditor's attestation and management's statement.

Now the producer can select type of statement and invite his auditor (if auditor's attestation).

Changes and additions to reported data

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