What is the LUCID Packaging Register?
The LUCID Packaging Register is a publicly accessible database created by the Central Agency Packaging Register (ZSVR). The purpose of the Packaging Register is to promote transparency and ensure fair competition.
Why is it necessary?
- Under the German Packaging Act, initial distributors must participate in a dual system of their choice, through which they pay for the collection, sorting and recovery of the product packaging they’ve put on the market. However, not everyone complies with this obligation.
- The LUCID Packaging Register is there to monitor compliance. Clients, competitors, administrative authorities, dual systems, environmental and consumer associations can use the search function of this public register to check whether a specific initial distributor has met its obligation to license its packaging.
ZSVR: Who operates the LUCID Packaging Register?
The LUCID Packaging Register is operated by the Central Agency Packaging Register (ZSVR), which was set up as a private-law foundation by industry and trade associations. Since 1 January 2019, the ZSVR has been entrusted with tasks of public authority by the German Packaging Act. This means that it now acts as an authority of national scope.
The ZSVR’s activities are monitored by the legal and professional supervisory body of the Federal Environmental Agency and its development and operating costs are refinanced by contributions that are ultimately borne by the dual systems, such as Noventiz Dual.
What are the tasks of the Central Agency Packaging Register (ZSVR)?
The tasks of the ZSVR are defined in the German Packaging Act as follows:
Who must register with the LUCID Packaging Register?
Many businesses feel overwhelmed by the requirements of the German Packaging Act and wonder whether they are required to register with the LUCID Packaging Register. What’s more, there are regular updates to the German Packaging Act, which may affect and change the obligation to register. The most recent amendments to the Packaging Act came into force in July 2022. Currently, the following groups must register with the LUCID Packaging Register:
- Initial distributors of all types of packaging filled with goods
- This includes transport packaging or reusable packaging subject to mandatory deposit, for instance
- Final distributors of filled food service packaging also have to register with the packaging register, even if they have purchased pre-licensed packaging
- All groups must provide information concerning their packaging
Let’s talk about licence fees: How much does it cost to register with the LUCID Packaging Register?
Registration with the LUCID Packaging Register, data reporting and all related tasks of the ZSVR are free of charge for the producer/initial distributor. The Central Agency Packaging Register is financed exclusively by approved systems and sector-specific solutions. Regardless of whether they have registered with the LUCID Packaging Register, producers must pay to participate in a dual system. These participation fees are used to pay for the disposal of the packaging they’ve placed on the market.
Fines and distribution bans: What happens if I don’t register?
Failure to register with the LUCID Packaging Register is a big risk. Non-registered goods and packaging are subject to a distribution ban. This also applies to downstream distributors. Placing packaging on the market without registering with the LUCID Packaging Register is a regulatory offence. Failure to register is punishable by a fine of up to 100,000 euros, and failure to participate by a fine of up to 200,000 euros.
Online marketplaces such as Amazon or eBay will ask their marketplace sellers for their EPR number, which they receive once they have registered with the LUCID Packaging Register. Selling goods without this registration number is prohibited and the shop may be closed.
Where to get a packaging licence
Get a packaging licence and participate in Noventiz Dual now
Packaging volume reports and more: What needs to be reported to the packaging register?
The first step for the producer is to register with the LUCID Packaging Register. Depending on the type of packaging, this includes a reporting obligation.
Packaging volume reports for producers of packaging which is subject to mandatory participation:
- Anyone who distributes packaging subject to mandatory participation must regularly report the quantities actually placed on the market to a dual system.
- This basically means making two reports, as the packaging volume must be reported both to the dual system and to the ZSVR. In addition to the registration number, type of material and mass, the ZSVR also requires the name of your dual system and the period during which your business participated. There are specific take-back schemes for reusable beverage packings subject to mandatory deposit and for transport packaging.
Declarations of completeness for producers of packaging which is subject to mandatory participation:
- As soon as a certain minimum amount of packaging is placed on the market, producers must submit an annual declaration of completeness to the packaging register, in addition to the packaging volume reports.
- This declaration of completeness contains the packaging volume that was actually placed on the market in the previous calendar year.
- Please note: This declaration must be made by an independent expert, tax consultant, public auditor or accountant.