The German ZSVR agency launched the LUCID packaging register in January 2019. Since then, all companies selling products to German consumers are required to register and declare their annual packaging weight.
Who should register for the LUCID packaging register?
All producers and traders who put sales packaging into circulation that accumulates as waste at the private end consumer must comply with the obligations of the German Packaging Act and must therefore register with the LUCID packaging register.
What should you consider when registering?
The LUCID packaging register was set up by the Central Agency Packaging Register so that companies that put packaging into circulation can share the costs of recycling packaging waste as part of their product liability and thus put the recycling economy on a sustainable footing. Registration in the LUCID packaging register can only be done by the companies themselves. Affected companies cannot commission a third party, such as bilateral systems, to carry out registration or Data Reports on their behalf.
What information is publicly available in the LUCID packaging register?
In addition to the general public, your competitors can also see the following information
- Company and company address
- Contact data (Postal address, e-mail, telephone number)
- LUCID registration number
- Date of entry or, if applicable, date of exit (you must inform the ZSVR if you cease your business activity in Germany)
- Brands you sell
Of course, you can look at the LUCID packaging register to find the same information about your competitors. What is not publicly available is the amount of packaging waste a company produces in a year or which recycling scheme it operates. This information is only available if ZSVR ensures that all market participants fulfill their obligations.
Step by step Registration in the LUCID packaging register
There is no fee for registration. Thus, there is no additional cost for companies that are required to register.
In order to properly comply with your obligations under the Packaging Act, your registration must be complete and error-free. Otherwise, you are not complying with the law and should expect warnings from the Central Agency Packaging Register, the control body of the VerpackG. For your convenience, we have prepared a clear registration guide:
- Click LUCID registration page for manufacturers.
- Create a login (just follow steps 1 to 4 on the page).
- Confirm data within 24 hours via verification link received by email.
- Complete master data in the LUCID account.
- License your package via Lizenzero with a binary system such as Interseroh+ (if not already done) this is VerpackG’s 2nd obligation, the system participation obligation; only after this additional obligation has been fulfilled can registration with LUCID be completed, see points 6) to 8).
- Send your registration number to your binary system.
- Specify the name of the binary system in the LUCID master data.
- Under the “Data Report” tab, enter your licensed packaging volumes for the current year.
New regulations are being introduced for online retailers selling to Germany that will affect their sales. If you are a seller in the German market, the VerspactG (Packaging Act) is of particular interest to you. Until July 1, 2022, failure to comply with the law may result in the suspension of distribution of your products in the country or heavy fines.
What is the VerpackG (Packaging Act)?
The VerpackG is a law that obliges shippers of packages to Germany. It replaced the December 1, 1991 VerpackV (Packaging Ordinance) and came into force on January 1, 2019.
On January 1, 2019, Germany’s VerpackG (Packaging Act) came into force. Negotiations for the German packaging law, which has been in force for the last 3 years, were finalized in 2021 and it was agreed that the most current version of the law will enter into force on July 3, 2022. This packaging law encourages the reuse and even recycling of packaging materials used in packaging (cardboard boxes, tape, bubble wrap). New on the agenda: Registration and certification of a license by 1 July 2022.
What needs to be done to comply with the Packaging Law?
After the theory and glossary explanations, let’s talk about the practical side. How to get a LUCID license and a certificate for compliance with the Packaging Code?
1) You need to register with the LUCID Packaging Register on the ZSVR Verpackungsregister website (Germany’s official central registration system). In this way, you will receive your register, i.e. your member number.
2) You need to get a certificate from one of the Dual Systems. In these systems, you indicate the annual amount of packaging materials you use and the fee you have to pay is calculated for you.
3) You need to inform LUCID of the certificate number you received.
4) Finally, you should not forget to add the legal logo given to you after making your payment at Dual Sistem to your packages.
What happens if the Packaging Act is not complied with?
Failure to obtain a certificate, failure to obtain a LUCID license, failure to declare quantities in DUAL systems or false declaration of quantities is considered an administrative offense under the Packaging Act.
If you do not comply with the Packaging Act:
– You may receive a written warning.
– If you sell unregistered products, you can be fined up to €100,000.
– If you do not participate in the recycling system, you can be fined up to €200,000.
– If you do not pay for the materials you use from one of the Dual Systems and do not obtain a LUCID license, you can receive an immediate sales ban. Therefore, from July 1, 2022, you will not be able to distribute any of your packaged products in Germany.
In addition
The Central Packaging Registration Office registers all companies and makes them publicly available. The purpose of transparency is to ensure fairness in competition. Anyone can report those who conduct unregistered trade.
Inform your buyers about return and recycling options
The new packaging law also requires sellers to provide information to buyers about return and recycling options. You can post this information as a message in your shop in the marketplace where you sell. For more information, visit the LUCID website or seek legal advice.
