No, the Verpackungsgesetz (Packaging Act) prohibits the instruction of a third party for data reporting. Data reporting must be completed personally by the producer under obligation or an appropriately authorised contact person within the producer's company. This must also be confirmed with each report.

Exception: international producers under obligation without a branch within Germany can appoint an authorised representative to fulfil their duties under the Verpackungsgesetz on their behalf. (This does not apply, however, to registration.) Further information can be found in our knowledge base dedicated to authorising a representative.

As soon as a volume report is made to a system, the producer is required to report the same information to the LUCID Packaging Register. The reporting schedule depends on what is agreed in the system participation agreement.

If a producer has contractually agreed to provide a single report to a system per year (regardless of whether it contains planned or actual volumes), they also must report this information to the LUCID Packaging Register immediately. If a more frequent reporting schedule was agreed with the system (e.g. quarterly or monthly), the producer must also submit more frequent volume reports to the LUCID Packaging Register. 

The system participation agreement does not have to be submitted to the ZSVR or uploaded to your registration unless you are requested to do so. You just need to include the system operator and other details about the participated packaging in a data report to the LUCID Packaging Register.

No. Data reports must be submitted personally and electronically to the LUCID Packaging Register. It is not enough to send the ZSVR a volume confirmation. 

The company under obligation under the Verpackungsgesetz (Packaging Act) must itself submit the data report to the LUCID Packaging Register. 

There is an exception for international companies without a branch in Germany (for example companies located in China, the UK, the USA, Poland or Italy): if such a company has appointed an authorised representative to fulfil its obligations under packaging law, the authorised representative must submit the data report for the party under obligation. In this case, all the international company has to do is register with the LUCID Packaging Register and enter its authorised representative. 

You do not have to explicitly inform the LUCID Packaging Register about the change. With every data report in the LUCID Packaging Register, you enter the system with which you concluded an agreement. Going forward, when filing a data report simply enter the appropriate (new) system.

The obligation to report data about packaging volumes applies to companies that place packaging subject to system participation on the German market. Packaging subject to system participation includes retail, grouped and shipment packaging.

That means that if you exclusively place packaging on the German market that is not subject to system participation (for example transport packaging, reusable packaging and single-use beverage packaging subject to deposit), you do not have to submit data reports about your packaging volumes. An exception applies to declarations of completeness: declaring volumes of industrial retail and grouped packaging is mandatory.

Packaging that is not subject to system participation does not have to participate with a system. But recovery, return and documentation obligations do apply; these obligations are set out in section 15 VerpackG (Packaging Act).

Good to know: if your information in the LUCID Packaging Register states that you exclusively place packaging not subject to system participation on the German market, LUCID will not let you file a data report. 

In this case, you first have to report the change in packaging volumes to your system operator. Then submit a data report to the LUCID Packaging Register. This report to LUCID must contain the adjusted and confirmed volumes reported to your system. Which type of data report you have to choose in the LUCID Packaging Register depends on when you adjust your packaging volumes:

• Have you adjusted your planned volumes during the current forecast period? Then file an intra-year volume report in the LUCID Packaging Register with the new total volume. If you have already submitted an intra-year volume report for this forecast period, please adjust the volumes stated in this report.

• Have you corrected your planned volumes after the forecast period has expired? Have you reported the volumes you actually placed on the German market to your system? If the calendar year for which you have submitted your forecast report has ended, you have to submit a year-end volume report to the LUCID Packaging Register concerning those volumes.

That depends on the type of report in the LUCID Packaging Register. Let us have a look at two of these types, and how to edit them.

• Initial planned volume reports: You would like to correct your report for the current year? Then all you have to do is file an intra-year volume report containing the amended packaging volumes. The reporting period you have to enter is January to December. The initial planned volume report you had filed already will still be included in the overview of data reports. The newly filed intra-year volume report replaces the corrected initial planned volume report and is now considered to be your current forecast report.

• Year-end volume reports: If you can no longer edit a year-end volume report, you have to submit a supplementary volume report to correct it. In this supplementary volume report, you simply enter the difference between the year-end volume report that needs to be corrected and the actual volumes. If volumes need to be reduced, add a negative sign in front of the difference.  

Example: Your year-end volume report in the LUCID Packaging Register states that you placed 100 kg of paper, paperboard and cardboard (PPC) on the German market during the past year. This is wrong. You actually placed 120 kg of PPC on the German market and participated that volume with a system. If you can no longer edit your year-end volume report, you must file a supplementary volume report with the following value for the year in the question: 20 kg of PPC.