Registration must be completed before packaging filled with goods is placed on the German market for the first time.

Registration, data reporting and all the related activities of the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) are free of charge for producers/initial distributors. The ZSVR is financed exclusively by approved systems and sector-specific solutions. Independently of this, producers/initial distributors of packaging subject to system participation incur the costs of their packaging participating in the selected system(s), i.e. participation fees for the recovery and recycling of this packaging.

Providing a VAT number is not mandatory when registering in LUCID; the taxpayer reference number is sufficient. The primary purpose of the VAT number is to regulate cross-border transactions within the EU for value-added tax reasons. In many countries, as in Germany, this number is different from a regular identification or taxpayer reference number. Anyone without a VAT number will be automatically prompted to enter a taxpayer reference number after indicating accordingly. Companies/businesses generally are assigned a taxpayer reference number that they are required to include in their tax returns and invoices. Small businesses receive a commercial taxpayer reference number that differs from the owner's private taxpayer reference number, once the tax authority has received notification of their business.

You need to enter a VAT number or taxpayer reference number to register with the LUCID Packaging Register. If you do not have a VAT number, please indicate this during the registration process. You will then be prompted to enter your taxpayer reference number.

In this case, please enter the German VAT number.

You need to enter a VAT number or taxpayer reference number to register with the LUCID Packaging Register. 
Please check yourself what national identification number corresponds to the German VAT number or taxpayer reference number. The following information will help you:

• The primary purpose of the VAT number is to regulate cross-border transactions within the EU for value-added tax reasons. In many countries (e.g. in Germany) this number is different from a regular identification or taxpayer reference number. If you do not have a VAT number, please indicate this when registering with the LUCID Packaging Register. You will then be automatically prompted to enter a taxpayer reference number.

• The taxpayer reference number is the number that the tax authority assigns to every taxable natural or legal person. It is uniquely assigned to one single taxable person. Companies generally are assigned a taxpayer reference number that they are required to include in their tax returns and invoices.

Are you sure that neither a VAT number nor a taxpayer reference number is assigned to your company? If that is the case, please enter your personal taxpayer reference number.

For associated companies or a group, it is necessary to check who can undertake registration and/or data reporting as the authorised person. Individuals possessing authorisation or power of attorney within a circle of associated companies will qualify as persons within a company, not as third parties. These individuals can also be named as the authorised person for multiple producers within the same circle of associated companies. However, they must set up and provide a dedicated e-mail address for each individual producer. Entering the same e-mail address for multiple producers during the electronic registration process will not be accepted.

Example:

An employee of the parent company is to be the authorised person for three group entities. Three different e-mail addresses need to be set up and entered into the Packaging Register so that they are specific to each producer, such as:

firstname.lastname1@company.com, firstname.lastname2@company.com and firstname.lastname3@company.com, or
packaging1@company.com, packaging2@company.com and packaging3@company.com

Whether you need to register depends on whether your branch is legally independent (which is usually the case if it is registered in the commercial register). If your branch is legally independent, it must have its own registration with the LUCID Packaging Register. In addition, you have to check whether there are any other obligations.

Companies under obligation are called producers in the Verpackungsgesetz (Packaging Act). The law essentially defines producer as any party who is the first to fill packaging with goods and place it on the German market on a commercial basis.

• This is usually the party producing and packaging the product.

• It may also be retail companies that distribute own brands if the packaging is filled by a third party on the retail company's behalf before being handed over to the retail company and if the packaging bears only the name and/or brand of the retail company.

• Importers are also producers if they bear legal responsibility for the goods at the time they cross the border. 

• Mail order companies and online retailers that fill shipment packaging with goods for the first time also count as producers.

Every company that is a producer under the Verpackungsgesetz must register with the LUCID Packaging Register. If the company distributes its goods in packaging subject to system participation on the German market (retail, grouped and/our shipment packaging), the company must also pay for that packaging's recycling. To do so, the company has to conclude a system participation agreement with a system operator and regularly report its packaging volumes to both its system operator and the LUCID Packaging Register (data reporting).  

It is a registration number in the LUCID Packaging Register. This number is noted on the administrative act that was sent to you electronically by the ZSVR after registration. You can also find the number in your personal dashboard in the LUCID Packaging Register.

The producer/initial distributor must apply to register personally. The information and declarations this requires may not be provided by third parties. Granting power of attorney (or similar authority) to a third party for this purpose is prohibited pursuant to section 35 (1) VerpackG (Packaging Act). Third parties include people such as external agents and brokers, who may not be instructed to act on behalf of a producer. This is intended to prevent third parties from giving incorrect information in the producer's name.

If the producer is a natural person (for example a sole trader), they can provide information and make declarations themselves.

In the case of a legal person, an authorised person within the company must act on behalf of that legal person. If there is no individual with with sole power of representation, an individual within the company must be granted power of attorney and be named as the authorised person. Depending on the form of business organisation, this could be, for example, a member of a multi-member management board, a managing director, an authorised signatory, authorised agent or individual with sole power of representation. An authorised person within the company could also include an appropriately authorised team leader or a department head. The registration does not need to reflect internal company regulations (dual control principle, approval limits, departmental responsibilities, etc.).

The authorised person must bear responsibility for ensuring due and proper registration, particularly with regard to providing accurate declarations.

With the exception of the registration requirement, international producers under obligation without a branch within Germany can appoint an authorised representative to fulfil their duties under the VerpackG on their behalf.

Every producer must submit their application for registration personally. Section 35 (1) VerpackG states that the obligation to provide the required information and declarations may not be transferred to a third party. Third parties include people such as authorised representatives, external agents and brokers. This is a situation where they may not be instructed to act on behalf of a producer. This is to prevent third parties from giving incorrect information in the producer's name. Where a legal person is concerned, an authorised person within the company must act on its behalf. If there is no individual with sole power of representation, an individual within the company must be named as the authorised person. Depending on the form of business organisation, this could be a member of a multi-member management board, a managing director or another authorised officer or signatory. An authorised person within the company could also include an appropriately authorised team leader or a department head.

The authorised person must bear responsibility for ensuring due and proper registration, particularly with regard to providing accurate declarations.

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

When producers quit placing packaging filled with goods on the German market (market exit), they must end their registration. This can be accomplished by logging into the LUCID Packaging Register and clicking on 'Edit master data' and then on 'Terminate registration'. The registration will end on the date selected (the earliest date is the date of termination). The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) will confirm the end of the registration to the user electronically via an administrative act. Producers/initial distributors may only place packaging filled with goods on the market if they are properly registered. Any party terminating their registration should therefore be certain that they are no longer placing any packaging filled with goods on the German market.