Declaration of completeness in LUCID

This page provides answers to the most frequently asked questions about submitting and correcting a declaration of completeness.

Key questions

No. The deadline for submitting a declaration of completeness (DoC) for the prior year is 15 May. The DoC must have been filed with the LUCID Packaging Register by this date. As this is a statutory deadline, the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) cannot arrange or grant an extension. Even after the deadline has passed, you are still required to file a declaration of completeness with the LUCID Packaging Register. Failing to submit a declaration of completeness on time or at all constitutes an administrative offence and may be punished with a fine. 

Further information can be found in our knowledge base dedicated to declarations of completeness.

Unlike a data report, the obligation to submit a DoC applies only to companies that generate large packaging volumes. These companies must submit an audited DoC if their packaging volumes reached or exceeded at least one of the following thresholds in the previous calendar year:

  • Glass: 80 tonnes

  • Paper/cardboard in total: 50 tonnes  

  • Ferrous metals + aluminium + plastics + beverage cartons + other composites (lightweight packaging) in total: 30 tonnes

The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and the competent state authorities also have the power to require at any time that a declaration of completeness be submitted, even if these thresholds are not reached.
Further information can be found in our knowledge base dedicated to declarations of completeness.

Your auditor will only be able to view or retrieve the DoC in/from the LUCID Packaging Register once you have generated the producer declaration.
To do this, follow these steps: 

  1. Use your login credentials to sign in to the LUCID Packaging Register.

  2. Next, open the 'Declaration of completeness' tile by clicking on 'Edit'.

  3. Open 'Declaration of completeness pursuant to VerpackDG/VerpackG' and click the 'Edit' tile next to the declaration of completeness you would like to submit. 

  4. Please check that you have filed all your packaging volumes. 

  5. Open the 'Declaration of completeness submission' tile.

  6. Click on 'Generate producer declaration' at the very bottom of the page.

Generating the producer declaration can take several minutes. You and your auditor will then be able to retrieve and download the producer declaration.

Do you have any further questions? If you still have a technical issue, you can contact our support team. Please note that they only provide support for technical queries.

Declaration of completeness submission

Declarations of completeness (DoC) are submitted wholly electronically to the LUCID Packaging Register. The process involves creating and uploading three documents:

  • The company under obligation's producer declaration

  • The appointed auditor's or expert's audit confirmation 

  • The appointed auditor's or expert's audit report 

You can find detailed information about how to prepare a producer declaration on our knowledge base dedicated to declarations of completeness.

No. It is a legal requirement that the declaration of completeness (DoC) must be filed electronically with the LUCID Packaging Register. Submissions by post or e-mail are not accepted. Further information about the submission can be found in the knowledge base dedicated to declarations of completeness

You prepare the producer declaration electronically via the LUCID Packaging Register when you submit a declaration of completeness. Information filed in the producer declaration includes details regarding your appointed auditor and your packaging volumes. You can find detailed information in the step-by-step guide to the declaration of completeness.

Do you have any further questions? If you still have a technical issue, you can contact our support team. Please note that they only provide support for technical queries.

The button will only be displayed once you have filed and saved your packaging volumes in the declaration of completeness.
Proceed as follows:

  1. Use your login credentials to sign in to the LUCID Packaging Register.

  2. Next, open the 'Declaration of completeness' tile by clicking on 'Edit'.

  3. Open 'Declaration of completeness pursuant to VerpackDG/VerpackG' and click the 'Edit' tile next to the declaration of completeness you would like to submit. 

  4. Enter your packaging volumes and save this information. 

  5. Open the 'Declaration of completeness submission' tile.

  6. Click on 'Generate producer declaration' at the very bottom of the page.

Generating the producer declaration can take several minutes. You and your auditor will then be able to retrieve and download the producer declaration.

Do you have any further questions? If you still have a technical issue, you can contact our support team. Please note that they only provide support for technical queries.

If you are unable to upload your documents, this may be due to the following reasons, for example:

  • The producer declaration seal has been changed. The seal of the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) is added automatically when the producer declaration is generated. The document can only be uploaded if the seal remains intact. 

  • The documents (producer declaration and audit confirmation) have not been signed with a qualified electronic signature. Your auditor must sign both documents with a qualified electronic signature (QES).

You and your auditor can find further information about the technical requirements in the knowledge base dedicated to electronic signatures.

Do you have any further questions? If you still have a technical issue, you can contact our support team. Please note that they only provide support for technical queries.

All auditors registered with the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) are authorised to audit declarations of completeness (DoC). You can find an overview of registered auditors and their contact details in the public register of auditors. 

Important information: 

  • You must enter into a contractual agreement with an auditor before you indicate them as the responsible auditor in your DoC.

  • For companies located abroad: your auditor does not need to be located in the same country as you.

  • You are free to choose your auditor from the ZSVR's public register of auditors.  

Correcting a declaration of completeness

A declaration of completeness that has already been started cannot be completely deleted. However, you can check its status in the LUCID Packaging Register and update it if necessary: 

  • If the status is 'Producer declaration generated', click on 'Correct' so that the status changes to 'Being corrected'. 

  • If the declaration of completeness has the status 'Being corrected' or 'Started', you do not need to take any further action. The declaration of completeness is not taken into account in these two statuses. 

Do you have any further questions? If you still have a technical issue, you can contact our support team. Please note that they only provide support for technical queries.

You can edit the details in your declaration of completeness (DoC) at any time. To do this, click on 'Edit' or 'Correct' next to the relevant DoC.

Please note: as soon as you change any details, a producer declaration that has already been generated will no longer be valid. You should therefore generate the producer declaration again via the 'Declaration of completeness submission' tile. Only then will your auditor be able to retrieve the document with the corrected details.

Do you have any further questions? If you still have a technical issue, you can contact our support team. Please note that they only provide support for technical queries.

The 'DoC reason' cannot be amended in a declaration of completeness (DoC) that has already been created. Nor is it possible to delete the declaration of completeness. You must therefore create a new declaration of completeness with the correct 'DoC reason'. You can also review and update the status of the DoC that has already been created. 
Proceed as follows, depending on the status:

  • If the status is 'Producer declaration generated', click on 'Correct' so that the status changes to 'Being corrected'. 

  • If the declaration of completeness has the status 'Being corrected' or 'Started', you do not need to take any further action. The declaration of completeness is not taken into account in these two statuses. 

Do you have any further questions? If you still have a technical issue, you can contact our support team. Please note that they only provide support for technical queries.