System participation & catalogue

This page provides answers to the most frequently asked questions about system participation and the system participation requirement catalogue.

System participation

Use the system participation requirement catalogue to figure out quickly and easily if your packaging needs to participate with a system.

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To pay for the recycling of your packaging that is subject to system participation, you are required to conclude a system participation agreement with a system operator. The costs for participating your packaging with a system depend on different factors such as the volume and material type of your packaging. You can conclude your system participation agreement with the system operator of your choice.

You enter into a contractual agreement with a system operator to carry out system participation. The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) does not arrange system participation agreements. Nor can you enter into a contractual agreement of this sort via your registration with the LUCID Packaging Register. You will find a list of system operators and their contact information under Overview of system operators.

You can conclude your system participation agreement with the system operator of your choice. Antitrust law prohibits the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) from recommending a particular system operator and from informing about the services offered or fees charged by system operators. You will find a list of system operators and their contact information under Overview of system operators.

You will receive confirmation directly from the system operator with whom you have concluded the system participation agreement or your packaging licence. The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) does not issue such a confirmation. The confirmation is not available via the LUCID Packaging Register either. As a rule, the system operator will provide you with the relevant documentation/evidence once the agreement has been concluded. You will find a list of all approved system operators and their contact information under Overview of system operators.

The costs mainly depend on the volumes and material types used in your packaging subject to system participation. Antitrust law prohibits the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) from recommending a particular system operator and from informing about fees charged or conditions imposed by system operators. You will find a list of system operators and their websites under Overview of system operators.

First, contact the system operator with whom you have concluded your system participation agreement (packaging licence) and clarify whether you can adjust the contractually agreed volumes. Amendments can be made only by the system operator – not via the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) or in the LUCID Packaging Register.

The data you enter in LUCID must correspond exactly to the volumes that you have participated with your system operator for the relevant period.
Once your system operator has adjusted the volumes, you must also make the corresponding amendment in your data report in the LUCID Packaging Register. You will find instructions on how to correct this under How can I correct a data report that I have submitted to the LUCID Packaging Register?.

Registering with, and submitting data reports to, the LUCID Packaging Register is free of charge. Therefore, the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) does not issue any invoices. System participation (packaging licence), for which fees are payable, involves entering into a private civil law contract with a system operator outside of the LUCID Packaging Register. 

Please contact your system operator or the sender of the letter if you have any questions about invoices or other letters.

System participation requirement catalogue

You can use the catalogue to find out if a unit of packaging is subject to system participation. The catalogue consists of two parts, a General section and a Special section. 

The General section is available as a PDF document. It contains important definitions and explanations for the different packaging types. It also explains the system participation requirement for service packaging and transport packaging. Transport packaging includes packaging intended for the shipment of products.

The Special section provides information about decisions regarding the system participation requirement for sales packaging and the majority of grouped packaging. As these packaging types are classified taking the packaged product into account, the Special section is organised by product groups and products. You can access the product group sheets via the catalogue database or download them as PDF files. You can also search the catalogue database for individual products.

Please note: because service packaging and packaging intended for the shipment of products are always subject to system participation, you do not need to search the catalogue for these packaging types.

Heads-up: when using the catalogue, first consult the General section to identify the packaging type that is relevant for your check. Next, refer to the Special section, i.e. the product group sheets.

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The catalogue applies to all packaging subject to system participation. It consists of two parts, a General section and a Special section. 

The General section is available as a PDF document. It contains important definitions and explanations for the different packaging types. It also explains the system participation requirement for service packaging and transport packaging. Transport packaging includes packaging intended for the shipment of products.

The Special section provides information about decisions regarding the system participation requirement for sales packaging and the majority of grouped packaging. As these packaging types are classified taking the packaged product into account, the Special section is organised by product groups and products. You can access the product group sheets via the catalogue database or download them as PDF files. You can also search the catalogue database for individual products.

Please note: because service packaging and packaging intended for the shipment of products are always subject to system participation, you do not need to search the catalogue for these packaging types.

Heads-up: when using the catalogue, first consult the General section to identify the packaging type that is relevant for your check. Next, refer to the Special section, i.e. the product group sheets.

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Comparable sources of waste generation are businesses or institutions where packaging waste accumulates that is similar in type and volume to the packaging waste that accumulates with private households. This includes restaurants, hotels, hospitals, canteens, amusement parks, libraries and schools. Other examples are craft enterprises (e.g. laundries) and agricultural holdings (e.g. plant nurseries), where packaging waste can be disposed of at the rate that is normally associated with private households, i.e. at 14-day intervals, in waste bins that do not exceed 1,100 litres per collection group. 

List of comparable sources of waste generation

  1. Start by using the General section to identify the packaging type
    The catalogue's General section provides information about the different packaging types. It also explains the system participation requirement for service packaging and transport packaging. Transport packaging includes packaging intended for the shipment of products. If you have determined that the packaging unit in question is sales packaging or grouped packaging, please refer to the Special section of the catalogue (step 2).

  2. Once you have identified the packaging type, search the Special section of the catalogue for your packaged product
    Enter the product into the catalogue database's search field. If you cannot find the product in the product group sheets that are then displayed, search for comparable products, i.e. products similar to yours.

  3. Open the relevant product group sheet
    Select the relevant product – or one that is as similar as possible – from the list provided, and click on 'Open'. Depending on the product, factors such as size, quantity or other characteristics of the packaging unit in question may be relevant for its classification.

  4. Check the search result for your packaging unit
    The product sheet shows which packaging is subject to system participation. Check the relevant delineation criterion, such as quantity, volume or unit. The brief overview in the product group sheet presents the key information at a glance. In the detailed overview, you can also filter by packaging material, shape/form and quantity (or volume or unit).
    If you come to the conclusion that the packaging in question is subject to system participation, you must enter into a system participation agreement with a system operator and report your packaging volumes there as well as in the LUCID Packaging Register (data reporting).
     

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If you cannot find your product in the catalogue, this does not mean that the packaging of that product is automatically exempt from the system participation requirement or other packaging law obligations. The catalogue is not exhaustive.
Search the catalogue for comparable products – especially comparable as to how and in which packaging they are distributed and whether they accumulate as waste with private households or comparable sources of waste generation. The result, i.e. how these comparable products are classified, may serve as guidance. 

Further sources of advice 

For case-based specialist advice, you can also reach out to qualified experts, environmental consultants, system operators or auditors. You will find the ZSVR's register of auditors on the public registers page.

Yes, B2B packaging may also be subject to system participation. The mere fact that you supply exclusively to business customers does not rule out that the system participation requirement applies. The decisive factor is where your products' packaging for the most part typically accumulates as waste. This classification, as it is used in the catalogue, is based on an overall market assessment for the specific products.

It does not hinge on any specific case, the sector or your company's particular distribution channel. If the packaging in question for the most part typically accumulates as waste with private households or comparable sources of waste generation, you must participate the packaging with a system.

What are comparable sources of waste generation? 
Background information about the catalogue