Packaging categorisation and system participation
What types of packaging are there? What are the statutory obligations that come with each of them?
Entering brand names in the LUCID Packaging Register
When registering with the LUCID Packaging Register, you are required to enter the brand names you are using to distribute your packaged goods, broken down by packaging that is subject to system participation and packaging that is not subject to system participation. You can also edit or delete your brand names, or add new ones at any time.
What you need to know about brand names
As a matter of principle, only enter brand names in the LUCID Packaging Register if you are responsible for them and if they are in use. Only enter umbrella brands that you are currently using to commercially distribute your packaged goods.
It does not have to be a registered trademark under trademark law. Please do not enter any sub-brands into the LUCID Packaging Register. In addition, do not enter:
- Brand names of trading goods that you simply resell and have no legal responsibility for
- Type designations, article specifications, model descriptions (e.g. headphones A10, headphones A15)
- Quantities (e.g. 50 or 100 grammes)
- Product descriptions (e.g. headphones, lubricant)
- Name of system operator
- 'No brand' or 'no name'
Heads-up: If you are using the same brand name of packaging that is subject to system participation and on packaging that is not subject to system participation, you are required to enter that brand name for both product categories in the LUCID Packaging Register.
For retail, grouped or shipment packaging with no brand name, please enter your company name as a brand name. You do not have to add the name of the manufacturer who produced the empty packaging.
For service packaging, the name you enter as a brand name depends on the circumstances: If you have fulfilled the system participation requirement yourself, please enter your company name. But if you have acquired unfilled pre-participated service packaging, you have to enter the name of your packaging supplier.
You have to add third-party brands if you yourself are the first to commercially place the packaged goods on the German market. In this case, you are considered to be the producer under the Verpackungsgesetz (Packaging Act) and need to fulfil your obligations under German packaging law. This may be the case if you are importing packaged goods from abroad into Germany and are legally responsible for those goods at the time they cross the border.
Do not enter any brands into the LUCID Packaging Register that you are not responsible for. If you are a downstream seller of goods that you have acquired from a supplier in Germany or imported into Germany, you are not responsible for them. It is not you, but the supplier or wholesaler who must enter the brand name to the LUCID Packaging Register.
Use your login credentials to sign in to the LUCID Packaging Register. Click on 'Edit' in the 'Brand names' tile.
- Change brand names
The name of a brand cannot be changed once it has been entered. If you would like to correct a brand name, you have to delete it and then add the correct brand name. Click on the waste bin symbol in the 'Actions' column to the right of the brand that you would like to delete. Confirm the deletion. Click the 'Add brand names' button and enter the new brand name. Then click 'Save' or 'Save and add new'.
- Delete brand names
Click on the waste bin symbol in the 'Actions' column to the right of the brand that you would like to delete. Confirm the deletion.
- Add brand names
Click the 'Add brand names' button and enter the new brand name. Then click 'Save' or 'Save and add new'. If you have filed both packaging that is subject to system participation and packaging that is not, please note that you have to enter at least one brand name in each category.
- Re-categorising packaging as subject to system participation or not subject to system participation
Go to the table of brand names and look for the brand name you would like to re-categorise. Click the 'Edit' symbol in the 'Actions' column to the right and assign the brand name to the right category.
Have you made all your changes? Then scroll down and click 'Next'. Review the summary of the information you have entered. Scroll down to the 'Declarations' section and check the boxes. Click 'Submit registration changes' to save your changes.
The ZSVR will send out an electronic notice (administrative act) for this brand name change. The corrected brand names will be visible in the LUCID Packaging Register starting from the following day.
