- producers / initial distributors of packaging filled with goods required to report data as per section 10 VerpackG (Packaging Act), and
- systems that are required to submit data reports as per section 20 VerpackG.
Producer data reporting
Producers / initial distributors of packaging subject to system participation are required by law to also report to the ZSVR the exact same information that they provide to a system in connection with system participation, and to do so without undue delay. These are duplicate reports in the purest sense. If a producer has contractually agreed one report per year with a system, the producer must submit this report to the LUCID Packaging Register at the same rate without delay.
The following information needs to be submitted as part of this process:
- Registration number
- Material type and mass of the participating packaging
- Name of the system in which the packaging participates
- Period of system participation
The same applies to
- packaging that the producer is planning to place on the German market in a certain time period (e.g. calendar year) ('planned volume'), and
- packaging that the producer actually placed on the German market in a previous period (e.g. calendar year) ('actual volume').
If the contract with the system includes more frequent reporting (e.g. quarterly or monthly), then the producer must in turn submit more frequent volume reports to the ZSVR. In order to make the process as simple and unbureaucratic as possible, the volume reports can also be transmitted using an XML file. For IT-related questions about the data reporting process, you can find more information here.
- The conclusion or extension of an agreement with a system (system participation agreement for specific volumes) must also be reported pursuant to section 10 VerpackG. In other words, a second data report regarding the volumes agreed upon in the contract must be made to the LUCID Packaging Register. This also applies if you do not have to report to the system until a later point in time, e.g. for another year.
- To ensure due reconciliation of the packaging volumes reported to the systems and to the LUCID Packaging Register, it is key that the system and producer use the same registration number for all their data reports. Systems must have the producers' 'active' registration number on hand. Where necessary, this needs to be verified. Otherwise data reports cannot be conclusively matched to the right producer.
Declaration of completeness
Producers who are under an obligation to file a declaration of completeness with the ZSVR must do so no later than 15 May. The declaration of completeness must be audited and confirmed by a registered expert or a registered auditor / tax adviser / sworn accountant pursuant to section 27 (2) VerpackG.
Pursuant to section 11 (3) VerpackG, the ZSVR has published standard operating procedures concerning the electronic filing procedure, in the form of the 'declaration of completeness technical guidelines'. These guidelines require the use of certain electronic forms and input screens as well as access to the ZSVR's database (LUCID). The requirements set out in these guidelines must be complied with when making filings.
System data reporting
Section 20 VerpackG requires systems to electronically report the packaging participated with them on a quarterly basis (as a 'planned volume' in advance) and in the following year (as an 'actual volume') to the ZSVR. When reporting the volumes, the systems must indicate type and mass of the participated packaging per producer providing the corresponding registration number. The data must be confirmed by a system auditor.
It is on this basis that the ZSVR calculates the systems' market share, which is then used to allocate both the costs of collection and the packaging volumes to the individual system operators, applying a concept for market share calculation that was developed in agreement with the German Federal Cartel Office. This concept also takes into account the system auditors' guidelines according to which the numbers reported to the ZSVR by the system operators are certified. This is a major step forward compared to the method employed under the Verpackungsverordnung (Packaging Ordinance): the standards for data reporting and audit will now be established on a statutory basis.
Click here to go to the portal for submitting a system data report.