Reporting packaging volumes
When and how do you submit a data report to a system? When...
- ...you conclude a system participation agreement.
- ...you extend an existing agreement with a system.
- ...the system operator asks you to report your packaging volumes.
What information do you have to file in the LUCID Packaging Register?
- Reporting period. This must be the same period as for the report to your system operator.
- Name of the system with which you concluded a system participation agreement.
- Material types (e. g. paper/paperboard/cardboard, plastics, ferrous metals or glass) and packaging volumes per material type. Enter the packaging volumes in kilogrammes to the third decimal point.
The systems are required by law to file the participated packaging volumes as a control report to the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR). The ZSVR compares the data with the volume reports of the companies submitted in the LUCID Packaging Register and thus quickly uncovers deviations. Based on their reports, the ZSVR also calculates the systems' market share. Click here for more information.
The system with which you concluded a system participation agreement is filed when the data report is submitted in the LUCID Packaging Register.
The following additional information is required:
- Reporting period. This must be the same period as for the report to your system.
- Packaging volumes and materials.
You do not have to explicitly inform the LUCID Packaging Register about the change. With every data report in the LUCID Packaging Register, you enter the system with which you concluded an agreement. Going forward, when filing a data report simply enter the appropriate (‘new’) system.
In this case, you first have to report the change in packaging volumes to your system operator. Then submit a data report to the LUCID Packaging Register. This report to LUCID must contain the adjusted and confirmed volumes reported to your system. Which type of data report you have to choose in the LUCID Packaging Register depends on when you adjust your packaging volumes:
- Have you adjusted your planned volumes during the current forecast period? Then file an intra-year volume report in the LUCID Packaging Register with the new total volume. If you have already submitted an intra-year volume report for this forecast period, please adjust the volumes stated in this report.
- Have you corrected your planned volumes after the forecast period has expired? Have you reported the volumes you actually placed on the German market to your system? If the calendar year for which you have submitted your forecast report has ended, you have to submit a year-end volume report to the LUCID Packaging Register concerning those volumes.
The company under obligation under the Verpackungsgesetz (Packaging Act) must itself submit the data report to the LUCID Packaging Register.
There is an exception for international companies without a branch in Germany (for example companies located in China, the UK, the USA, Poland or Italy): if such a company has appointed an authorised representative to fulfil its obligations under packaging law, the authorised representative must submit the data report for the party under obligation. In this case, all the international company has to do is register with the LUCID Packaging Register and enter its authorised representative.
More information about authorised representatives can be found here.
Your system reports the packaging volume data you have filed there to the ZSVR. But you are still legally required to report your data in the LUCID Packaging Register: you have to file every report on packaging volumes that you file with your system operator with the LUCID Packaging Register without delay. This also applies when entering or renewing a system participation agreement. The system's report is used for checks, amongst other purposes.
The obligation to report data about packaging volumes applies to companies that place packaging subject to system participation on the German market. Packaging subject to system participation includes retail, grouped and shipment packaging.
That means that if you exclusively place packaging on the German market that is not subject to system participation (e.g. transport packaging, reusable packaging and single-use beverage packaging subject to deposit), you do not have to submit data reports about your packaging volumes. An exception applies to declarations of completeness: declaring volumes of industrial retail and grouped packaging is mandatory.
Packaging that is not subject to system participation does not have to participate with a system. But recovery, return and documentation obligations do apply; these obligations are set out in section 15 VerpackG (Packaging Act).
Good to know: if your information in the LUCID Packaging Register states that you exclusively place packaging not subject to system participation on the German market, LUCID will not let you file a data report.
What packaging types – that are or are not subject to system participation – are there? What are the obligations that come with each of them? Learn more in this graphic.
There are technical restrictions for both:
- Initial planned volume reports for the following year can only be filed up to 31 December of the current year.
- Year-end volume report for the previous year can only be filed up to 15 May.
See question no. 8 to learn more about how to correct these reports if needed.
That depends on the type of report in the LUCID Packaging Register. Let us have a look at two of these types, and how to edit them.
- Initial planned volume reports: You would like to correct your report for the current year? Then all you have to do is file an intra-year volume report containing the amended packaging volumes. The reporting period you have to enter is January to December. The initial planned volume report you had filed already will still be included in the overview of data reports. The newly filed intra-year volume report replaces the corrected initial planned volume report and is now considered to be your current forecast report.
- Year-end volume reports: If you can no longer edit a year-end volume report, you have to submit a supplementary volume report to correct it. In this supplementary volume report, you simply enter the difference between the year-end volume report that needs to be corrected and the actual volumes. If volumes need to be reduced, add a negative sign in front of the difference.
Example: Your year-end volume report in the LUCID Packaging Register states that you placed 100 kg of paper, paperboard and cardboard (PPC) on the German market during the past year. This is wrong. You actually placed 120 kg of PPC on the German market and participated that volume with a system. If you can no longer edit your year-end volume report, you must file a supplementary volume report with the following value for the year in the question: 20 kg of PPC.
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