Any party who places packaging subject to system participation on the German market (producer / initial distributor) must register with the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) in the LUCID Packaging Register. Producer status is triggered by the first placement of packaging on the German market on a commercial basis, or introduction of packaged goods into Germany, and does not depend on distribution method or retail level (section 3 VerpackG (Packaging Act)).
So-called service packaging is subject to special arrangements. 'Service packaging' refers to packaging that is filled with goods at the point of sale (e.g. bakery bags, carrier bags, takeaway coffee cups, takeaway containers, etc.). In this situation, the final distributor can demand that responsibility for system participation be assumed by the distributor immediately upstream from them. This means that all of the other obligations (e.g. registration and any declaration of completeness, as applicable) would also be shifted to the upstream distributor.
If registration is not completed, a distribution ban is automatically applied to the packaging and fines may be charged. Because of the public nature of the register, any party that does not comply with the law must expect to face the delisting of their products from trading. Publication enables everyone to search through the register for specific producers and brands to check whether a producer has met the registration requirement. The LUCID Packaging Register makes violations apparent and provides for related transparency.
The registration requirement for producers derived from section 9 VerpackG has existed since 1 January 2019, when the Verpackungsgesetz (Packaging Act) came into force. Producers / initial distributors of packaging file their master data with the LUCID Packaging Register and receive a registration number, which they then provide to their system counterparty to enter into a system participation agreement. Please note: during the registration process, you will be asked to confirm that you will enter into such an agreement for the recovery and recycling of your packaging with a system operator. Producers then automatically receive an registration administrative act issued by the ZSVR. They will also be included in the public register of producers, along with their brand names. The content of this register is governed by section 9 VerpackG. The register of producers can be found here.
This procedure ensures that properly registered producers / initial distributors will not be subject to a distribution ban. By registering in the LUCID Packaging Register, producers / initial distributors make it clear to the public that they have fulfilled their producer responsibility for the packaging they market.
The steps of the registration process are largely set out in the Verpackungsgesetz. A producer submits an application to register to the ZSVR, which completes the registration and then includes that producer and their brand names in the public LUCID Packaging Register. The LUCID Packaging Register operates exclusively electronically. The Verpackungsgesetz expressly provides for this.
As part of first-time registration, the producer / initial distributor of packaging first sets up their login by entering their company name together with the authorised and specific contact person in the company, including their e-mail address. Since 3 July 2021, the e-mail address entered during the registration process is no longer displayed in the public register. The party under obligation will receive an activation link from the ZSVR, sent by e-mail, and has to use this link to activate the login within 24 hours. Then, once additional producer information has been provided within seven days, the registration is completed. Before the producer submits the final application for registration, they will be shown an overview of all the information entered. Once the producer has made the application for registration, the ZSVR will send them an e-mail with their registration number, and an administrative act for registration will automatically be generated and transmitted electronically.
The Verpackungsgesetz requires the producer / initial distributor of packaging to provide notification of any changes to their registration information without delay and update the LUCID Packaging Register accordingly. To update their master data or brand information, the producer / initial distributor uses their login. The producer entries in the public section of the LUCID Packaging Register are updated on a daily basis to reflect changes. As the e-mail address entered when registering will be used for all further communications with the ZSVR, it has to be ensured that it can be accessed at any time. To change this e-mail address, the login has to be transferred to a new e-mail address; this can be done in the master data section of the LUCID Packaging Register.
Click here for the LUCID Packaging Register.
On the following pages, you can find important tips and guides to make it easier for you to complete and submit your application for registration.