- 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 file 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 duplicates of the information that they provide to a system in connection with system participation to the ZSVR, and without undue delay. These are duplicate reports in the purest sense. If a producer has agreed one report per year with a system following conclusion of the contract (system participation agreement), the producer must also submit this report to the LUCID Packaging Register 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 onto the German market in a certain time period (e.g. calendar year) ('planned volume'), and
- packaging that the producer actually placed onto the German market in a previous period (e.g. calendar year) ('actual volume').
Declaration of completeness
Producers under 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 on 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 in the declaration of completeness technical guidelines must be complied with when making filings.
Click here for the declaration of completeness technical guidelines.
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 Competition Office. This concept also takes into account the system auditors' guidelines according to which the system operators' numbers 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 data reporting for systems.