Further information on producer registration and visibility in the public part of the LUCID Packaging Register can be found here. More details regarding registered experts pursuant to sections 3 (15), 27 (1) VerpackG (Packaging Act) and other registered auditors pursuant to section 27 (2) VerpackG and the publicly accessible information can be found here.
Furthermore and in accordance with its statutory mandate, the ZSVR also publishes a list of producers / initial distributors that have submitted a declaration of completeness (DoC list). More information on the declarations of completeness can be found here.
Register of producers
Before packaging subject to system participation is placed on the German market for the first time, producers / initial distributors are required to register with the ZSVR. This requirement has existed since 1 January 2019, when the Verpackungsgesetz (Packaging Act) came into force. More information on placement of packaging subject to system participation on the German market and on the definition of a producer / initial distributor can be found here.
The Verpackungsgesetz distinguishes between first-time registration and reports of any changes. The ZSVR publishes the registered producers with the following details set out in section 9 VerpackG:
- Registration number (this remains the same, even where changes are reported)
- Registration date (reports of any changes will contain the date on which changes were reported)
- Name, address and contact details (in particular postcode and town/city, street address, country, telephone number and fax number, and e-mail address)
- Brand names under which the producer places its packaging subject to system participation on the German market
For producers whose registration is to be terminated, the date of market exit must also be specified. The information published is deleted three years following the end of the year in which the producer’s registration terminates.
The publication of registered producers is designed to enable consumers and distributors, as well as competing businesses, to search for specific producers and brands so that they can check whether the producer / initial distributor has fulfilled their system participation responsibilities. Complete system participation requires a registration number.
The ZSVR also offers automatic data reconciliation upon request. Using the VAT ID provided during registration, information about registration status (yes/no) can be queried; the VAT ID itself will not be made available to third parties if consent to automatic data reconciliation is given. Only those producers will be included that have chosen to consent to automatic data reconciliation.
If a producer has not registered or not registered properly, they may not place their packaging subject to system participation on the German market and distributors are not permitted to offer these for sale (distribution ban). Further details can be found in the How-To Guide.
Click here to see the register of producers.
Register of auditors
In the course of exercising its statutory authority, the ZSVR includes experts and other auditors who have indicated their intention to conduct the audits provided for by the Verpackungsgesetz in a register of auditors.
The register of auditors is made up of two divisions:
Division 1 lists the following registered experts:
- Publicly appointed experts
- Environmental verifiers or organisations
- Experts accredited by national accreditation bodies
- Foreign experts (experts in another EU Member State or another country in the European Economic Area)
These registered experts are authorised to audit the volume flow records of the systems, the sector-specific solutions and the declarations of completeness.
Click here to see division 1 of the register of auditors.
Division 2 lists the following other types of auditors:
- Tax advisers
- Sworn accountants
These other registered auditors are authorised to audit the declarations of completeness.
Click here to see division 2 of the register of auditors.
The publication of the register of auditors fosters transparency and makes it easier for systems, sector-specific solutions, producers and distributors to find these registered experts and other auditors.
The ZSVR may reject listing in the register of auditors if the respective registered expert and/or other auditor cannot produce suitable evidence of their professional certification upon request. This certification may be evidenced, for example, by a relevant certificate or an appointment.
The ZSVR offers a training course at least once a year for its software system including the data formats and use of the audit guidelines. Registered experts pursuant to sections 3 (15), 27 (1) VerpackG are required to complete one of these training courses within one year of admission into division 1 of the register of auditors and once every five years thereafter. If this requirement is not met, the ZSVR is entitled to remove the registered expert pursuant to sections 3 (15), 27 (1) VerpackG until they have attended the training course.
Furthermore, the ZSVR is entitled to remove a registered expert pursuant to sections 3 (15), 27 (1) VerpackG and other registered auditor pursuant to section 27 (2) VerpackG for up to three years from the register in the event of repeated and gross breach of duty violations of the audit guidelines.
Declaration of completeness list (DoC list)
In the course of exercising its statutory authority, the ZSVR keeps a public list of producers that have filed a declaration of completeness (DoC list).
Unlike the register of producers and the register of auditors (see above), the DoC list is not new. The declaration of completeness was already included under the Verpackungsverordnung (Packaging Ordinance), and will continue to be used. While the Verpackungsverordnung states that the chambers of industry and commerce were responsible for maintaining and publishing the DoC list until 31 December 2018, it has been the ZSVR since 1 January 2019.