System participation and data reporting

Are you placing packaging that is subject to system participation on the German market? If the answer is 'yes', you not only need to register with the LUCID Packaging Register. You also have to fulfil the system participation requirement and regularly report your packaging volumes.

Registering with the LUCID Packaging Register is the first step. You are also responsible for financing the recycling of your sales, grouped or shipment packaging and must therefore also assume extended producer responsibility by participating that packaging in a system. You first have to conclude a system participation agreement. After that, you are required to report the exact same packaging volumes you provided to your system operator to the LUCID Packaging Register and you must do so without delay. This is called 'data reporting'.

 

In addition to clarifying who is responsible for financing packaging recycling, it must also be determined who is considered the manufacturer under the PPWR and therefore responsible for the technical documentation and declaration of conformity. Both obligations may – but do not necessarily have to – lie with the same company.

Heads-up

If you are using packaging that is subject to system participation to distribute your products, the system participation and data reporting requirements go hand in hand.