The LUCID Packaging Register of the Central Agency (ZSVR)
As a public, state-run online packaging register, LUCID was launched by the Central Agency Packaging Register (ZSVR) as part of the German Packaging Act (VerpackG).
In force since 1 January 2019, the VerpackG aims to minimize the environmental impact of packaging waste, increase recycling rates and hold the producers of packaging waste accountable.
In this context, LUCID fulfills the function of a central platform for recording packaging data and monitoring the legal requirements. The required data includes material type, quantity and proof of recycling.
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Key facts about the LUCID Packaging Register
- Registration in the LUCID portal of the Central Agency Packaging Register (ZSVR) is completely free of charge.
- Anyone who puts packaging into circulation in Germany must register in the LUCID Packaging Register.
- After registration, each company receives an individual number, which is essential for licensing with dual systems and all data reports.
- Companies report their packaging volumes at least twice a year - a planned report in advance and a final report after the end of the year.
- The ZSVR checks compliance with the Packaging Act via LUCID data and can impose fines of up to 200,000 euros or sales bans in the event of violations.
What is the LUCID packaging register of the ZSVR?
LUCID is a public online packaging register that was created by the ZSVR to implement and monitor the VerpackG. The aim is to record marketers of packaged products. This registration serves to monitor the packaging licensing obligations under the VerpackG. The LUCID register is therefore a database in which information on manufacturers, brands and packaging is recorded and forwarded to the central office. Required data on packaging includes material type, quantity and proof of recycling.
To ensure greater transparency, the LUCID packaging register is publicly accessible. However, not all details of registered distributors are published, only the data specified in Section 9 of the Packaging Act. These are:
- Registration number
- Date of registration
- Name, address and contact details of the company
- Brand names under which packaging subject to system participation is placed on the market
Who must register with LUCID?
Anyone who puts packaging into circulation in Germany must register in the LUCID Packaging Register. These companies are referred to as initial distributors or distributors. Initial distributors or manufacturers are therefore all companies that place packaging filled with goods on the German market for the first time on a commercial basis or import it into Germany.
According to the statutory provisions of the Packaging Act, LUCID registration, packaging licensing and the associated reporting of packaging data are mandatory. According to the Packaging Act, packaging serves to protect and transport, handle or present the goods sold.
What is the LUCID number?
The LUCID number is an identification number that is assigned upon registration in the Packaging Register. It is used for registration with a dual system and as proof that the company complies with the obligations of the Packaging Act. It is often necessary to provide the LUCID number to authorities or business partners. In this way, proper licensing can be confirmed.
You will receive confirmation and your LUCID number immediately after registration. The number is then immediately valid so that you can subsequently register with a dual system. There is a fixed format for the LUCID registration number
- which consists of the country code and a 13-digit number sequence and looks like this: DE 1234567890987. You can find the LUCID number in the dashboard of your LUCID account.
Which packaging must be registered with LUCID?
In principle, all packaging placed on the market in Germany must be registered with LUCID. However, not all packaging must also be licensed with a dual system. The Packaging Act distinguishes between packaging subject to system participation and packaging not subject to system participation.
Packaging subject to system participation is all packaging that accumulates with private end consumers. Packaging that is not subject to system participation is generated commercially, is export packaging or packaging that is not placed on the market via private final consumers.
In both cases, the obligation to register in the LUCID Packaging Register applies equally. However, the obligation to obtain a packaging license only applies to packaging subject to system participation.
Packaging subject to system participation
- Sales packaging
- Shipping packaging
- secondary packaging
- Service packaging (if not pre-participated) which mostly accumulates as waste with end consumers
Packaging not subject to system participation
- Disposable beverage packaging with mandatory deposit
- Transport packaging
- Reusable packaging
- Sales packaging and secondary packaging that does not typically accumulate as waste with end consumers after use
Apply for LUCID registration and LUCID number
Strictly speaking, the LUCID number is not applied for, as it is issued immediately upon registration in the LUCID Packaging Register. When registering in the LUCID portal of the ZSVR, you start as a “manufacturer”. This category includes producers of goods, distributors, importers as well as online and mail order companies. You enter your e-mail address and choose a password. When registering, you must enter important data about your company.
You enter your company's master data. This includes general data such as address, telephone number, your VAT identification number or tax number and a national identification number. You then specify the types of packaging, whereby there are two categories of packaging. Packaging with system participation obligation and packaging without system participation obligation. Select the appropriate one in each case. Then it's on to brand names. The brand names that are recognizable on the packaging of your goods must be indicated here. If there is no brand name on the packaging, enter your company name. If you are dealing with pre-packaged service packaging, enter the company name of your supplier/wholesaler.
LUCID Packaging Register: Costs
Registration in the LUCID Packaging Register of the ZSVR is free of charge for manufacturers and initial distributors. The transmission of data and all associated steps are also free of charge.
The costs associated with placing on the market are related to packaging licensing. This is because the costs of licensing packaging to cover disposal costs are covered by dual systems.
To get a quick overview of the costs of packaging licensing, you can use the zmart online calculator.
[zmart online calculator]](https://www.zmart.de/en/calculator)
LUCID packaging register for small businesses
As already clarified, all companies that place packaging on the German market for the first time must register with LUCID. This affects large, medium-sized and small businesses equally
- regardless of the size and turnover of the company. The Packaging Act does not provide for any minimum quantity regulations or turnover-related differences. Freelancers and retailers are subject to the obligations of the Packaging Act. This means that even the smallest quantities of sales, shipping or service packaging must be registered.
*How does LUCID affect Amazon, Ebay, Etsy & Co.
Products that are sold to German customers via online stores such as eBay, Amazon, Etsy or Alibaba are also subject to registration. This registration obligation also applies to online retailers when they place packaging on the German market for the first time. This applies regardless of whether they are based in Germany or abroad.
Which quantity and data reports are mandatory with LUCID?
Do you place packaging with a system participation obligation on the market? Then you must regularly report your packaging quantities
- not only to your dual system, but also to the LUCID Packaging Register. *Every data report to the dual system must therefore also be entered 1:1 in the LUCID packaging register without delay.* The reporting frequency depends on the system participation contract - e.g. monthly, quarterly or annual reports on packaging quantities.
If there are no contractually defined reporting periods, you must at least enter the total quantities from your system participation contract as an annual planned quantity in the LUCID Packaging Register. A notification of the packaging quantities must also be submitted to the Packaging Register when your system participation contract is concluded or extended.
The planned quantity report is the initial report. This relates to the following calendar year. You use it to report your planned packaging quantities. The submission of this planned quantity for the following year can only be submitted by December 31 of the current year. After this deadline, your planned quantity will be filed as a quantity report for the current year.
The year-end quantity report is the actual quantity report for the previous calendar year. You use it to report your total packaging quantities placed on the market in a year. This can only be submitted for the previous year by May 15. After this deadline, please submit your actual quantities as a supplementary quantity report.
What are the penalties for not registering?
The LUCID Packaging Register and the German Packaging Act (VerpackG) are closely linked, as the online register serves to implement the law. The obligation to register packaging placed on the market for the first time is therefore binding in any case. If you as a distributor of packaging do not register with LUCID, you are in breach of the VerpackG. This means that the packaging in question will be banned from sale. The violation may result in legal consequences and financial penalties. If, for example, the Central Agency finds that a company has not licensed any or too little packaging material, this can be punished with fines of up to 200,000 euros.
Austria
In Austria, manufacturers and importers must license packaging in order to finance disposal and recycling. Austria's own system differs from the German LUCID register. The Packaging Act (VerpackG) is the relevant regulation, and packaging registration is carried out by organizations such as ARA and Interseroh Austria GmbH.
France
Manufacturers and importers of packaging in France are also obliged to license their packaging. The organizations CITEO and Adelphe are responsible for packaging registration and licensing. Companies that place packaging on the French market must register with one of these organizations.
European Union
To date, EU countries have transposed EU directives into national law, resulting in different regulations. The EU is striving to harmonize environmental standards, including the Packaging Directive (94/62/EC) and the Circular Economy Package. These set out requirements for packaging management and recycling in the member states
United States
In the US, there is neither a packaging registry like LUCID nor federal regulations for packaging registration and licensing. Regulation is the responsibility of the states and can vary widely. Some have Extended Producer Responsibility (EPR) laws for the disposal and recycling of packaging waste.
Important questions again in brief:
You are unsure whether your packaging is subject to system participation?
You can use the ZVSR digital catalog of packaging subject to system participation to check whether your packaging is subject to system participation.
What is the Central Agency Packaging Register?
The Central Agency Packaging Register (ZSVR) was established as a private foundation on May 15, 2017. The ZSVR aims to make the market surveillance of packaged goods and disposal systems more effective. Since 2019, it has been the officially appointed authority for monitoring compliance with the German Packaging Act (VerpackG). This ensures greater transparency and fairer competition. The ZSVR is also subject to the supervision of the Federal Environment Agency. The Central Agency manages the LUCID Packaging Register. This is used for the comprehensive recording of packaging information from manufacturers, initial distributors and dual systems.
The main tasks of the ZSVR in connection with the VerpackG and the packaging license are:
- Registration of all manufacturers of packaged goods in the LUCID Packaging Register
- Receiving and checking the quantity and data reports from manufacturers
- Checking and ordering declarations of completeness
- Publication of manufacturers with filed declarations of completeness