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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Who must register with LUCID?

Companies that place packaging on the German market for the first time are regarded as initial distributors of packaging. This includes manufacturers, importers, online retailers and stationary retailers.

This applies equally to large, medium-sized and small businesses. The obligation to register applies to all companies that place packaged goods on the German market. According to the legal regulations, LUCID registration, packaging licensing and the associated reporting of packaging data are mandatory.

Which type of packaging must be registered?

The VerpackG distinguishes between packaging subject to system participation and packaging not subject to system participation. Both types are equally subject to the obligation to be registered in the LUCID Packaging Register. However, the obligation to obtain a packaging license only applies to packaging subject to system participation.
Packaging subject to system participation is packaging that accumulates with private final consumers and is typically disposed of in the dual system. Packaging that is not subject to system participation is packaging that is generated commercially, export packaging or packaging that is not placed on the market via private final consumers.

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

Amazon, Ebay & Etsy

Retailers who sell via platforms such as Amazon, eBay, Etsy or Alibaba are also subject to the general obligations. In addition to the obligation to register and provide packaging data, there is also the platform responsibility.
In some cases, platforms such as Amazon or eBay assume certain responsibilities in connection with packaging. Nevertheless, the direct seller, i.e. the retailer, remains responsible for compliance with legal requirements and registration in LUCID.

What does the LUCID registration cost?

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.

However, it is important to note that there are costs associated with the licensing of packaging. The zmart online calculator is available to give you a quick overview of the costs of packaging licensing.
[zmart online calculator]](https://www.zmart.de/en/calculator)

Penalties for non-registration

LUCID and the German Packaging Act (VerpackG) are closely linked, as the law sets out the regulations for packaging and licensing. Companies that place packaging on the market for the first time are obliged to register and license the packaging.

If you do not register with LUCID as a distributor of packaging, 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. For example, if the Central Agency finds that a company has not licensed enough or any packaging material at all, this can result in fines of up to 200,000 euros.

Small businesses and online retailers

Both large companies and small businesses, including online retailers, that place packaging on the German market must register in the LUCID Packaging Register of the Central Agency Packaging Register (ZSVR).

Costs for *packaging licensing: Small businesses and online retailers should be aware that there are costs associated with packaging licensing. These costs depend on various factors, such as the type of packaging and recycling rates. Compliance with legal requirements: Compliance with legal requirements, including registration in LUCID, is crucial for small business owners and online retailers to avoid legal consequences and fines.

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.