German Packaging Act: Effects of the Corona Pandemic on the Declaration of Completeness by 15 May 2020

The obligation to submit a declaration of completeness only applies if the volume of packaging placed on the market that is subject to the system participation obligation reached one of the three following quantity thresholds in the previous calendar year: 80,000 kg of glass; 50,000 kg of paper, cardboard, carton; 30,000 kg of ferrous metals, aluminium, plastics, beverage cartons, other composites. The 15 May 2020 target date refers to the statutory deadline over which the German Central Packaging Register has no influence.

The obligation to submit a declaration of completeness only applies if the volume of packaging placed on the market that is subject to the system participation obligation reached one of the three following quantity thresholds in the previous calendar year: 80,000 kg of glass; 50,000 kg of paper, cardboard, carton; 30,000 kg of ferrous metals, aluminium, plastics, beverage cartons, other composites. 

What is decisive for the obligation to submit a declaration of completeness are the quantities of packaging subject to system participation that you actually brought into circulation. Only if one of these packaging types reaches one or more of these threshold values in your end of year report 2019 ("Jahresabschlussmeldung, Istmengenmeldung") you are required to submit a declaration of completeness for the previous year by 15 May of the following year.
 
With respect to the declaration of completeness, you must electronically submit a so-called manufacturer’s declaration, a test confirmation, a test report and the test result in the LUCID Packaging Register. The registered inspectors required for the tests can be found in the inspection register of the Central Packaging Register at  Prüferregister Abt. 1 (Inspector Register Section 1) and Prüferregister Abt. 2 (Inspector Register Section 2).
 
Effects of the Corona Pandemic on the Declaration of Completeness
 
The 15 May 2020 target date refers to the statutory deadline over which the Central Packaging Register has no influence. Please contact your inspector if you have not already done so and clarify how the test can be carried out under the present framework conditions. It is the responsibility of the inspectors to decide which test activities can be performed instead of the on-site inspection. Options conceivable include video conferences to allow an insight into the IT system, clarification of questions by mail/telephone or the sending of packaging samples for sample weighing by post/parcel. The inspectors have already been contacted by the Central Packaging Register in this regard.
 
The Central Packaging Register hereby makes the following current supplementary information on the corona pandemic known: "The target date of 15th May is a legal deadline. An extension of the deadline can therefore not be granted. You can still file a declaration of completeness after the deadline. The obligation continues to apply even if the deadline has passed. The inspectors will receive additional information on this subject shortly."

If you have any queries, please do not hesitate to contact Ms Imke May at take-e-way GmbH by calling +49/40/750687-136 or sending an e-mail message to may@take-e-way.de.

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