Companies placing certain types of packaging on the German market must register with the ZSVR (the Central Agency Packaging Register). For shipping packaging, they must also participate in a waste management scheme and report their packaging data correctly. Merely registering is not enough in these cases.
Under Section 7 of the German Packaging Law Implementation Act (VerpackDG), taking part in a waste management scheme is generally mandatory. Costs depend, among other things, on packaging type and weight. Although, according to the ZSVR’s current guidelines, registration confirms that the system participation obligation has been fulfilled, the registration does not itself select a specific scheme. Therefore, being registered does not automatically mean you are part of a system.
Reporting packaging data correctly is crucial
Under Section 9 of the VerpackDG, relevant packaging data must be reported to both the ZSVR and the chosen waste management scheme. The report should include:
- Your registration number
- Packaging material and weight
- The participating waste management scheme
- Since when and for how long you have been participating in said system
Check for missing or inconsistent quantity reports and correct them where necessary! Depending on your packaging volume, a declaration of completeness may also be needed, Section 10 of the VerpackDG says.
Review your data to avoid costly compliance risks
Even previous reporting periods should be reviewed. The fact that the ZSVR has not contacted you does not necessarily mean that all your obligations have been met. According to Section 66 of the VerpackDG, violations can lead to fines ranging from 10,000 to 200,000 euros.
Make sure you know where you stand:
- Has all required packaging data been reported?
- Have you participated in a waste management scheme?
- Are retrospective reports needed?
- Is a declaration of completeness required?
Need help with LUCID or your packaging obligations? The take-e-way team is happy to support you with registration, system participation and data reporting.
