As reported by the Bundestag, on 16 April 2020 the federal government published its evaluation report on the effects of the regulations under Section 22 (2) of the Packaging Act and on the operation and effectiveness of the Foundation Central Agency Packaging Register (21/14). The report praises the Central Agency Packaging Register (ZSVR) in particular for strengthening competition through its efficient organisation, especially in the area of enforcement. The way in which the Packaging Act is enforced in close cooperation with the state enforcement authorities is described in detail on page 8 of the report. Here is a brief summary of the key points (further details can be found in the report linked above):
- The Central Agency Packaging Register (ZSVR) works closely and effectively with the state enforcement authorities.
- It makes suspected cases of administrative offences available via a digital state enforcement authority portal, which is used by over 90% of the authorities.
- A special mailbox for authorities and telephone consultations enable fast communication.
- In addition, the ZSVR regularly provides information about events (e.g. enforcement meetings at state level) and webinars, which have met with a positive response from the authorities.
- An open working group of the ZSVR with representatives of the federal states from the Committee for Product Stewardship (APV) of the Federal Working Group on Waste (LAGA) promotes regular dialogue on enforcement issues. The results of the discussions are communicated so that all federal states benefit from them.
- ZSVR reports are prepared in a practical manner so that the enforcement authorities can handle them well and obtain the necessary information from them.
- There are currently no known complaints about the ZSVR from the federal states.
Against the background of the well-established Packaging Act enforcement, the following crucial information from the report is a warning signal to all sellers and producers registered in the LUCID portal who have not yet commissioned a dual system or registered one in LUCID:
"At the same time, it is also clear that so far only around a third of the producers who, according to their own statements in LUCID, are required to prove system participation have actually done so. This poses a considerable challenge for enforcement." From take-e-way's point of view, it can be assumed that the ZSVR will deal heavily with this issue in the area of enforcement, especially as the registration data makes it easy for the ZVSR to identify sellers registered in LUCID who are not participating in the system.
No system participation available? The take-e-way consulting team will be happy to help you and is available via +49/40/750687-0 or consulting@take-e-way.de
PPWR online training now available
The EU Packaging Regulation (EU) 2025/40 (PPWR) is one of the most important to-do topics for sellers and producers of products and packaging in the coming months – alongside the EU Batteries Regulation. Due to the great interest in the PPWR, we recommend that you request your personalised online PPWR training course in good time and without obligation.
