Current situation
Companies that place packaging on the market in Germany must conclude a system participation agreement (also for 2025) and report the planned packaging quantities to the
Zentrale Stelle Verpackungsregister (ZSVR). Otherwise, these companies will not be allowed to sell their goods (any more).
Is your packaging subject to a system participation obligation?
The Zentrale Stelle Verpackungsregister (ZSVR) last updated the “Catalog of packaging subject to system participation” in 2023. It can be used to check which kind fo packaging the ZSVR defines as subject to system participation. If you cannot find your packaging in the catalog, you can submit a corresponding request to the ZSVR.
Manufacturers, retailers and online retailers with packaging subject to system participation
must essentially fulfill 4 important tasks:
- Conclusion of a system participation agreement
- Registration in the LUCID packaging register of the ZSVR
- Data reporting to LUCID and its system operator:
- Estimation of the expected annual packaging quantities and notification of the planned quantities to a system operator
- Regular reporting of the quantities actually placed on the market. This serves to reconcile and consolidate the quantities reported to the system operator and the ZSVR in order to ensure data consistency
- Communication of the LUCID registration number from the manufacturer, retailer and online retailer to the system operator to ensure smooth data synchronisation.
Important:
Having only a registration and consequently the existence of a LUCID number is NOT sufficient for packaging material that is subject to system participation. As the term already makes clear, you also need a contract with a so-called “dual system”, of which 10 are currently accredited in Germany.
What is the ZSVR?
The Zentrale Stelle Verpackungsregister (ZSVR) was implemented in the course of the introduction of the Packaging Act (VerpackG) in order to
- monitor the legal framework and ensure that applicable rules are observed by everyone.
- ensure effective enforcement of market control.
Sales packaging – what is it?
Depending on the required function, packaging can have different functions and be made from a wide variety of materials.
In Germany, the Packaging Act (VerpackG) defines the different types of packaging in Section 3 (1):
- Sales packaging (primary packaging, subject to system participation)
Sales packaging is generally filled with goods and offered to private end consumers. This includes not only private households, but also hotels, restaurants and other catering establishments, hospitals, educational institutions and freelancers, as well as some craft businesses, agricultural businesses and many other establishments. - Secondary packaging (secondary packaging, subject to system participation)
Packaging that contains a certain number of sales units that are delivered together to the end user or consumer at the point of sale. - Transport packaging (tertiary packaging, not subject to system participation)
Packaging that facilitates the handling and transportation of goods in such a way that direct contact and transport damage are avoided. This packaging is typically not intended for distribution to end consumers.
There are also the following other types of packaging that are subject to system participation as well:
- Service packaging
Packaging, that is only filled when a product is purchased in the store, for example carrier bags or to-go cups - Shipping packaging
Packaging, which enable or support the shipment of goods to the end consumer.
Important:
Unlike in some other European countries, the Packaging Act does not have any de minimis limits.
Obliged parties must take care of the licensing of their packaging as soon as they place it on the market.
Do you need help with packaging licensing in Germany or the EU?
PRONEXA will be happy to help you! Answer 5 simple questions in our quick assessment and then arrange a non-binding telephone call with us.