The obligation to report data about packaging volumes applies to companies that place packaging subject to system participation on the German market. Packaging subject to system participation includes retail, grouped and shipment packaging.

That means that if you exclusively place packaging on the German market that is not subject to system participation (for example transport packaging, reusable packaging and single-use beverage packaging subject to deposit), you do not have to submit data reports about your packaging volumes. An exception applies to declarations of completeness: declaring volumes of industrial retail and grouped packaging is mandatory.

Packaging that is not subject to system participation does not have to participate with a system. But recovery, return and documentation obligations do apply; these obligations are set out in section 15 VerpackG (Packaging Act).

Good to know: if your information in the LUCID Packaging Register states that you exclusively place packaging not subject to system participation on the German market, LUCID will not let you file a data report.