From 55,000 to 1,000,000 – how the LUCID Packaging Register is improving fairness and transparency in the packaging recycling market

From 55,000 to 1,000,000 within just five years – before the Verpackungsgesetz (Packaging Act) entered into force, the packaging recycling market had been on the brink of collapse multiple times. Companies have technically been subject to financial producer responsibility for their packaging and required to pay for recycling since 1993, but many of them ignored their duty under packaging law to undertake system participation. The ZSVR’s mission was to make the packaging waste management market fairer for German and international companies by instilling transparency. That is why the LUCID Packaging Register is public and can be accessed by anyone.

Extended registration requirement and checks proving effective
The most recent amended version of the Verpackungsgesetz in particular has made an important contribution towards achieving a level playing field. Regardless of what type of packaging companies use to distribute their goods commercially for the first time in Germany, they have been required to register with the LUCID Packaging Register since 1 July 2022. To minimise the administrative burden this involves for companies, the ZSVR has streamlined the registration process. Visual examples of packaging and explanations have since made the process even more user friendly.

Since July 2022, a due diligence obligation applies to electronic marketplaces and fulfilment service providers. They have to check whether their retailers or ordering parties have met their registration and system participation requirements. If they have not, the marketplaces are not permitted to let online retailers use their platform to offer their goods and fulfilment service providers are not allowed to provide their services to these clients. To help marketplaces and fulfillers carry out their checks, the ZSVR has provided a digital register excerpt function. They can use an API to automatically verify their business partner’s registration status.

Impact of statutory amendments in figures
Registration numbers in the LUCID Packaging Register have risen dramatically since the end of 2021, and significantly through 2022. Nearly 750,000 have registered for the first time since January 2022, more than 400,000 from China alone. The number continues to grow every day; it is now over one million and spans more than 160 countries.

Streamlined, thoroughly digital and future-orientated – the ZSVR’s approach
This development is the result of digitalising all processes across the board, rigorous public relations work and awareness-raising campaigns. A high degree of automation and agile working methods have also helped. The ZSVR is committed to at least keeping up with the latest technology, if not staying ahead of the curve.

It is something the ZSVR has already been recognised for multiple times: for its IT security concept, the structure of its data-centred analysis platform CLAIR and the current transitioning of its IT architecture to become CO2 neutral. A central part of this is the ongoing restructuring of the packaging register to LUCID 2.0, which involves a newly programmed software application, an energysaving programming language and energy-efficient devices and servers.

For a level playing field – the ZSVR sets the rules
To achieve a level playing field, the ZSVR determines the rules of play within statutory bounds.

• Is an article of packaging subject to system participation – or not?
  Find out quickly and without any bureaucratic hassle with the system participation requirement catalogue.
• When is an article of packaging recyclable?
  The minimum standard for recycling-friendly packaging, which is updated and published annually, has the answer.
• How are companies with substantial volumes of packaging held accountable for living up to their producer responsibility?
  How are companies with substantial volumes of packaging held accountable for living up to their producer responsibility?

With the millionth registration in the LUCID Packaging Register, the ZSVR has created a transparency never experience before. It serves as the basis for identifying breaches and initiating enforcement proceedings. The ZSVR has referred more than 20,000 administrative offences to state enforcement authorities since 2019. And it has done so automatically using the LUCID Authorities Portal.

Central point of contact for target group-specific queries globally
The ZSVR helps companies and multipliers comply with Germany’s Verpackungsgesetz. It is the first point of contact and provides extensive information and guidance. Since its founding, the ZSVR team has responded to roughly 200,000 queries, more than 130,000 on the support hotline. The communication team works closely with chambers of commerce, associations, embassies and consulates in Germany and around the world. It also offers webinars and develops target group-specific materials including info graphics, check lists, explanatory films and comics.

Accepting producer responsibility, financing recycling
Registering in the LUCID Packaging Register is just the first step. Companies only live up to their producer responsibility when they then pay for their packaging to be recycled by concluding a system participation agreement with a system operator. The degree of system participation has increased dramatically across every material group since 2018. Eliminating underparticipation and making the packaging recycling market financially functional is the mission at the heart of the ZSVR’s activities and measures, whether through technical, communication, legal or digital channels. Everyone has to take part; that is what the ZSVR has laid the groundwork for over the past several years.

Ms Gunda Rachut, Chair of the ZSVR, commented: “A million registrations in the LUCID Packaging Register – that is more than simply a number. It is a sign of the massive strides that we have made on the way to creating a level playing field. The ZSVR and the LUCID Packaging Register are global pioneers and are seen as role models. The German government has put trailblazing laws into effect and anticipated planned requirements under the EU packaging regulation, such as marketplaces’ due diligence obligations. It puts us on good footing for what is planned on an EU level.”