Guidelines: Reporting packaging volumes
Find out when and how to submit which data reports to the LUCID Packaging Register.
Data reporting
You submit a data report to a system when you …
… report your packaging volumes when concluding a system participation agreement,
… extend an existing system participation agreement,
… submit additional reports about packaging volumes at contractually agreed intervals,
… correct a report about packaging volumes that you had already submitted,
… report your packaging volumes because the system operator asked you to do so.
What information do you have to enter under your registration number when filing data report in the LUCID Packaging Register?
All the details you need can be found in your system participation agreement:
the reporting period. This period must match the one used for the report to your system operator.
the name of the system with which you concluded a system participation agreement.
the material types (e.g. paper, paperboard and cardboard, plastics, ferrous metals or glass) and packaging volumes per material type (mass). Enter the packaging volumes in kilogrammes to the third decimal point.
Heads-up: Please make sure that the registration number in your system participation agreement matches the one in the LUCID Packaging Register so that data reports can be conclusively assigned to you. If the registration number is missing from your system operator's volume confirmation, please contact them.
How to submit data reports on packaging volumes
Whenever a company reports packaging volumes to its system operator, the exact same report must also be filed with the LUCID Packaging Register. The reporting schedule depends on what you agreed in your system participation agreement. Typical intervals include monthly, quarterly or yearly data reports. If no intervals were agreed in your system participation agreement, you have to at least report the total packaging volume from your system participation agreement as an annual planned volume to the LUCID Packaging Register. You also have to report you packaging volumes to the LUCID Packaging Register when entering into or extending your system participation agreement.
Heads-up: You will not receive any separate confirmation that your data report was filed in the LUCID Packaging Register. However, you can access your data reports at any time through your personal dashboard in the LUCID Packaging Register.
The following deadlines must be observed for technical reasons when submitting reports:
An initial planned volume report refers to the following calendar year and includes your packaging volumes planned for that year. Initial planned volume reports for the following year can only be filed by 31 December of the current year. After that date, you file your planned volume as an intra-year volume report.
A year-end volume report is an actual volume report for the past calendar year. It includes the total volume of all packaging that you placed on the German market in a given year. Year-end volume reports for the previous year (actual volumes) can only be filed up to 15 May. After that date, please file your actual volumes as a supplementary volume report.
In this case, you first have to report the change in packaging volumes to your system operator. Then submit a data report to the LUCID Packaging Register. This report to LUCID must contain the adjusted and confirmed volumes reported to your system. The type of data report you submit in the LUCID Packaging Register depends on when you adjust your packaging volumes:
Scenario #1: You adjust your planned volumes with your system operator in the current year. In this scenario, the adjustment refers to the current year. That is why you need to file an 'intra-year volume report' in the LUCID Packaging Register with the new total volume. If you have already filed an intra-year volume report, you have to correct the volumes on file.
Scenario #2: You adjust your planned volumes with the system operator after the forecast period / calendar year has expired. In this scenario, you need to file the new total volume as a 'year-end volume report' in the LUCID Packaging Register after the calendar year has ended.
System data reporting
The systems are legally required to report the packaging volumes participated with them to the Zentrale Stelle Verpackungsregister (Foundation Central Agency Packaging Register – ZSVR) as a control report. The ZSVR compares the data with the volume reports submitted by companies registered with the LUCID Packaging Register, enabling it to quickly identify any discrepancies. Based on their reports, the ZSVR also calculates the systems' market shares.
Heads-up: You are still legally required to report your data to the LUCID Packaging Register.
Selected FAQs for this topic
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.
That depends on the type of report in the LUCID Packaging Register. Let us have a look at two of these types, and how to edit them.
Initial planned volume reports: You would like to correct your report for the current year? Then all you have to do is file an intra-year volume report containing the amended packaging volumes. The reporting period you have to enter is January to December. The initial planned volume report you had filed already will still be included in the overview of data reports. The newly filed intra-year volume report replaces the corrected initial planned volume report and is now considered to be your current forecast report.
Year-end volume reports: If you can no longer edit a year-end volume report, you have to submit a supplementary volume report to correct it. In this supplementary volume report, you simply enter the difference between the year-end volume report that needs to be corrected and the actual volumes. If volumes need to be reduced, add a negative sign in front of the difference.
Example: Your year-end volume report in the LUCID Packaging Register states that you placed 100 kg of paper, paperboard and cardboard (PPC) on the German market during the past year. This is wrong. You actually placed 120 kg of PPC on the German market and participated that volume with a system. If you can no longer edit your year-end volume report, you must file a supplementary volume report with the following value for the year in the question: 20 kg of PPC.
No, the Verpackungsgesetz (Packaging Act) prohibits the instruction of a third party for data reporting. Data reporting must be completed personally by the producer under obligation or an appropriately authorised contact person within the producer's company. This must also be confirmed with each report.
Exception: international producers under obligation without a branch within Germany can appoint an authorised representative to fulfil their duties under the Verpackungsgesetz on their behalf. (This does not apply, however, to registration.) Further information can be found in our knowledge base dedicated to authorising a representative.
As soon as a volume report is made to a system, the producer is required to report the same information to the LUCID Packaging Register. The reporting schedule depends on what is agreed in the system participation agreement.
If a producer has contractually agreed to provide a single report to a system per year (regardless of whether it contains planned or actual volumes), they also must report this information to the LUCID Packaging Register immediately. If a more frequent reporting schedule was agreed with the system (e.g. quarterly or monthly), the producer must also submit more frequent volume reports to the LUCID Packaging Register.