Good start to the Packaging Register

The Stiftung Zentrale Stelle Verpackungsregister (Foundation Central Agency Packaging Register) was set up with the Packaging Act. It ensures greater transparency in the financing of waste disposal and the use of packaging.

Since 1 January, new far-reaching regulations for packaging disposal have been in force in Germany. On the one hand, significantly more packaging is to be recycled. On the other hand, all enterprises acting professionally in the course of their business – from corporate groups to small retailers – that fill packaging for the first time and place it on the market – are also to pay for its collection and recycling.

Less and better-recyclable packaging

The German Federal Environment Minister Svenja Schulze formulated the idea behind this as follows: “We want the industry to think comprehensively about what packaging is really necessary and what materials can be used in an environmentally friendly way. This works particularly well when environmentally harmful behaviour is more expensive and environmentally friendly behaviour is rewarded. This is where the Packaging Act comes in. Less packaging, but with better recyclability – that is the goal.”

Although in Germany, product responsibility for packaging, i.e. the obligation to finance the disposal and recycling of the packaging one has placed on the market, had already been in force since 1993, many companies did not fulfil this obligation due to a lack of official control possibilities.

Hardly any opportunities left for previous “responsibility dodgers”

However, the situation changed significantly on 1 January. Since then, all the companies concerned, whatever their size, have had to register their master data and the brand names they sell in the new “LUCID” Packaging Register. In addition, they must report the total quantities of packaging placed on the market per year to this online register at least once a year.

Those who do not comply with these legal requirements face sanctions. Those who fall within the scope of the Packaging Act and do not fulfil their obligations are subject to an automatic ban on the distribution of their goods. This applies to all distribution stages right through to the final distributor stage of a product, for example a kiosk. As a supportive measure heavy fines can be imposed.

A public authority as a supervisory body

Compliance with these obligations is monitored by the “Zentralen Stelle Verpackungsregister” (ZSVR) (Central Agency Packaging Register) in Osnabrück. The Foundation authority lists the obligated companies in a public register which is also accessible to consumers, records the registered companies’ reports on packaging quantities and those of the dual systems and compares these. This will be made possible for the first time by the fact that, in addition to the companies, the dual systems will in future also have to report the quantities of packaging to the LUCID Packaging Register in the context of the registration number available for each contract.

Each obligated party is itself responsible for registration at https://lucid.verpackungsregister.org and for reporting the packaging quantities. It is not possible to delegate the fulfilment of obligations to third parties. On the ZSVR website, www.verpackungsregister.org, you will find much information on the Packaging Act as well as on all changes, new obligations and deadlines.

A catalogue for identifying notifiable packaging

This includes, among other things, a (comprehensive, but not yet complete) catalogue, which is intended to assist in classifying with legal security whether or not packaging is subject to system participation. However, since the ZSVR itself is not allowed to provide legal advice, in cases of doubt fundamental questions regarding the system participation obligation must be addressed with system operators, consultants, experts, auditors or other relevant stakeholders. According to the ZSVR, the registration procedure itself has been “streamlined and takes about 10 to 15 minutes”.

By 25 January 2019, 150,000 companies had already registered in the LUCID Packaging Register. “This means that 90,000 more companies are registered than was previously the case with the dual systems. That is a good start,” says Gunda Rachut, head of the Foundation authority.

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