18. May 2022
From 1 July 2022, all marketers of packaging filled with goods in Germany will be obliged to register in the public register LUCID. This expanded mandatory registration is part of the amendment of the German Packaging Act (VerpackG), which came into force in mid-2021. The amendment imposes additional obligations on manufacturers and distributors of packed industrial, transport or commercial products, such as information, evidence, registration and financing obligations. Further information about the amendment of the German Packaging Act
The new mandatory registration is a supplement to the compulsory reporting in the existing LUCID system, which has been in place since 2019. This required manufacturers and distributors to register in a dual system for liable household packaging. Due to the supplement to the registration obligation, liable manufacturers and distributors must now register all packaging in the public register LUCID. It is already the case that RIGK licensees report types of packaging to the relevant RIGK take-back system. However, from 1 July this year it will also be mandatory for RIGK clients who are included under the liable manufacturers and distributors to register in the LUCID register at the German Central Agency packaging register (ZSVR). A manufacturer or distributor subject to this duty is anyone who commercially markets packaging, including secondary packaging and transport packaging, in Germany. The initial registration must now be carried out before the relevant packaging is marketed. If a company is already registered for a dual system for licensed household packaging, they must in any case provide a notification of change for industrial, transport and secondary packaging by 1 July 2022. Any breaches of the duty to register are punishable with fines.
Since 5 May 2022, all liable manufacturers and distributors have been able to carry out initial registration and notifications of change through the ZSVR website, using the LUCID data processing system there to transmit the disclosures now required about selling, secondary, transport and dangerous goods packaging to the ZSVR. For example, the name of the company, the type of packaging and the brands distributed must be given.
RIGK will support its clients with the implementation of mandatory registration, even if this obligation must be met by liable manufacturers themselves and cannot be delegated to a third party. For example, information correspondence has been sent to all RIGK clients, which describes in detail which companies come under the new registration obligation. In addition, a guideline about the exact procedure of the registration process has been provided, as well as the required disclosures. You can also find this guideline on the RIGK website.
This video also visually presents the obligations that result from the amendment.
Customer Relationship Manager / Public Relations Manager
Tel.: +49 611 308600-12