Data reporting according to the Packaging Act
If you bring packaging into circulation in Germany, you cannot avoid the German Packaging Act (VerpackG). This law regulates how packaging must be licensed, collected and recycled
- an essential step for a functioning circular economy. The quantity and data reports that companies have to submit regularly are particularly important. These ensure transparency, enable correct licensing and help to reduce the environmental impact of packaging.
Planned quantity notification: Your forecast for the coming year (§ 10 VerpackG)
The planned quantity report is your estimate of the packaging quantities that you will place on the market in the coming calendar year. It concerns all packaging subject to system participation, i.e. packaging that typically accumulates with private final consumers, such as sales packaging (e.g. yoghurt pots), secondary packaging or shipping material. You must submit this notification to the LUCID packaging register by December 31 of the current year at the latest.
What is included in the notification? You must state which materials (e.g. glass, paper, plastic, aluminum) you use and how much of them you expect to use in kilograms (to the nearest gram, with three decimal places). This data must match the information you report to your dual system, as the Central Agency Packaging Register (ZSVR) carries out a comparison. An accurate estimate is important as it forms the basis for your license fees. If your quantities change later, you can correct them using the quantity adjustment during the year.
Tip: Use past sales data to make your forecast as realistic as possible.
Volume adjustment during the year: flexibility for adjustments (§ 10 VerpackG)
It can happen that quantities turn out to be different from the planned quantity report - whether due to unexpected growth, new products or changes in packaging. In such cases, the quantity adjustment during the year comes into play. It allows you to correct your original planned quantity report during the current year. It is also mandatory if you register in the Packaging Register during the year and have to submit an initial quantity estimate for the current year.
You submit the adjustment via the LUCID Packaging Register after you have reported the changed quantities to your dual system. This is important to ensure data consistency between the register and the system. Please note: Changes can concern both an increase and a reduction in quantities. Accurate documentation of your packaging quantities will help you to make these adjustments quickly and correctly. Violations of the reporting obligation can result in fines in accordance with Section 34 VerpackG.
Year-end report: Focus on actual consumption (Section 10 VerpackG)
The year-end report, often also referred to as the actual quantity report, marks the end of your annual reporting obligations. Here you enter the actual quantities of packaging subject to system participation that you placed on the market in the previous calendar year. This report must be submitted to the LUCID Packaging Register by May 15 of the following year at the latest.
The data must again include the type of material and quantity in kilograms and must correspond exactly with the information provided to your dual system. If you discover errors in your original report, you can correct them by submitting a supplementary quantity report. For damaged or unsaleable packaging, there is the option of submitting a deduction quantity report - however, this requires complete documentation. The year-end declaration is not only a legal obligation, but also crucial for the correct billing of your license costs and the recording of packaging volumes in Germany.
Declaration of completeness: transparency for large distributors (§ 11 VerpackG)
The declaration of completeness is an additional obligation for companies that place large quantities of packaging on the market. It serves to provide detailed proof of compliance with the VerpackG and covers both packaging subject to system participation and packaging not subject to system participation (e.g. transport packaging). This declaration must be submitted to the LUCID portal by May 15 of the following year and checked by an independent, registered expert, auditor, tax consultant or sworn accountant.
When does this obligation apply? As soon as you exceed the following de minimis limits:
- 80,000 kg of glass
- 50,000 kg of paper, cardboard, carton
- 30,000 kg of other materials (e.g. plastic, aluminum, ferrous metals)
If you are below these limits, you are exempt from the declaration, unless the ZSVR or a state authority explicitly requests the submission. The declaration of completeness ensures maximum transparency and helps to ensure data quality in packaging management.
Our tip: Prepare your documents in good time, as it can take time for an expert to check them.
Conclusion:
The quantity and data reports in accordance with the Packaging Act are essential to ensure transparency in the handling of packaging in Germany. The planned quantity report forms the basis by providing a forecast of packaging quantities for the coming year and is submitted to the LUCID portal by December 31. The quantity adjustment during the year offers flexibility to correct deviations during the year and ensures that your data is always up to date. With the year-end report, which is due by 15 May of the following year, you document the actual packaging quantities of the previous year, which enables accurate billing of license costs. For companies with large quantities of packaging, the declaration of completeness is an important tool for demonstrating compliance with the law - it requires an audit by an expert and takes all types of packaging into account.