ZSVR data reporting: What are manufacturers obligated to do?

Who must submit data reports to the ZSVR?

Under the Packaging Act (VerpackG), manufacturers or initial distributors of packaging as well as the dual systems in Germany are required to submit regular reports to the Central Agency Packaging Register – ZSVR. These reports are made via the LUCID portal.

Manufacturers in the sense of § 7 Paragraph 1 Sentence 1 VerpackG must provide at least

• their individual registration number,
• the material type and mass of the packaging involved in a dual system,
• the name of the dual system with which the system participation was carried out,
• as well as the period of the system participation.

They are obliged to do this in accordance with § 10 of the Packaging Act. All data reports must be made without the involvement of third parties.

The dual systems, in turn, are required by Section 20 of the Packaging Act to report to the ZSVR both the expected mass of packaging and the actual mass of packaging participating per manufacturer.

What is important about ZSVR data reporting for manufacturers?

Anyone who is considered to be a manufacturer or first distributor of packaging subject to system participation must also immediately report to the ZSVR all data within the scope of system participation that they transmit to a dual system.

This means: The information about material types and quantities that are passed on to the system to be involved must also be immediately communicated to the Central Packaging Register.

This means: The information about material types and quantities that are passed on to the system to be involved must also be immediately communicated to the Central Packaging Register Office. This is a so-called double notification.

This also concerns the time frame. If a manufacturer has agreed with the system on one report per year, this rhythm also applies to the data report to the ZSVR. A higher reporting frequency can also be agreed with the system, for example per quarter or month. Participation in the dual system and data reporting to the ZSVR must always take place immediately one after the other.

Which data reports must be received by the ZSVR?

A manufacturer or initial distributor must submit several data reports to the ZSVR:

• The planned quantity report, in which he states which packaging types and quantities he plans to place on the market and during which period (for example, a calendar year).
• The year-end declaration (also called actual declaration), in which he states which packaging types and quantities he actually placed on the market in the previous licensing period.

Important to know: Both the conclusion and the extension of a contract with a dual system require a data report according to § 10 VerpackG. This also applies if a manufacturer or initial distributor has already participated in packaging quantities with a (different) dual system.

In addition, it is important for manufacturers and initial distributors to ensure that they notify the dual system of the "active" registration number under which they are listed with the ZSVR. The dual systems also specify this number when reporting to the ZSVR. If there are discrepancies here, proper system participation cannot be traced.

WHAT IS IMPORTANT IN THE DECLARATION OF COMPLETENESS?

Companies with a certain amount of packaging material that they put into circulation must submit a declaration of completeness to the ZSVR every year. It is mandatory to file this declaration by May 15, because this is the deadline for the Central Packaging Register. It is recommended to link this deposit directly with the system participation and data reporting. As of June 1, each data report is considered a subsequent quantity adjustment.

Obligated to submit a declaration of completeness are automatically companies that have exceeded the following quantity limits in the previous year:

• 80,000 kg glass;
• 50,000 kg of paper, cardboard, carton;
• 30,000 kg of other materials.

Even if a company does not reach the above-mentioned quantities, the ZSVR may still require a declaration of completeness in case of doubt. In any case, this must be checked and confirmed by a registered expert, auditor, tax consultant or sworn accountant.

Important: The requirements of the ZSVR for the "Technical Instructions on the Declaration of Completeness" must be strictly adhered to when filing.