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The Zentrale Stelle Verpackungsregister / LUCID

The Stiftung Zentrale Stelle Verpackungsregister (Central Office) was founded on 15.05.2017 as a foundation under private law. Since 01.01.2019, the Central Office has been operating as an entrusted authority and is subordinate to the Federal Environment Agency. It maintains a public register in which every first distributor of sales packaging must register and receives data on the packaging quantities of manufacturers/first distributors and dual systems.

Tasks of the Central Office

The tasks of the Central Office are defined in § 26 of the Packaging Act and include the following tasks:

  • Keeping of the public register for initial distributors
  • Database for packaging data from manufacturers and systems
  • Market share calculations for the systems and industry solutions
  • Standards for measuring the recyclability of packaging
  • Testing of industry solutions
  • Setting standards with regard to the system participation obligation for packaging, reusable packaging, mandatory deposit, etc.
  • Register of experts, verification of volume flow certificates and recovery quotas as well as test guidelines

The control mechanism of the Central Office

Among other things, the Central Office was created to monitor compliance with the Packaging Act. Before the Packaging Act came into force, it was easier for companies to evade the licensing obligation.

Since 01.01.2019, every manufacturer/first distributor has had to register in the online portal LUCID of the Central Office. All registered companies are entered in a public register. The register can be viewed by anyone. If a company is not registered there, it may not place sales packaging on the German market that is not licensed. In practice, there is a ban on distribution. If a company has registered, it must report to the Central Office which quantities of packaging have been licensed under which dual system. In order to check whether the companies have actually carried out the licensing, the dual systems must also submit reports to the Central Office. For this purpose, the systems of the Central Office share with which company how much packaging material has been licensed. The registration number, which companies receive from the Central Office and must inform their system partner, is used as the identification feature. If the Central Office determines that a company has licensed too little or no packaging material, fines of up to €200,000 can be imposed.

At the same time, companies can check in the public register whether a competitor has registered with the Central Office. If this is not the case, there may be warnings under competition law.

The LUCID registration portal

Every company which, according to the Packaging Act, is regarded as a manufacturer/first distributor of sales packaging in Germany must register with the Central Office in the LUCID portal. After registration, the companies are included in the public register and receive a registration number, which they must communicate to their system partner. You can register here.

Who is regarded as the manufacturer/first distributor?

According to the Packaging Act, the manufacturer or first distributor is the party who places b2c packaging filled with goods on the German market for the first time. To put it more simply: The company that first wraps packaging around a product that will eventually be sold to private end consumers must license the packaging material. This also includes the shipping material. For example, if an online retailer purchases goods from a supplier that has already licensed the product packaging, the retailer must license the shipping material. Further information and examples can be found here.

Service packaging is an exception to this rule. These are packages that are filled by the distributor at the place where the goods are handed over. Typical service packages are, for example, bread roll bags, carrier bags or disposable snack dishes. Here, the final distributor can demand that the packaging licence is carried out by his packaging supplier. Anyone who licenses service packaging through his previous distributor is not permitted to register in the LUCID portal.

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