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Completeness Declaration (LUCID, VerpackG)

Do you deliver your goods to the German market?

If the answer is YES, then according to the provisions of German law, you are therefore the entity that places the packaging on the German market and you are obliged to register in the LUCID register and fulfil all additional obligations related to it.

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What is LUCID?

LUCID is a public register, the administrator of which is the Zentrale Stelle Verpackungsregister (Central Register of Packaging).

What is the purpose of these rules?

VerpackG is the German Packaging Act that entered into force on January 1, 2019, and replaced the previous Packaging Ordinance. This is related to the implementation of the EU directive, which aims to move to more environmentally friendly packaging materials.

Who is required to register with LUCID?

Each entity that places packaging on the German market along with the delivered goods.

What specific information should you report in the system?

In connection with the new act, contractors selling their products or goods to Germany should register in the LUCID register and prepare the so-called Completeness Declaration (Vollständigkeitserklärung).

Who is required to draw up the Completness Declaration?

The obligation to draw up and submit the Declaration is required for units whose actual quantity of packaging placed on the German market in the previous calendar year exceeds at least one of the following three thresholds:

  • 80 000 kg of glass,
  • 50 000 kg of paper and cardboard,
  • 30 000 kg of other materials (plastics, composite materials, metal).

The unit responsible for fulfilling the packaging obligations is the unit that is legally responsible for products or goods when they cross the border. It is also worth knowing that the Packaging Office is entitled to request the submission of the Declaration, even if the values shown by the unit are below the above thresholds.

Are there any additional requirements?

The mere registration in LUCID is not tantamount to meeting the requirements – in addition to the obligation to submit the Declaration, you must also sign an agreement with a selected organisation for a system for declaring the number of packaging placed on the market and company data. 

Moreover, the act imposes on entities an obligation to verify by an auditor the information contained in the Declaration and to prepare an appropriate report on this verification, which the entity attaches to the Declaration.

Where should the Declaration be submitted?

The declaration and the auditor’s verification report should be submitted in electronic form to the central register of packaging (LUCID).

By when should the Declaration be submitted?

The declaration should be submitted annually by May 15 for the previous year.

What will happen if you fail to meet these obligations?

In the absence of registration, reporting in the system, or reporting data on the number and type of packaging, the goods may not be sold in Germany. Depending on the seriousness of the infringement, fines of up to EUR 200 thousand may be imposed.

Piotr STASZKIEWICZ

Piotr STASZKIEWICZ

Audit Partner

+48 61 8515 766

Contact Piotr STASZKIEWICZ