Der Grüne Punkt is often asked this question at this time of year.

We at Der Grüne Punkt are the operator of a (dual) system and as such are legally obliged to report the quantities of packaging subject to system participation that you as a customer have accounted with us to the Central Agency Packaging Register (ZSVR) in the LUCID. This is done, among other things, with the so-called annual report, which contains all our customers with their respective LUCID registration numbers and the packaging weights per material fraction reported for the previous calendar year. The Packaging Act now obliges us to "inform" each individual customer of the content of our annual report, i.e. their registration number and the packaging weights accounted with us. This is why the document is entitled "Notification", whereby it makes no difference whether the quantity involved in the system is one kilogram or one thousand tons.

The situation is completely different with the so-called "declaration of completeness" (German Vollständigkeitserklärung (VE)), which must be submitted independently by all producers within the meaning of the Packaging Act to the Central Agency Packaging Register in LUCID if one or more of the statutory de minimis limits for sales packaging subject to system participation have been exceeded in the past calendar year.

These are

• 80 tonnes of glass or
• 50 tonnes of paper, cardboard or carton or
• 30 tonnes of any other material (plastics, metals, composite packaging).

The deadline for submission is 15.05. of the following year, i.e. for the calendar year 2023 until 15.05.2024. Furthermore, the VE must be certified by an auditor registered with the ZSVR.

However, if the quantities of packaging subject to system participation that you place on the market are below the above-mentioned de minimis limits, there is no obligation to make an unsolicited submission. However, the ZSVR is authorized to order the disposal regardless of the aforementioned limits.

To summarize once again:

Please note: The submission of the VE represents an additional obligation that must be fulfilled if the corresponding above-mentioned thresholds are exceeded. Completely independent of these limits, there is an unrestricted obligation to participate in the system and to report data in LUCID. These apply from the first kilogram of packaging placed on the market that is subject to system participation, i.e. packaging that typically accumulates with private final consumers.

This is an informational text and does not constitute legal advice.