Do I have to submit a declaration of completeness and if so, what do I have to do?

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Whether you as a producer - and this also includes large online retailers - are obliged to submit a declaration of completeness to the Central Agency Packaging Register (ZSVR) depends on the quantities of packaging you put into circulation that is subject to system participation. You are obliged to submit an unsolicited declaration if you exceed one of the following de minimis limits within a calendar year:


  • 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 in each case, i.e. for the calendar year 2022 by 15.05.2023. Furthermore, the declaration of completeness must be certified by an auditor registered with the ZSVR.


If, on the other hand, the quantities of packaging subject to system participation that you place on the market are below the above-mentioned de minimis limits, you are not obliged to make an unsolicited submission. However, the ZSVR is authorised to order the surrender irrespective of the aforementioned limits.


Please note: The surrender of the declaration of completeness  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. that which typically accumulates as waste at the private end consumer.

Your declaration of completeness checklist:

  • 80 t glass,
  • 50 t PPK,
  • 30 t Light Weight Packaging

15 May of the following year

At the Central Agency Packaging Register (LUCID)

Only experts, auditors, tax advisors or certified accountants registered with the Central Agency. An overview of these registered auditors can be found here.