In accordance with its sovereign duties, the Central Agency Packaging Register (ZSVR) is obliged to inform state authorities about potential administrative offences.
To fulfil this obligation, the ZSVR is currently carrying out further mailing campaigns. This time, registered manufacturers are affected who, by submitting a year-end report in LUCID, state that they have a system participation, but no identical counter-report is available from the respective system for the period in question. As a result, the ZSVR now has a “suspicion of failure to participate in the system, section 36 (1) no. 3 VerpackG”. An administrative offence for which the Packaging Act provides for fines of up to 200,000 Euro.
The years 2019 to 2022 are affected and around 10,000 such suspected administrative offences (in German “Ordnungswidrigkeitsverdachtsfälle, or “OWi-Verdachtsfälle” for short), from Germany and abroad are pending.
If the response to the mailing campaign confirms the potential suspected case of failure to participate in the system, the offence will be reported to the relevant enforcement authority.