Declaration of Completeness, LUCID (VerpackG)

What is LUCID?

We support you in complying with the obligations under the German Packaging Act (VerpackG),in registering with the LUCID system, in filing reports and declarations, and with the audit validation of the LUCID Declaration.

What is the purpose of the LUCID (VerpackG) regulation?

VerpackG is the German act on packaging and packaging waste ("Packaging Act") which entered into force on 1 January 2019, replacing the previous regulation on the subject. The act is linked to the implementation of the relevant EU directive and aims to promote the shift to more environmentally friendly packaging materials. VerpackG is an important element of sustainability efforts which are gaining momentum not only in Germany, but across the EU as well. 

Who is required to register with the LUCID system?

LUCID registration is mandatory for all entities which, acting as a first distributor in Germany, supply third parties, either for sale or for their own use, with any packaging containing goods that typically generates waste for the end-user. This means that LUCID registration is mandatory for all companies which directly or indirectly supply packaging to the German market.

How can our auditors help you with LUCID compliance?

Our experts are fully familiar with the details of LUCID regulations and procedures, and so we are able to support our partners in the following areas:

• We validate the LUCID Declaration of Completeness prepared by the company.
• If required, we can assist the company in registering with LUCID, which is the first step towards LUCID compliance.
• After registration, our experts provide assistance in completing the LUCID Declaration.
• We help file any missing documentation if a deadline is missed, in order to avoid any fines involving the LUCID system.

What specific information must be reported in the LUCID system?

According to the new act, businesses selling products or goods in Germany must register with the LUCID system and report data on planned and actual quantities of packaging. In doing so, they must prepare a so-called LUCID Declaration of Completeness (Vollständigkeitserklärung) in which they must list any packaging they have put into circulation. 

Who has to prepare a Declaration of Completeness?

The obligation to prepare and file a LUCID Declaration of Completeness applies to businesses/companies for which the quantity of packaging actually put into circulation in the German market during 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 (plastic, composite materials, metals).

The entity required to comply with the packaging-related obligations is the legal entity which is responsible for the cross-border distribution of the products or goods. It is worth knowing that the authority keeping the packaging register (Zentrale Stelle Verpackungsregister) may request a Declaration of Completeness to be filed even if the figures reported by the entity are below the above thresholds.

Are there any additional requirements?

Registering with the LUCID system is only the first step and does not mean that the obligations are fulfilled. – In addition to filing the Declaration of Completeness, a contract must be entered into with a selected organisation/company to report the quantities of packaging put into circulation in the market, as well as company data.

Additionally, the act requires companies to hire an auditor to verify the information contained in the Declaration of Completeness and to arrange for the preparation of an appropriate report which documents this verification process. This validation process is a critical element of compliance, and the report prepared by the auditor must be attached to the Declaration. At this point, we provide dedicated support to our partners to ensure that this validation fully complies with the regulations.

Where does the Declaration of Completeness have to be filed?

The Declaration and the auditor's verification report must be filed with the central packaging register (LUCID) in electronic form. It is important to ensure that LUCID filings are made in a timely manner as delays can have serious consequences.

When does the Declaration of Completeness have to be filed?

The Declaration has to be filed each year until 15 May for the previous year.

What happens if a company fails to meet its LUCID obligations?

In the event of a failure to register, to file a report in the system or to report data regarding the quantities and types of packaging, the goods cannot be sold in Germany. Depending on the severity of the infringement, a fine of up to EUR 200,000 may also be imposed.

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