Declaration of Completeness (LUCID, VerpackG)

Preparation and submission – the Declaration of Completeness according to the Packaging Act.

Do you deliver your goods to the German market?

If it is Yes, then you have to follow the German regulations and law. These might include product safety regulations, labeling requirements, and environmental standards like the VerpackG (Germany Packaging Act) for packaging materials.

What is LUCID?

Germany LUCID could refer to a specific environmental policy, addressing environmental concerns related to Zentrale Stelle Verpackungsregister” (Central Agency Packaging Register).


How to LUCID Registration?

 Companies subject to the VerpackG must register with this Zentrale Stelle Verpackungsregister system (central agency). This involves providing information about the types and quantities of packaging placed on the market.

What obligations do you need fulfil?

Any company who is selling goods in Germany and it would be subject to the Packaging Act must fulfill their obligations, including registration and reporting, through the Zentrale Stelle Verpackungsregister to ensure compliance with the law.

Who is required to draw up the Declaration of completeness?

Declaration of Completeness (Vollständigkeitserklärung) is required to be drawn up by producers, distributors, and retailers of packaged goods who are obligated under the VerpackG law. It applies to units whose actual quantity of packaging placed on the German market in the previous calendar year exceeds at least one of the specified thresholds:

  1. 80,000 kilograms of glass.
  2. 50,000 kilograms of paper and cardboard.
  3. 30,000 kilograms of other materials (such as plastics, composite materials, and metal).

The “unit” responsible for fulfilling the packaging obligations is the entity that is legally accountable for products or goods when they enter the German market. This responsibility typically falls on producers, distributors, or retailers placing packaged goods on the market, and these entities must comply with the VerpackG requirements.

If the actual quantity of packaging materials placed on the German market by a unit exceeds any of the specified thresholds, that unit is required to draw up and submit the Declaration of Completeness. This declaration confirms the accuracy and completeness of the data related to the quantities and types of packaging materials placed on the market in the previous year.

Who can submit Declaration of Completeness?

Under the German Packaging Act (Verpackungsgesetz or VerpackG), there are additional requirements beyond mere registration in LUCID for entities involved in placing packaging materials on the market. These requirements include:

1. Agreement with a System for Declaring Packaging Data

 Entities subject to VerpackG obligations are required not only to register in LUCID but also to sign an agreement with a selected organization responsible for managing the declaration of the quantity of packaging placed on the market and company data. This agreement involves the selection of a packaging compliance scheme or system, commonly known as a dual system (Duales System), which manages the recycling and recovery of packaging waste. The entity must declare its packaging data to this selected system.

LUCID Packaging Register

2. Verification by an Auditor and Preparation of a Verification Report

 Entities are obliged to verify the information contained in the Declaration of Completeness through an independent auditor. After the verification, an appropriate report detailing the findings of the audit must be prepared by the auditor. This verification report needs to be attached to the Declaration of Completeness submitted to the authorities.

These additional requirements aim to ensure the accuracy, completeness, and reliability of the information provided by the entities regarding the quantities and types of packaging materials they place on the German market. The involvement of an independent auditor helps validate the reported data, providing assurance regarding compliance with the VerpackG regulations.

Completeness of Declaration

Where should the Declaration be submitted?

Submitting the Declaration and the auditor’s verification report via the LUCID platform is an essential step to fulfill the legal obligations related to packaging waste management and compliance with the VerpackG regulations in Germany. It allows for the documentation and verification of the data provided by the entities, ensuring transparency and accountability in managing packaging waste.

What will happen if you fail to meet these obligations?

Depending on the severity and recurrence of the infringement, fines can be imposed. The fines for non-compliance with the VerpackG can be substantial, with penalties reaching up to EUR 200,000. The actual amount of the fine depends on the specific circumstances of the violation and can vary.