Packaging Register LUCID
From July 1, 2022, the registration obligation in the packaging register LUCID will apply in Germany. It applies regardless of the type of packaging for packaging with system participation obligation and for packaging without system participation obligation. What LUCID is and whether you are also affected by the registration obligation, you can find out here.
The legal background
The Packaging Act (VerpackG) has already been force in Germany since 1993. The aim of the law is to motivate private households to recycle their waste and to use more ecologically beneficial and recyclable packaging. The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR), which was founded for thos purpose, aims to establish a transparent and fair distribution of the costs of the disposal and recycling system within the dual system.
Due to an amendment of the VerpackG, from 01 July 2022 all persons who commercially place packaging on the market are obliged to register in the packaging register LUCID and to provide information on the individual types of packaging and the respective brand names in the register.
You can find more information about the Packaging Act in our guide article.
What is the packaging register LUCID?
The ZSVR operates since 01 January 2019 as an entrusted authority and is subordinate to the Federal Environment Agency. The main task of the ZSVR is to check whether the requirements of the VerpackG are met. For this purpose, the public register LUCID was introduced.
Via LUCID, companies indicate the quantities of packaging they are placing on the market for the first time on a commercial basis in Germany and the extent to which they have participated in the dual system. The dual systems also report which company has licensed how much packaging material. In this way, the ZSVR can check whether Hersteller (the Packaging Act generally refers to the obligated initial distributors as "Hersteller") have actually licensed the packaging and whether there are quantity discrepancies between the individual data reports.
Violations of the VerpackG can be punished by the ZSVR with fines of up to 200,000 euros or a ban on distribution. Should a company discover via the public register that competitors have not registered with the ZSVR, this may result in warnings under competition law. If you become aware of a violation, contact the ZSVR directly.
Delivery service without commission
So how do I get started? This is a question that many restaurant operators who are planning a take-away business are likely to ask themselves. The least effort would be to accept orders exclusively by telephone. For many, however, a telephone call is not user-friendly enough and also no longer up-to-date due to the advancing digitalisation. The catering industry must inevitably adapt to this fact. But how do you launch your own online shop? The first mistake is already lurking here: restaurant owners turn to market leaders in the online delivery services segment. At first glance, this seems the easiest option, but you not only lose control, but also a large part of your turnover. The food does reach the customers - but a commission of up to 30 per cent is due. This is one of the reasons why the big delivery services are emerging from the crisis as winners. But there is now an alternative where your turnover goes exclusively into your pocket: foodsta®!
Who has to register?
According to the Packaging Act, the Hersteller are obliged to register, i.e. those who put packaging filled with goods into circulation for the first time. This can be producers, trading and import companies and online store operators. This applies to companies based in Germany as well as foreign companies that sell goods to Germany.
For further details on the term Hersteller, please refer to the ZSVR chart.
Also as a distributor of so-called service packaging you have to register with LUCID. However, you can transfer the duty of licensing to your supplier or wholesaler when you buy the packaging. At the ZSVR, you must then provide proof that you have already purchased licensed packaging. This is usually shown on the invoice.
Which types of packaging are subject to registration?
The Packaging Act distinguishes between packaging that is subject to system participation and packaging that is not subject to system participation.
Packaging subject to system participation is retail or grouped packaging filled with goods that typically accumulates as waste with private final consumers after use..
Packaging that is not subject to system participation includes
- Transport packaging,
- reusable packaging,
- deposit-liable disposable beverage packaging,
- sales packaging and outer packaging that does not typically accumulate as waste at private end consumers after use, and
- Sales packaging of hazardous filling goods.
Special regulation for service packaging
Service packaging is packaging that is only filled with goods at the final distributor and then handed over to the end consumer; special regulations apply to this type of packaging. Service packaging includes, for example, roll bags from bakeries, snack trays from fast food outlets, carrier bags, coffee-to-go cups etc. Packaging with which food and beverages are delivered by catering businesses or delivery services is not service packaging. They are shipping packaging, and the special regulation does not apply.
According to the special regulation, final distributors of service packaging have the possibility to buy the unfilled service packaging from delivery companies or wholesalers "pre-participated". In this case, the packaging recycling has already been paid for. As the last distributor, you must have the prepaid purchase of the unfilled service packaging confirmed on the invoice or delivery bill. You can report the pre-participated purchase to LUCID.
If service packaging is not purchased in advance, the same regulations apply to it as to sales packaging subject to system participation.
Still questions?
You can find more information about the Packaging Act, the packaging register LUCID or the registration obligation on the website of the Zentralen Stelle Verpackungsregister (Central Agency Packaging Register). Here you will also find a link to the LUCID portal and assistance with registration.
The right packaging
Transporting a pizza is not a big hurdle. However, if a customer orders a soup, suitable packaging is absolutely necessary. Individual components, such as salad dressings, sauces and toppings, should also be packaged separately. In addition to the practical and functional aspect, the EU single-use plastic ban (SUPD) should also be taken into account. This directive aims to reduce environmental damage caused by single-use plastic products. Therefore, certain products for which there are sustainable alternatives are now banned. In our shop you will find everything you need in take-away packaging - completely SUPD-compliant, of course!
Concept
Not every gastronomic concept can be easily squeezed into a delivery service scheme. A gourmet restaurant that thrives on artful and elaborate dishes of the highest quality also needs the appropriate to-go packaging to survive transport undamaged. If your business is known for unique dishes or exceptional cuisine, out-of-home sales are very worthwhile for you!
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