Declaration of Completeness (VerpackG): Who is obliged to report it?

This article answers the following questions:

• What is the Declaration of Completeness (VerpackG, LUCID)?
• Who is required to report the quantities of packaging placed on the German market?

The Declaration of Completeness (German: Vollständigkeitserklärung) is an annual report required from selected businesses registered in the LUCID system—the German Packaging Register. This document, submitted to confirm compliance with German environmental protection and recycling regulations, must include detailed information on the quantity and type of packaging placed on the market. It is essential not to overlook this obligation, as failure to comply may result in fines of up to €200,000.

The legal basis for the Declaration of Completeness is the German Packaging Act (Verpackungsgesetz – VerpackG), which imposes obligations on “producers” of packaging, as well as entities that first place packaging on the market—including importers and cross-border sellers. These obligations include registration, participation in a dual system (for certain types of packaging), and the reporting of data in the LUCID register (Zentrale Stelle Verpackungsregister – ZSVR).

As of 1 July 2022, the obligation to register in the LUCID system applies to all types of packaging—including those used in B2B transactions, exclusively for transport, or designed for multiple use. However, participation in the dual system and ongoing quantity reporting only apply to packaging subject to system requirements—that is, to waste generated by the average consumer (private end user) or in comparable settings.

What must be declared in the German Declaration of Completeness?

The Declaration of Completeness is an official electronic document submitted to the ZSVR (Stiftung Zentrale Stelle Verpackungsregister – Central Packaging Register), in which a company must provide detailed information on:

• the types and weights of all packaging placed on the German market during the reporting year,
• the breakdown of packaging by material used in its production (e.g. glass, paper, plastics, aluminium, etc.),
• details of which packaging is covered by a contract with a dual system (i.e. the system responsible for financing recycling),
• a summary of any packaging returned through industry-specific solutions or other collection systems.

The primary purpose of the Declaration is to verify whether a business has accurately reported the quantities of packaging. In addition, it enables German authorities to check whether all packaging subject to system requirements has indeed been reported and paid for within the dual system. Another key function of this document is to help eliminate so-called “free riders”—companies that avoid paying recycling fees.

The obligation to prepare and submit the Declaration of Completeness applies to entities whose actual volume of packaging placed on the German market in the previous calendar year exceeds at least one of the following thresholds:

• glass – 80,000 kg,
• paper and cardboard – 50,000 kg,
• other materials (plastics, composites, metals) – 30,000 kg.

The Declaration, prepared by the entity placing packaging on the German market, must be independently audited and submitted no later than 15 May (for the previous calendar year). The verification must be approved by an authorised auditor who has been granted rights by the aforementioned ZSVR.

Types of information reported to the Central Packaging Register

The first element submitted to the ZSVR consists of current data required by the LUCID system. Each entity participating in the system for packaging subject to system requirements must submit to LUCID exactly the same quantity reports as those provided to their dual system. It is important to ensure that the data remains consistent (no discrepancies may occur between the information reported in LUCID and that submitted to the dual system), and that the reports are filed according to the same reporting periods—monthly, quarterly, or annually.

The second element required under German regulations is the Declaration of Completeness—a summarised, annual declaration subject to audit, which must be submitted by 15 May for the preceding calendar year. Entities are only obliged to submit this document if they exceed the statutory volume thresholds or if it is specifically requested by the ZSVR.

The key distinction is that current data reporting applies to every entity subject to system requirements, whereas the Declaration of Completeness concerns only “large” organisations—those placing packaging on the German market in volumes exceeding the specified thresholds, or those required to submit it upon special request from the authority.

Who must report packaging volumes to LUCID?

Any entity that places packaging subject to system requirements on the German market for the first time—such as sales packaging, shipping packaging, or certain service packaging—must, after entering into a contract with a dual system, report the same quantities to LUCID. 

If the contract with the dual system does not specify clear reporting intervals, the entity is required to report at least the planned annual volume of packaging to LUCID.

Which packaging is subject to system requirements?

Packaging subject to system requirements includes sales packaging, shipping packaging, and certain types of service packaging that become waste at the premises of a private end user (the average consumer) or in comparable waste-generating locations, such as hotels or food service establishments. Such packaging must be covered by a contract with a dual system and is subject to ongoing reporting obligations.

The producer or first distributor responsible for reporting is the entity that initially places packaging together with goods on the German market. This may include a manufacturer, importer, marketplace seller, or a foreign vendor without a registered office in Germany—often operating through an authorised representative.

The audit report accompanying the Declaration of Completeness remains a key obligation—one that many companies tend to overlook

Regulations governing packaging reporting across EU member states are not harmonised. As a result, many entities fail to realise that—when operating in Germany—registration in the LUCID system and preparation of the Declaration of Completeness are not sufficient. The document must also be submitted together with an audit verification report. This additional step, which is not required in many other countries, makes compliance more complex and time-consuming, particularly for foreign companies active on the German market.

RSM Poland, as an audit firm with a dynamic Risk Advisory team, offers efficient and professional support to meet the needs of internationally operating companies. We assist in fulfilling all current and outstanding compliance obligations. We warmly invite you to make use of our services!