How to fulfil your obligations as a seller or producer in
GERMANY
Packaging
To comply with your packaging obligations, seller/producers have 3 duties:
- Join a dual scheme:
The person who puts the sales packaging filled with goods into circulation for the first time – the so-called „initial filler“ or „initial distributor“ (as it is called in the Packaging Act „manufacturer/distributor“) – is obliged to participate.In Germany, the dual systems organise the collection, sorting and recovery of used sales packaging.
Together with their contracted disposal companies, they have set up a takeback system that is used by citizens throughout Germany.
The financing of the takeback system is assumed by those manufacturers and distributors who put packaged goods into circulation and who must therefore participate in a system as a distributor for the disposal of used sales packaging.
- LUCID registration:
Producers/distributors are obliged to register with the Central Agency Packaging Register (ZSVR) before placing packaging on the market.
Without this registration, products in packaging requiring system participation may not be offered for sale.
After registration, the ZSVR will give you a registration number (LUCID number), which you must then quote in order to conclude a contract with a dual system such as Landbell.
- Reporting:
You are legally obliged to submit an initial planned quantity report for each contract year (quantity estimate for the following year) and, after the end of the contract year, a year-end quantity report (actual quantity report) on the packaging you put into circulation that is subject to system participation.
The quantities must be entered twice – both in your dual system, e.g. here in your MyEASy shop area, and in LUCID.
- Join a dual scheme and licence your packaging with the Landbell EASyShop!
2. Register with LUCID!
At a glance – the LUCID registration process
Before starting the registration, please ensure you have the following data available:
2. You will receive an activation link from LUCID: Please do not forget to activate the link within 24 hours.
3. Complete the 4 fields in your LUCID account: „Master data“, „Packaging details“, „Brand names“ and „Summary“
Before you submit your registration, you must confirm that you are fulfilling your takeback obligation through participation with Landbell.
4. LUCID will instantly send you a confirmation of your registration.
You will receive your LUCID number (= EPR number) directly – commencing with DE + 13 digits.
5. Go to EASyShop and buy your packaging compliance contract for the required period.
This is the 2nd legal obligation of the VerpackG!
You must join a Producer Responsibility Organisation(PRO) – Landbell in this case. Please note that your EASyShop contract will only become valid after receipt of payment (electronic payment normally clears overnight).
Both steps need to be completed!
If you only register at LUCID or only at Landbell, your compliance is not completed.
It is absolutely necessary that you submit your identical quantities in both the LUCID reporting portal of the Central Packaging Register (ZSVR) and in the Landbell EASyShop. A simple declaration in only one portal is not sufficient. The ZSVR will check this!
Please refer to the LUCID website for legal, financial and administrational consequences in case of provision of no or wrong data and see here what happens if you do not register.
- Reporting:
Reporting in LUCID
Please log on to your LUCID account, choose “Data report”.
If you conclude the system participation contract and the registration right now for the current year, select “intra-year volume report”, then select reporting period and “Landbell” as your system operator.
Finally, enter your annual planned quantities with the respective material types.
Reporting in EASyShop
After contract validation, please log in to your EASyShop account and submit your planned volumes report.
It is absolutely necessary that you submit your identical quantities in both the LUCID reporting portal of the Central Packaging Register (ZSVR) and in the Landbell EASyShop. A simple declaration in only one portal is not sufficient. The ZSVR will check this!
In case quantities need to be adjusted – also for your quantity report – these changes must be done in both your LUCID („Data report“) and EASyShop account.
WEEE
To comply with your WEEE obligations, sellers/producers have 5 duties:
- Registration: Your electrical devices must be registered at the public register EAR (per category and per brand.) Please be aware that foreign companies can only register via an appointed authorized representative (see point 2).
- Appoint an Authorized Representative (AR) in Germany: for electrical and electronic equipment manufacturers/dealers without a subsidiary in Germany.
- Join a Producer Responsibility Organisation (PRO): Landbell, in this case, to ensure collection and recycling of electrical and electronic equipment.
- Report to the Registry: you report to Landbell Group and we will provide this to the registry.
- Fulfilment of other obligations: for example, takeback (1:1 and others) is provided as (paid) services by Landbell Group as well.
Licence your WEEE in just a few clicks with Click & Comply!
Batteries
To comply with your battery obligations, sellers/producers have 3 duties:
- Registration: The registration of your batteries must show up in this register (stiftung elektro-altgeräte register). Your batteries must be registered with the EAR (per category and per brand). This is a service we can do for you.
- Join the battery takeback scheme of Landbell Group: membership must be approved by Landbell during the registration process.
- Report: the quantities of batteries placed on the German market. In case you join Landbell Group’s scheme, please report to them and submit to the authority.
Licence your Batteries in just a few clicks with Click & Comply!
Definitions
Packaging
Sales packaging (product packaging) is packaging used to protect goods and products and ensure their safe handover to the consumer. Sales packaging is considered as a sales unit, consisting of goods and packaging offered to the end user.
Shipping packaging for online sales is used to deliver goods to the end users (e.g. the shipping cartons, filling materials like bubble foil, etc.). Shipping packaging is always subject to registration and membership of a PRO. For shipping packaging, there are always direct obligations for marketplace sellers/online sellers selling to Germany.
Very rarely, sales packaging (product packaging) may already be registered and covered by membership of a scheme, if the manufacturer fulfilled the obligations in Germany. In this case, proof of registration and scheme membership is required. If there is no proof, the obligations remain with the marketplace seller/online seller.
Please remember: In Germany, you must fulfil the obligations for all packaging put on the German market. Therefore, the obligations are valid for all sales channels!
WEEE
Devices which are exposed to an alternating voltage of maximally 1,000 V or a direct current voltage of maximally 1,500 V during operations and:
- which are dependent on electric currents or electromagnetic fields for proper operation, or
- which serve for the generation, conduction and measurement of electric currents and electromagnetic fields.
If you offer an EEE product containing a battery, you must register for both EEE and Batteries
Batteries
The battery law differentiates between three battery types:
- “portable batteries” are batteries which are sealed and can be hand-carried. Industrial and automotive batteries are not portable batteries.
- “industrial batteries” are all batteries for exclusively industrial, commercial or agricultural purposes.
- “automotive battery” means any battery used for automotive starter, lighting or ignition power.
The manufacturer of all battery types has to register these batteries with the correct brand and battery type at the authority (Stiftung ear) before placing them on the market. Landbell Group can do this for you.
Manufacturers of portable batteries are obliged to take back the waste portable batteries, at no charge and nationwide, which are collected at distributors or local collection points.
In order to fulfil this takeback obligation, the producer has to participate in a takeback scheme approved by §7 of the battery law. The takeback scheme carries out the takeback and recycling of the waste batteries and reaches the legally demanded collection rate of at least 50% from reporting year 2021 onwards.
Manufacturers of industrial batteries and automotive batteries are obliged to take back waste batteries. They have to offer a reasonably convenient takeback solution at no cost and recycle these batteries according to §14.
