By Razvan Toma · Founder · Last checked 4 October 2026 · Sources linked below
Quick answer
No LUCID data report, but other duties apply. ZSVR says the obligation to submit data reports applies “exclusively to packaging that is subject to system participation”. Packaging outside system participation, typically transport or sales packaging that ends up with business end users, falls under § 39 VerpackDG instead: free take-back, recovery and annual documentation. Note that shipping packaging sent to consumers is always subject to system participation. Sources (2)
ZSVR helpZSVR help — Data reporting in LUCID
VerpackDG § 39VerpackDG § 39
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