By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below
The German packaging register, and the body that cross-checks your numbers. ZSVR, the Zentrale Stelle Verpackungsregister, is a foundation under German civil law (§ 48 VerpackDG) entrusted with public tasks by § 54 and supervised by the Umweltbundesamt (§ 57). It runs LUCID, registers producers and confirms their representatives, publishes who is registered, and checks data reports and declarations of completeness against the register and the dual systems' own reports. It passes what it cannot clear up to the state authorities, which set any fine (§ 66(4)). Sources (3)
VerpackDG § 48VerpackDG § 48VerpackDG § 54VerpackDG § 54VerpackDG § 57VerpackDG § 57
What ZSVR is
The Zentrale Stelle Verpackungsregister is a foundation under German civil law. It was set up under the old Packaging Act and continues under the VerpackDG (§ 48(1)). The law entrusts it with public tasks (§ 54(1)), so for those tasks it acts as a public authority.
| Feature | Rule |
|---|---|
| Legal form: foundation under civil law | § 48(1) |
| Its statute must guarantee neutrality towards all market players and protect business secrets | § 48(2) nos. 4 and 5 |
| Legal and technical supervision by the Umweltbundesamt | § 57(1) |
| Finances audited by the Federal Court of Auditors | § 57(2) |
| If it fails its tasks, the Umweltbundesamt can take them over | § 57(3) |
| Competent authority for the producer register under Article 44 PPWR | § 54(1) no. 4 |
VerpackDG § 48 VerpackDG § 54 VerpackDG § 57
What ZSVR checks
§ 54(1) VerpackDG lists its tasks. The ones that touch a seller of packaged goods:
| Task | § 54(1) |
|---|---|
| Registers producers, confirms registrations, publishes the list of registered producers, and can revoke a registration | no. 1 |
| Can forbid, case by case, a packaging from being taken into a dual system if it would seriously harm recycling or public health (§ 7(5)) | no. 2 |
| Checks producers' data reports | no. 5 |
| Checks declarations of completeness against the register, the data reports and the systems' annual reports; issues orders and informs the state authorities of irregularities it cannot clear up | no. 7 |
| Can order a producer to file a declaration of completeness | no. 8 |
| Publishes the list of producers that filed one | no. 9 |
| Checks the dual systems' quarterly and annual reports | no. 17 |
| Issues procedural instructions for registration, data reports and declarations | no. 20 |
| Calculates and publishes each dual system's market share | nos. 21 to 24 |
How the cross-check works
Every kilogram is reported twice. You, or your representative, report the quantities licensed to ZSVR (§ 9). The dual system reports the same participations to ZSVR (§ 25). ZSVR compares the two, and for larger producers also the declaration of completeness (§ 10). A gap leads to questions, an order to correct, or a report to the state authority (§ 54(1) no. 7). The safest data report is therefore the one that matches the system's figures exactly.
VerpackDG § 9 VerpackDG § 10 VerpackDG § 54
What ZSVR does not do
- It does not fine. Fines are set by the authority of each federal state (§ 66(4)). See the fines.
- It does not sell licences. Participation is concluded with a dual system. See the dual systems.
- It does not act for you. If your company has no establishment in Germany, a representative does (§ 5(2)).
What you see of ZSVR as a seller is LUCID: your registration, your number, the confirmation of your representative and the public register. Step by step: LUCID registration.
More on LUCID and licensing
- Can a service get me a LUCID number and a packaging licence for Germany?
- Can a marketplace or a service provider register me in LUCID?
- Do I have to license the shipping box, filling and tape too?
- When do I have to report my packaging volumes in Germany?
- I already pay a dual system. Can I keep my operator, and do I pay twice?
- Why is LUCID asking me to appoint an authorised representative?