Germany: LUCID and the VerpackG packaging register
Germany requires registration in the LUCID packaging register and declaration of volumes per VerpackG material code, submitted as XML. Fees are set by dual system operators and are tied to the ZSVR minimum standard for recyclability, which has been in force longer than most equivalent assessments in Europe.
What you must do
- Register in LUCID and report volumes against the VerpackG material codes rather than your own material naming.
- Declare per material code: 02 for paper, card and cardboard (PPK), 03 for ferrous metals, 04 for aluminium, 05 for plastics, 06 for wood and 07 for composite packaging (Sonstige Verbundverpackungen).
- Carry the LUCID registration number on the declaration, alongside the volume data per material code.
- Contract with a dual system operator, which is where the fee is actually charged.
- Assess recyclability against the ZSVR minimum standard, because that assessment is what determines the fee level applied by the dual system.
What data you need
| Field | What the scheme needs |
|---|---|
| LUCID registration number | Carried on the declaration itself, not held separately as an administrative note. |
| VerpackG material code | Codes 02 to 07 per component. This is a separate classification from the PPWR PP01 to PP12 codes and does not replace them. |
| Component weight | Aggregated into volume per material code, which is the unit the declaration is made in. |
| Composite construction | Composite packaging is code 07 in Germany and is categorised differently in other schemes, so the construction has to be recorded rather than inferred from a dominant material. |
| ZSVR recyclability assessment | Per component, against the minimum standard. The bifa catalogue published alongside the standard provides the technical assessment framework. |
| Recycled content | Per component, as a nullable value. Relevant to fee level and to the PPWR obligations that run in parallel. |
How fees work
Fees are charged by dual system operators (Der Grune Punkt, Interseroh+ and others) rather than by the register itself. Germany has had recyclability linked fees longer than most markets.
The ZSVR minimum standard determines whether packaging counts as recyclable, and the dual systems use that assessment to set the fee level. Non-recyclable composites and multi-material flexible packaging attract the highest fees. Mono-material packaging compatible with existing sorting and recycling infrastructure attracts the lowest.
A design change that improves the ZSVR assessment reduces German fees specifically. It does not automatically reduce fees elsewhere, because other schemes assess recyclability by their own methodology.
What Merchant produces
- LUCID XML using the VerpackG material codes, with the registration number and volume data per code.
- Excel export of the same data set for internal review before submission.
Common mistakes
- Mapping composite packaging by its dominant material. A plastic coated paperboard tray is code 07 in Germany, and calling it card because card is the heaviest layer produces wrong volumes in the wrong category.
- Treating VerpackG codes and PPWR PP01 to PP12 codes as the same classification. A component needs both, and mapping one to the other by hand is where the errors get in.
- Assuming LUCID registration is the whole obligation. The register and the dual system contract are separate, and the fee is charged by the latter.
- Optimising a component for one market and assuming the gain travels. A move to a mono-material PE pouch may improve the ZSVR assessment while changing nothing about the French position on the same component.
- Maintaining the German material mapping in a spreadsheet parallel to every other scheme. One wrong mapping means wrong declared volumes, and wrong volumes mean either overpaying or underdeclaring.
How Merchant helps
- Generate the LUCID XML from a single component data set
- Assess components against the ZSVR minimum standard
- Model what a ZSVR assessment change saves in German fees
Questions
XML, using the VerpackG material codes, carrying the LUCID registration number and the volume per material code.
02 is paper, card and cardboard. 03 is ferrous metals. 04 is aluminium. 05 is plastics. 06 is wood. 07 is composite packaging, Sonstige Verbundverpackungen.
No. They are parallel classification systems with different granularity, and a component carries both. The PPWR code identifies the material for EU purposes, the VerpackG code determines what you declare and pay in Germany.
The ZSVR minimum standard assessment of whether the packaging is recyclable, applied by the dual system operator you contract with. Non-recyclable composites and multi-material flexibles sit at the top of the range, mono-materials compatible with existing infrastructure at the bottom.
Not automatically. France assesses through COTREP and CEREC, the UK through RAM and the OPRL RAT, the Netherlands through KIDV. The same component can move up in one assessment and stay where it is in another.
Related reading
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Book a demoLast reviewed 2026-08-17