EPR Germany (VerpackG)
What is the LUCID forecast (HPM1) and who must file it?
TL;DR: The LUCID forecast (HPM1) is your next-year estimate of packaging mass by material for system participation. Producers/first distributors placing B2C packaging on the German market must file it with their dual system and align data in LUCID per ZSVR guidance.
How do I create the LUCID forecast (HPM1) with EPR One?
TL;DR: Enter registrations, set shipping packaging uplift or box rules, assign materials to products/variants (or use presets), run validations, then generate and download the HPM1 XML/CSV for review and submission.
What data does EPR One include in forecast vs actuals (HJM1) and intra-year (HNM1)?
TL;DR: Forecast projects next year from current-year sales; HJM1 uses fulfilled orders for the reporting year; HNM1 lets you submit corrections/updates during the year.
What counts as consumer sales packaging vs shipping packaging under VerpackG?
TL;DR: Consumer sales (product) packaging accompanies the product; shipping (transport) packaging protects during shipment. For B2C both are generally reportable with material categories like paper, corrugated, plastics, glass, and metals.
Does dropshipping or 3PL change my EPR obligation?
TL;DR: Obligation lies with the first distributor in Germany. If your supplier is first distributor you may be out of scope for those flows; otherwise you are obligated. Keep documentation; use location exclusions to omit 3PL/dropship shipments you are not responsible for.
Do returns and cancellations reduce reportable mass?
TL;DR: Packaging already placed on the market usually remains reportable; simple returns do not reverse packaging mass. Follow ZSVR rules; adjust only if guidance explicitly allows.
What are common mistakes that cause LUCID rejections?
TL;DR: Missing registration numbers, unmapped materials, wrong material codes, zero shipping packaging where applicable, and mismatches versus your dual system. Run EPR One validations and reconcile totals before export.
How do I measure packaging weights reliably?
TL;DR: Use a calibrated scale and weigh each component (box, mailer, tape, label, filler). Average multiple samples; store results as package presets for consistent reporting.
Should I use shipping % uplift or box rules?
TL;DR: Use % uplift for quick, defensible estimates based on order weight. Use box rules for higher accuracy once your packing patterns stabilize.
Do I need to include marketplace sales (Amazon/eBay/etc.)?
TL;DR: Include if you are the first distributor for those shipments. If the marketplace is the obligated party, exclude and keep proof. For now, add manual adjustments for other channels.
Who is considered first distributor under VerpackG?
TL;DR: The entity that first places filled packaging on the German market for the first time on a commercial basis; imports and private label typically qualify.
Do private-label and imports trigger EPR duties?
TL;DR: Usually yes—if you own the brand or import into Germany, you are the first distributor and must register, participate in a dual system, and report.
How do I get and verify my LUCID registration?
TL;DR: Register with the ZSVR LUCID register and obtain your registration number; keep it current and store it in EPR One settings.
What is a dual system and how do I choose one?
TL;DR: Dual systems organize collection/recycling and charge fees based on your packaging masses. Compare pricing and service; enter your contract details in EPR One.
How do I classify paper vs corrugated vs composites?
TL;DR: Paper = flexible papers; corrugated = cardboard board; composites = multilayer materials that are not separable. Follow your dual system/material code lists.
How do labels, tape, and void fill get reported?
TL;DR: Include them in shipping packaging materials; estimate via presets or uplift splits so they are consistently counted.
Are B2B shipments out of scope?
TL;DR: Pure B2B transport packaging can be out of system participation; however other obligations may apply. Confirm with your dual system and ZSVR guidance.
How to report kits/bundles and multi-component products?
TL;DR: Report the total packaging mass placed on the market per order, using product presets or variant overrides for accuracy.
What documentation should I keep for audits?
TL;DR: Keep registrations, dual-system contracts, weight evidence, mapping acceptances, exports, and audit logs. EPR One records acceptances and key actions for traceability.
How do I correct a mistake after submission (HNM1)?
TL;DR: Use under-year (HNM1) reporting to correct quantities; coordinate with your dual system and update LUCID where required.