Moving three times is as bad as burning down once, as the saying goes. Now, I have moved more than three times and never burned down. So in March 2021 I bravely dared to do it an eighth time, but only from house number 17a to house number 8. Nothing else changed: still the same street, the same city, the same country, the same planet. No big deal, I thought.
No way: By this I triggered an administrative act!
And I don’t mean re-registering with the residents‘ registration office. Such mundane things are done in no time at all. No, I’m talking about the
LUCID register database of the Central Packaging Register.
What kind of thing, you ask? A good and legitimate question. Unfortunately, I have to go into a bit of detail to answer it:
I sold my first books using the self-publishing process, including through the shop on my website. I commissioned a printing company to do the printing and as I wanted to prevent the freshly printed books from gathering dust or yellowing while they were waiting for their new owners, I had them shrink-wrapped in plastic. When someone ordered a copy, I put the book into a cardboard box, stuck address and postage on it and took it to the post office. In this way, I put around 250 grams of plastic and a kilo of cardboard into circulation every year.
This meant that I was considered a „manufacturer of packaging“ under the Packaging Act (VerpackG) and as such was obliged to register in Lucifer’s database… sorry, the LUCID register database.
In theory, of course, I could have gotten around this by a) leaving out the plastic and b) personally delivering each ordered copy – without the cardboard – to the customers. In practice, however, that would have been a bit cumbersome and because the fun cost me less than ten euros a year, I smiled wearily at the German bureaucracy and went on with my day.
However, I had no idea that I would actually have fun for my money when I informed LUCY – or whatever it’s called – of my new address on March 26, 2021. After that, the following meaningful email fluttered into my inbox at 9:57 a.m. local time:
Notice of the change of registration data according to Section 9 Paragraph 2 Numbers 1 and 3 of the Packaging Act
Oops, a decision! And printed in bold! Not just a simple message: „Ok, we got it. Thanks and goodbye.“ No, a decision!
Dear Ms. Schirmer,
thank you for your change of registration data, which you submitted to the Central Packaging Register on March 26, 2021 via the LUCID register database. Your notification of the change has been processed.
Very good, that calms me down immensely and by the way: you’re welcome.
The decision contained in the attachment has been issued.
Holy moly, there is a separate attachment and something is being issued in it! What the hell…? I admit, I got a little nervous at that point.
Please do not reply to the sender address of this email, we only use it for automated delivery. You can find contact information on our website.
Kind regards,
Foundation Central Office PACKAGING REGISTER (etc. blabla)
Okay, up to this point everything seemed harmless. Nevertheless, I hesitated for a moment before opening the attachment, which read as follows:
Decision of the change of registration data in accordance with Section 9 Paragraph 2 Numbers 1 and 3 of the Packaging Act
Well, we’ve already had that.
The registration of Petra Schirmer as a manufacturer of packaging subject to system participation under registration number XY is changed with regard to the information listed in the appendix. With effect from March 26, 2021, Petra Schirmer is registered with these changed registration data under registration number XY.
Phew, that sounds like: „In the name of the people, the following judgment is issued,“ as if I had just gotten away with it.
Reasons:
Excuse me, several? Guys, I just moved!
(At the time of the crime – no, sorry, just joking) On March 26, 2021, Petra Schirmer notified the Central Packaging Register Foundation (Central Office) of a change in its registration data with regard to the manufacturer data listed in the appendix, Section 9 Paragraph 1 Sentence 2, Paragraph 2 Numbers 1 and 3 of the Act on the Placing on the Market, Return and High-Quality Recycling of Packaging (Packaging Act – VerpackG). In its application, the manufacturer made a declaration that the information listed in the appendix is true, Section 9 Paragraph 2 Number 6 Packaging Act.
Yes! I hereby solemnly swear on all the holy books in the world that I have moved from house number 17a to house number 8. That is the truth, the pure truth and nothing but the truth. Here I stand … no, I sit … and I can’t do anything else. May all the Gods who come into question help me. Amen.
The central office is responsible for deciding on the registration application, Section 26 Paragraph 1 Sentence 1, Sentence 2 Number 1 Packaging Act.
That comforts me again. Then I obviously did something right.
The central office registers Petra Schirmer as a manufacturer of packaging subject to system participation with the changed registration data as requested, Section 9 Paragraph 1 Sentence 2, Paragraph 3 Sentence 1 Packaging Act.
The registration data is kept in a modified form in accordance with Section 9 Paragraph 3 Sentence 1 Packaging Act and published on the Internet as far as the company name, address and/or email address are concerned.
No costs will be charged for this decision.
No costs, thank God! So I do not have to sell off my grandmother’s silverware or pawn my canary.
Legal remedy instructions
Ah, now it’s getting interesting!
An objection to this decision can be lodged with the Central Packaging Register Foundation within one month of notification… [etc…. blabla]… The deadline is also met by filing an objection with the appeals authority (Federal Environment Agency, Dessau-Roßlau).
I confess: At this point I was seriously tempted to object… about something… just for fun.
General information: Your company…
… essentially consisting of a desk, a computer, a bookshelf and a reading lamp…
… is published on the Central Agency’s website as a registered manufacturer of packaging subject to system participation in accordance with Section 9 Paragraph 4 Sentence 1 of the Packaging Act, with the company name, address and contact details as per the appendix to this decision, the brand name, the registration number assigned with this decision and the registration date. The market exit date, related to the brand name or your company, if you have specified it, is also published.
Strange, I suddenly felt an urgent need to exit the market and retreat to the Fiji Islands under a coconut tree.
According to Section 9 Paragraph 1 Sentence 2 of the Packaging Act, your company is obliged to immediately inform the Central Authority of any changes to the registration data listed in the appendix to this notice and of the permanent cessation of manufacturing activities.
„Immediately“ means: without culpable delay. I learned that in vocational school a good forty years ago. This means in consequence: If my computer crashes in the middle of communicating the cessation notice, that is force majeure, therefore not culpable delay and I am off the hook.
Changes to your registration data regarding contact details (email address, telephone number, fax number, if provided), the person responsible (title, academic title, if provided, first name, last name) and the national identification number of the manufacturer (HR/trade license, issuing authority, date of issue, HR number/trade license ref., if provided) will be confirmed to you after successful entry via the user interface in the LUCID packaging register. You will not receive any separate notification about this.
Oh, what a pity, I was really keen on reading more of this highly interesting stuff.
Changes to the company name, address (street and house number, postcode, town, country) or European or national tax number (VAT ID, tax number) will be confirmed to you by a change notice after successful entry in the LUCID packaging register.
Changes to brand names will be confirmed to you by a separate change notice after successful entry in the LUCID packaging register.
Why do you keep repeating yourself?
If your company is not registered or not registered properly as a manufacturer of packaging subject to system participation, it and other distributors are not permitted to place the packaging subject to system participation sold by your company on the market. Incorrect, incomplete or untimely registration/notification of changes to the registration information also constitutes a fine.
Of course! It is amazing what mundane things can constitute a fine in Germany, e.g. moving from one house number to another and not reporting it correctly, completely or in time. What else do we have that is nice?
This administrative act was created using a data processing system and is valid without a signature.
Note: Job and function titles are always used in the masculine form for reasons of better readability. However, the designations include personal and function titles of any gender equally.
„Any gender“! This is most important nowadays. So all 78 genders – or however many there may be currently – can feel addressed by this babble. Thank you for that. Let’s be honest: your stuff is not even remotely easy to read and the masculine form does not make it any better.
You can find more information on the rights and obligations under the Packaging Act at https://www.verpackungsregister.org/.
No, thank you, I am done. I do not want any more information. I am completely satisfied.
Conclusion: If I want or have to move again, it would be best to only move from one floor to another so as not to put too much strain on the German administrative apparatus… or I’ll just emigrate.