German volume reports: the mirror rule and the small-producer route

Every report is filed twice

A volume report made to a dual system must be repeated in the packaging register without delay and identically: same volumes, same material types, same period. Quantities are reported in kilograms to three decimal places, and no confirmation is issued for the register report.

The two sides are compared. The central agency cross-checks the control reports it receives from the systems against the register and forwards discrepancies to the competent state authority. An inconsistent mirror is the one recurring failure that reliably finds a producer, because it is detected automatically rather than by inspection.

Visual explainer

The four report types

The initial planned-volume report covers the volumes you expect to place on the market, and for the current year it can be filed only until 31 December. In-year reports adjust it. The closing annual report for the previous year is due by 1 June. Supplementary reports correct what the closing report missed.

A licence runs on the calendar year against planned volumes, so the closing report is a reconciliation rather than a formality. Plan the data cut-off for it well before the deadline; assembling a year of shipment data in late May is how corrections get made.

The small-producer route

A producer that placed less than 10 tonnes of system-relevant packaging on the market in the previous year may replace the mirroring with a single closing annual report by 1 June. Most cross-border e-commerce sellers qualify comfortably.

It is a route, not a status. It is tested against the previous year's actual quantity each year, and the statutory anchor should be confirmed in section 9 for the dossier rather than assumed from a summary. If volumes grow past the threshold, the mirroring resumes.