Foundation & Authority

Audit guidelines

Section 26 (1) no. 28 of the VerpackG (Packaging Act) gives the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) the authority to develop audit guidelines for registered auditors and experts to follow. The audit guidelines require approval from the German Federal Cartel Office.

The Verpackungsgesetz (Packaging Act) calls for audits and/or confirmations by auditors and experts at various junctures. To ensure that audits and confirmations are conducted in a uniform manner and to achieve a uniform standard between different auditor and expert groups, the ZSVR developed audit guidelines for these activities. The audit guidelines have been approved by the German Federal Cartel Office.

System volume flow record audit guidelines

The system volume flow record audit guidelines have been updated. They must be followed by registered experts when auditing systems' compliance with their record-keeping obligations, which must be submitted in writing to the ZSVR by 1 June of the calendar year following the reference year. The key updates to the content are:

  • incorporation of the facility audit report to assess facility suitability (6.5.3);
  • quota for other composite packaging (10.12.6 paragraph 3);
  • volume transfers between systems (14);
  • sample questionnaire to prepare a facility certificate (appendix 4).

The audit guidelines for the system volume flow record in German can be found here:


Declaration of completeness audit guidelines

The declaration of completeness audit guidelines have been updated for the 2019 reference year. These are to be followed when auditing declarations of completeness that need to be filed with the ZSVR by 15 May 2020. The key updates to the content are:

  • repeal of the provisions for the 2018 reference year under the Verpackungsverordnung (Packaging Ordinance);
  • description of the threshold for 'reasonable assurance' (A 2.5/glossary);
  • data reconciliation by registration number (B.1 and B.9);
  • clarification on sector-specific solution volumes and delineation of non-binding arrangements in relation to a system participation agreement (B.2);
  • highlighting the appendixes to be attached to the audit report (C 2.2);
  • description of subsequently participating volumes (C 2.2.19/glossary).

The declaration of completeness audit guidelines can be found here:

Pursuant to section 11 (3) VerpackG, the ZSVR has published standard operating procedures on the electronic filing procedure in the form of the 'declaration of completeness technical guidelines'. These guidelines require the use of certain electronic forms and input screens as well as access to the ZSVR's database (LUCID). The requirements set forth in these guidelines must be complied with when making filings. The 'declaration of completeness technical guidelines' can be found here.


The sector-specific solution audit guidelines can be found here:


These audit guidelines represent the foundation for the audits conducted by auditors/experts registered in the LUCID Packaging Register. The ZSVR has the power to remove auditors/experts from the register of auditors for up to three years if an auditor/expert repeatedly and in gross breach of duty violates the audit guidelines (section 27 (4) VerpackG).

Under 'market share', you will find the 'audit guidelines for system auditors for reporting and confirming packaging subject to system participation pursuant to section 20 VerpackG'.