Foundation & Authority

Declaration of completeness audit guidelines

Section 26 (1) no. 28 VerpackG (Packaging Act) authorises the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) to develop audit guidelines that auditors and experts must adhere to. The audit guidelines require approval from the German Federal Cartel Office.

The Verpackungsgesetz (Packaging Act) calls for audits and/or confirmations by auditors or experts at various junctures. To ensure that the audits and confirmations are consistent across auditor and expert groups, in terms of both audit process and audit level, the ZSVR has developed guidelines that have been approved by the German Federal Cartel Office.

Evolution of the declaration of completeness audit guidelines

The current declaration of completeness audit guidelines have been in place since the 2021 reference year. These guidelines are to be followed when auditing declarations of completeness that need to be filed with the ZSVR by 15 May of the year following the reference year. The key updates to the content are:

  • Reference to the removal of an auditor from the register of auditors in the event of a repeated breach in gross dereliction of duty under 1.7 of the introduction to the audit guidelines
  • A.2.1: clarification on compliance with statutory provisions and audit guidelines in the reference year, also in the event of intra-year amendments
  • Definition of composite packaging
  • Right to authorise a representative
  • New audit areas B.11-B.14 and related rules: audit of DoCs that were ordered or filed too late, or in cases where the ZSVR had found a previous declaration of completeness to be incorrect or incomplete and/or where administrative offence proceedings pursuant to section 36 (1) no. 11 or no. 3 VerpackG were initiated
  • Audit area B.1: information about packaging and pre-participated service packaging
  • Audit area B.2 and B.8: addition of late payment cases
  • Audit area B.5: review of shipment packaging
  • Audit area B.7: request for test runs to be repeated
  • Audit area B.9: clarification on unplanned exports and voluntary participation in the deposit system
  • Audit area B.10: correction of returns
  • C.2.1: audit report in German
  • C.2.2: addition of the volume of pre-participated service packaging, audit activities statement and sample determination to the audit report requirements
  • Glossary: update, inclusion of the definition of the term 'authorised representative'

The declaration of completeness audit guidelines can be found here:

Pursuant to section 11 (3) VerpackG, the ZSVR has published standard operating procedures concerning 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 LUCID Packaging Register. The requirements set out in these guidelines must be complied with when making filings. The 'declaration of completeness technical guidelines' can be found here.