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Declaration of completeness 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.

Declaration of completeness audit guidelines

Further information about the treatment of the new definition of composite in the Verpackungsgesetz (Packaging Act) introduced by the Act on the Implementation of the Waste Framework Directive of the European Union can be found here.

The declaration of completeness audit guidelines have been updated for the 2020 reference year. These are to be followed when auditing declarations of completeness that need to be filed with the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) by 15 May 2021. The key updates to the content are:

  • The producer declaration (A.4.2.8 and appendix 2) was adjusted to reflect the LUCID Packaging Register.
  • The approach for determining packaging weights was specified (B.5: Audit area 5).
  • Specifications were made regarding export packaging, retrospective deductions and retail returns (B.9: Audit area 9).
  • The electronic filing of volume confirmations issued by the systems was included (C.3.1.4).

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.