Foundation & Authority

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

The declaration of completeness (DoC) audit guidelines have been updated. The updated version applies from the reference year 2021 onwards. These guidelines are to be followed when auditing declarations of completeness that need to be filed with the ZSVR by 16 May 2022 for the reference year 2021. 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 the related rules: audit of declaration of completeness (DoCs) that were ordered or filed too late or in cases where the ZSVR had found a previous DoC to be incorrect or incomplete and/or where administrative offence proceedings pursuant to section 31 (1) no. 11 or no. 3 VerpackG were initiated,
  • audit area B.1: information about packaging, also about service packaging that has already participated in a system,
  • audit area B.2 and B.8: addition of cases of late payment,
  • 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,
  • audit area C.2.1: audit report in German,
  • audit area C.2.2: addition of the volume of packaging that has already participated with a system, the statement of the audit activities and the sample determination to the requirements for the audit report under C.2.2,
  • Glossary: update, inclusion of the definition of the term 'authorised representative'.

For the 2021 reference year, the changes to the content of the audit guidelines are only to be observed for audit activities that have not yet been completed at the time of publication, i.e. on 17 January 2022.

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.