System volume flow record audit guidelines

Section 54 (1) no. 39 VerpackDG (Packaging Law Implementation 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 Verpackungsrecht-Durchführungsgesetz (Packaging Law Implementation Act – VerpackDG) 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. 

Please note: new legal situation

In agreement with the German Federal Cartel Office, the provisions of the system volume flow record audit guidelines will remain in force until 31 December 2026. A new version, applicable from the 2027 reference year onwards, is currently being developed.

Evolution of the volume flow record audit guidelines

Registered auditors listed in division 1 of the register of auditors are required to adhere to the 'system volume flow record' audit guidelines when auditing systems' compliance with record-keeping obligations. The audit must be submitted to the ZSVR in writing by no later than 1 June of the calendar year following the reference year.

After two consultation procedures, which took place in October 2021 and March 2023, the German Federal Cartel Office approved the updated 'system volume flow record' audit guidelines on 6 February 2025. The revised audit guidelines were published on 11 February 2025 and will apply from the 2025 reference year onwards. Overview of key changes:

  • Clarification of and additions to the audit assignment (A.4)

  • Review of the system participation volumes by the auditor of the volume flow record (B.7)

  • Clarification of the validity of facility certificates (B.10.10)

  • Provisions on the qualifying or declining a confirmation pursuant to section 17 (2) (C.16.4)

  • Appointment of an additional auditor if there are indications of incorrectness/incompleteness (C.18.7)

  • Definition of reasonable assurance (Appendix 1, glossary)

System volume flow record audit guidelines for auditing systems from 2025 reference year

Compliance with record-keeping duties in relation to volume flow records pursuant to section 17 (2) VerpackG (last updated: 11 February 2025)

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