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Market share calculation and audit guidelines for system auditors for reporting and confirming packaging subject to system participation pursuant to section 20 VerpackG (Packaging Act)

The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR), in agreement with the German Federal Cartel Office, develops and publishes a procedure for calculating individual systems' market share of the total volume of packaging that participates in all of the systems (section 26 (1) no. 12 VerpackG), as well as the market share of individual systems and sector-specific solutions of the total volumes that participate in all of the systems and sector-specific solutions (section 26 (1) no. 13 VerpackG) – the so-called 'market share calculation concept'. This concept is the basis for the ZSVR's market share calculation pursuant to section 26 (1) nos. 14, 15 and 16 VerpackG.

In addition, the ZSVR, in agreement with the German Federal Cartel Office, has the authority to develop audit guidelines to be followed by system auditors when conducting audits under the Verpackungsgesetz (Packaging Act) (section 26 (1) no. 28 VerpackG).

To implement the Verpackungsgesetz since 1 January 2019, the ZSVR developed the market share calculation concept and audit guidelines for system auditors in collaboration with affected stakeholders in 2018. The German Federal Cartel Office approved the current version of the market share calculation concept and the current version of the system auditor audit guidelines (available in German only).

The German Federal Cartel Office created a case report for issuing approval for the market share calculation concept and the audit guidelines for system auditors that provides additional explanations.

Up to and including the report for the 2021 calendar year, supplementary volumes always had to be reported with the next data report under section 20 VerpackG (Packaging Act), i.e. with the next interim or annual report. Starting with the 2022 calendar year, the supplementary volume report needs to be submitted only once a year, as a part of the annual report. The market share calculation concept and the audit guidelines were amended accordingly as of 9 December 2021.

The market share calculation concept and system auditors' guidelines underwent a thorough overhaul in 2023, with all stakeholders participating in the process. Experiences in years past had made it necessary to adjust the auditing procedure and spell out requirements more clearly. Determining the actual market share as precisely as possible is in the best interests of all stakeholders, ensures an even playing field and supports the ecological goals behind the Verpackungsgesetz. The thorough overhaul is a major step forward in increasing the quality of system reports and streamlining the system auditing process (as well as any reviews by the ZSVR that may be necessary). The new concept will first be applied to interim reports for the second quarter of 2024 and annual reports for the 2024 reference year. Contracts with appointed third parties will be exempt in the first year. The following documents include an additional explanation for the overhaul conducted in 2023. 

2023 document versions (available in German only):

  • Market share calculation concept, 10 November 2023 version
  • Audit guidelines for system auditors for reporting and confirming packaging subject to system participation pursuant to section 20 VerpackG (10 November 2023 version) 
  • Information about the new market share calculation concept and the system auditors' guidelines (November 2023 version)


2021 document versions (available in German only):

  • Market share calculation concept, 9 December 2021 version
  • Audit guidelines for system auditors for reporting and confirming packaging subject to system participation pursuant to section 20 VerpackG (9 Dezember 2021 version)
  • The Federal Cartel Office’s case report  on the issuance of approval of the ZSVR's market share calculation concept (first edition) and the audit guidelines for system auditors – packaging recovery through dual systems