The declaration of completeness is an instrument that was provided for in the Verpackungsverordnung (Packaging Ordinance) to enhance transparency regarding packaging placed onto the German market. The main goal of the provision is to make the producers of packaging subject to system participation fully and accurately accountable for their system participation requirement. The declaration of completeness must contain entries detailing the material types and masses of all the retail and grouped packaging placed onto the German market in the previous calendar year, including those that accumulate as waste in industrial or large commercial enterprise settings after use. The declaration of completeness must be audited and confirmed by a registered expert, or by a registered auditor, tax adviser or sworn accountant.

Producers are required to submit a declaration of completeness for the previous year once the packaging subject to system participation placed on the German market in the previous calendar year reaches or exceeds at least one of the following three volume thresholds, or if an administrative order for submission of a declaration of completeness is issued.

List of packaging volume thresholds that trigger a requirement to submit a declaration of completeness: 

• Glass: 80,000 kg
• Paper, paperboard, cardboard (PPC) in total: 50,000 kg
• Ferrous metals + aluminium + plastics + beverage cartons + other composites (lightweight packaging) in total: 30,000 kg
   

The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and the competent state enforcement authorities also have the power to require at any time that a declaration of completeness be provided, even if the thresholds are not reached.

The declaration of completeness must be submitted electronically, along with the audit confirmation and the related audit report provided by registered auditor, to the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) in LUCID. You can also use LUCID to find registered auditors in the ZSVR's register of auditors. Further information about filing and the qualified electronic signature, as well as the technical process for filing the declaration of completeness, can be found in the 'declaration of completeness technical guidelines'.

The declaration of completeness contains entries detailing

• the material type and mass of all the packaging subject to system participation placed onto the German market for the first time in the previous calendar year;
• the material type and mass of all retail packaging and grouped packaging filled with goods that was placed onto the German market for the first time in the previous calendar year and that typically does not accumulate as waste with a private final consumer;
• participation of the packaging subject to system participation placed onto the German market for the first time in the previous calendar year in one or more system(s);
• the material type and mass of all packaging returned through one or more sector-specific solution(s) in the previous calendar year pursuant to section 8 VerpackG;
• the material type and mass of all the packaging returned in the previous calendar year pursuant to section 7 (3) VerpackG;
• fulfilment of recovery requirements for the retail and grouped packaging returned pursuant to section 15 (1) no. 2 in the previous calendar year;
• fulfilment of recovery requirements for packaging returned pursuant to section 7 (3) during the previous calendar year.

The information must be reviewed and verified by a registered auditor. The auditing and confirmation process is based on the 'declaration of completeness audit guidelines' on auditing and confirming declarations of completeness pursuant to section 11 VerpackG (Audit guidelines).

The declaration of completeness for the previous year must be submitted by 15 May. If the deadline falls on a Saturday, Sunday or public holiday, it is extended to the end of the next business day. Where the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register Verpackungsgesetz – ZSVR) or state enforcement authorities order that a declaration of completeness be submitted, the order will stipulate the deadline that must be complied with.