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High packaging volumes require a declaration of completeness

Companies with high packaging volumes have to submit a declaration of completeness for the previous year, checked by an auditor registered with the ZSVR, by no later than 15 May of each year. If 15 May falls on a weekend or a public holiday, the deadline is extended to the end of the next working day. As these are statutory deadlines, they cannot be extended. Even after the deadline has passed, the obligation to file a declaration of completeness with the LUCID Packaging Register remains.

A late submission, just like the failure to file declaration of completeness, constitutes an administrative offence that may be punished with a fine.

Who has to submit a declaration of completeness?

The obligation to file declarations of completeness applies to companies whose packaging volumes in the previous calendar year reached or exceeded at least one of the following three volume thresholds:

  • 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 authorities also have the power to require at any time that a declaration of completeness be submitted, even if these thresholds are not reached.

What is the process for submitting a declaration of completeness?

Declarations of completeness are filed wholly electronically in the LUCID Packaging Register. The submission consists of three documents:

  1. the 'producer declaration' of the company under obligation, which is prepared and generated by the producer under obligation in their registration in the LUCID Packaging Register.

  2. the audit confirmation of the appointed auditor.

  3. the audit report of the appointed auditor.

All documents must be uploaded electronically to the ZSVR's LUCID Packaging Register. The audit result must then be filed through the 'Entering the audit result' tile.

Heads-up: The declaration of completeness must contain entries detailing the material types and masses of all the retail and grouped packaging placed on the German market in the previous calendar year, including those that accumulate as waste in industrial or large commercial enterprise settings after use.

Declarations of completeness can be audited and attested by experts, auditors, tax advisers or sworn accountants, who must apply the ZSVR's 'Declaration of completeness' audit guidelines and be registered with the LUCID Packaging Register.

Where can I find an auditor?

Register of auditors

You can find an auditor in the ZSVR's public register of auditors. Please note:

  • It is mandatory that a contractual relationship with the auditor be in place before you indicate them as the responsible auditor in your declaration of completeness.

  • For companies located abroad: your auditor does not need to be located in the same country as you.

  • You are free to choose your auditor from the ZSVR's public register of auditors.

Heads-up: The ZSVR's experience to date indicates that the audit guidelines are often disregarded. As a result, auditors overlook under-participation by the companies under obligation. Practical information to help comply with the audit guidelines during the auditing and attesting of declarations of completeness is available here.

Further important information

A declaration of completeness is a written, truthful statement or confirmation regarding the packaging volumes that a company placed on the German market in a given year. The declaration of completeness must be audited and confirmed by an auditor registered in the LUCID Packaging Register.

Companies submit a declaration of completeness to confirm that they have duly participated their packaging with a system, paying for the recycling of their packaging and assuming producer responsibility. This creates transparency. The main goal of the provision is to make fully and accurately comply with the system participation requirement.

The declaration of completeness contains entries detailing

  • the material type and mass of all the packaging subject to system participation placed on the German market for the first time in the previous calendar year;

  • the material type and mass of all retail packaging and grouped packaging that was placed on the German market for the first time in the previous calendar year and that typically does not accumulate as waste with private final consumers;

  • participation of the packaging subject to system participation placed on the German market for the first time in the previous calendar year with one or more system(s);

  • the material type and mass of all packaging returned through one or more sector-specific solution(s) pursuant to section 8 VerpackG in the previous calendar year;

  • the material type and mass of all packaging returned in the previous calendar year pursuant to section 7 (3) VerpackG;

  • fulfilment of recovery requirements for retail and grouped packaging returned pursuant to section 15 (1) no. 2 VerpackG in the previous calendar year;

  • fulfilment of recovery requirements for packaging returned pursuant to section 7 (3) VerpackG during the previous calendar year.

Technical guidelines: how to file a declaration of completeness

A step-by-step guide to filing declarations of completeness with the LUCID Packaging Register.

pdf, 7 MB
'Declaration of completeness' audit guidelines

Each declaration of completeness must be checked by an auditor registered with the ZSVR's register of auditors, who is required to comply with the audit guidelines.

Practical information on auditing declarations of completeness

Documentation and audits should focus more heavily on identifying any under-participating producers. This is where auditors find guidance that is based on practical experience, with important notes on how to use the audit guidelines.

Register of declarations of completeness

This register publicly lists the companies that have submitted a declaration of completeness to the ZSVR.

Please refer to the support contact page for more information.

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