The Verpackungsgesetz (Packaging Act) 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.

The current declaration of completeness audit guidelines have been in place since the 2021 reference year. These guidelines are to be followed when auditing declarations of completeness that need to be filed with the ZSVR by 15 May of the year following the reference year. 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 related rules: audit of DoCs that were ordered or filed too late, or in cases where the ZSVR had found a previous declaration of completeness to be incorrect or incomplete and/or where administrative offence proceedings pursuant to section 36 (1) no. 11 or no. 3 VerpackG were initiated
• Audit area B.1: information about packaging and pre-participated service packaging
• Audit area B.2 and B.8: addition of late payment cases
• 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
• C.2.1: audit report in German
• C.2.2: addition of the volume of pre-participated service packaging, audit activities statement and sample determination to the audit report requirements
• Glossary: update, inclusion of the definition of the term 'authorised representative'

• 'Declaration of completeness audit guidelines’ 2021 (as of 17 December 2021), applicable from the 2021 reference year on
• 'Declaration of completeness audit guidelines' for the 2020 reference year (last updated: 6 November 2020)
• 'Declaration of completeness audit guidelines' for the 2019 reference year (last updated: 15 April 2020)
• 'Declaration of completeness audit guidelines' for the 2018 reference year for auditing and confirming declarations of completeness pursuant to section 11 VerpackG (last updated: 1 January 2019 with amendments dated 26 February 2019)
  (This declaration of completeness audit guidelines is only available in German.)

Pursuant to section 11 (3) VerpackG, the ZSVR has published standard operating procedures concerning 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 LUCID Packaging Register. The requirements set out in these guidelines must be complied with when making filings. The 'declaration of completeness technical guidelines' can be found here.