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System volume flow record audit guidelines

Section 26 (1) no. 28 VerpackG (Packaging 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 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.

Evolution of the volume flow record audit guidelines

Registered experts are required to adhere to the volume flow record audit guidelines when auditing systems’ compliance with record-keeping obligations. The audit must be presented to the ZSVR in writing by no later than 1 June of the calendar year following the reference year. The key updates to the content made in the latest version as of 15 December 2020 are:


•    Transitional provisions (Verpackungsgesetz vs. Verpackungsverordnung) are no longer accounted for.
•    The allocation of volumes to a reference year was specified (no. 10.3).
•    The eligibility of ash for the calculation of recycling rates was specified (no. 15.2.4).