Report on the audit and confirmation of declarations of completeness
The ZSVR has prepared a detailed presentation outlining its practical experience, including many suggestions about improving how audits are conducted (only available in German).
Auditing and confirming declarations of completeness
The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) engaged in an extensive dialogue with the German Chamber of Public Accountants and the Federal Chamber of Tax Advisers about how auditors and tax advisers audit and confirm declarations of completeness.
What should auditors be aware of when submitting a declaration of completeness?
Auditors have to be registered with the LUCID Packaging Register.
The ZSVR's audit guidelines must be applied: have companies participated the correct volume of packaging and the right material types?
The audit report must contain detailed documentation based on the system participation requirement catalogue.
When in doubt, auditors should take advantage of the services offered by the ZSVR to find answers or clear up uncertainties.
Auditors, tax advisers, sworn accountants and other experts (e.g. environmental verifiers) are being asked to focus more heavily on identifying possible under-participations when auditing declarations of completeness. Doing so requires diligently applying the ZSVR's audit guidelines for these declarations, including making sure that audit results are documented in detail to demonstrate that a thorough audit was conducted and that the correct volumes of the right material groups were participated.
Brief overview of the ZSVR's practical experience
The ZSVR requests that registrations be terminated if auditors are inactive.
The audit guidelines are intended to support auditors and help them to uncover under-participations.
The use of the catalogue during the audit should be clearly evidenced.
The ZSVR stresses the importance of the audit report containing comprehensive documentation.
The ZSVR would like to see more extensive use of its services to resolve uncertainties or questions.
What you need to know
The ZSVR lists experts, auditors, tax advisers and sworn accountants indicating their intention to conduct audits under the Verpackungsgesetz (Packaging Act) in a register of auditors that it publishes on the internet.
Auditors and experts must register individually for technical reasons; there is no way to register organisations of experts. The key registration requirements are set out in section 27 VerpackG (Packaging Act). In addition to entering the master data, suitable evidence of an expert's professional qualification must be uploaded. Documentation must be specific to the particular individual; authorisations for a firm of auditors will not be accepted. Once the information and the documentation has been verified by the ZSVR, the registration will be approved. This may take a few business days to complete.
The auditor has to log into the LUCID Packaging Register with their login credentials and click the 'Master data' tile. After clicking the 'Edit' button, click the 'Terminate registration' button at the very bottom of the page.
Insufficient audit documentation means, for example, that the responsible auditor has failed to take the opportunity to demonstrate to the ZSVR's satisfaction that the possibility of under-participation has been investigated to the required standard. Insufficient documentation prevents the ZSVR from ruling out producer under-participation, and in cases of actual under-participation, it may view the auditor's actions as a gross breach of the audit guidelines.
The removal of an auditor from the register of auditors would typically be accompanied by the ZSVR reporting the matter to enforcement authorities if it suspects that the producer has committed an administrative offence. However, the very objective of the audit is to protect the producer from such a significant consequence.