According to Section 11 of the Packaging Act, producers, importers and online sellers who place packaging on the market for the first time are obliged to submit a so-called "declaration of completeness" to the Foundation Central Agency Packaging Register (ZSVR) by 15 May of the following year at the latest if the so-called limit values are exceeded. Companies that use service packaging (e.g. bakeries, snack bars) may also be affected under certain circumstances. The declaration of completeness in accordance with the German Packaging Act (VerpackG) is a statutory declaration that companies must submit to the ZSVR every year. It serves the purpose of transparency and monitoring whether companies have fulfilled their obligation to participate in a dual system for the disposal of packaging.
Who has to submit a declaration of completeness?
The obligation exists if a company exceeded at least one of the following quantity thresholds in the previous year:
- Glass: at least 80,000 kg, or
- Paper, cardboard, carton (PPK): at least 50,000 kg, or
- Lightweight packaging (LVP) such as plastics, aluminium, ferrous metals, other composites, beverage carton composites: at least 30,000 kg in total
These thresholds apply to packaging subject to system participation, i.e. packaging that typically accumulates with private final consumers. The declaration must be certified by a registered auditor (e.g. expert or auditor/tax consultant) named in one of the two audit registers published by the ZSVR.
What happens if I don't hand it in?
- According to § 36 (11) VerpackG, this is an administrative offence that can be punished with fines of up to 100,000 euros.
- An extension of the deadline is not possible.
Violations of this legal regulation have been prosecuted and penalised by the competent authorities in the recent past, cf.
- Case report 02/2025: Online pharmacy has to make up for five years of non-compliance with the system participation requirement, paying millions - published on 18 March 2025
- Case report 01/2025: Court confirms high fine for food company’s outstanding declaration of completeness - published on 18 March 2025
- Case report 01/2023: Food producer failed to file declaration of completeness - published on 31 March 2023
- Case report 01/2020: Garden centre - Failure to system participation and lack of a declaration of completeness - published on 19 March 2020 with changes of 23 April 2020
Do you need support with the preparation and processing of your declaration of completeness? The take-e-way consulting team will be happy to help you via +49/40/750687-0 or consulting@take-e-way.de
PPWR online training now available
The EU Packaging Regulation (EU) 2025/40 (PPWR) is one of the most important to-do topics for sellers and producers of products and packaging in the coming months – alongside the EU Batteries Regulation. Due to the great interest in the PPWR, we recommend that you request your personalised online PPWR training course in good time and without obligation.
