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Who has to check my declaration of completeness in Germany?

A registered expert, or a registered auditor, tax adviser or sworn accountant. The confirmation carries a qualified e-signature and is filed with ZSVR with the audit reports (§ 10 VerpackDG).

Since 12 August 2026, § 5 VerpackDG, implementing Article 45(3) of Regulation (EU) 2025/40, requires a producer with no establishment in Germany to appoint an authorised representative before it first makes packaging available in Germany. Read § 5

By Razvan Toma · Founder · Last checked 7 November 2026 · Sources linked below

Quick answer

A registered expert or a registered auditor, tax adviser or sworn accountant. § 10(1) VerpackDG: the declaration of completeness, due by 15 May for the previous calendar year, is checked and confirmed by a registered expert or by an auditor, tax adviser or sworn accountant registered under § 56(2). § 10(3): you file it electronically with ZSVR together with the audit reports, and the confirmation carries a qualified electronic signature. ZSVR can also ask for the system-participation confirmations and, if it sees signs of errors, further documents. See who must file one. VerpackDG § 10

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