Completeness Statement (CS)

Completion and Delivery

The Completeness Statement provides a proof of all sales packaging and repackaging quantities placed on the market by a manufacturer / distributor in the previous calendar year. All obliged companies have to submit the Completeness Statement to the Central Agency by 15 May of each year for the respective previous year (§11 Packaging Act.)

The first distributor has to file the Completeness Statement at https://www.verpackungsregister.org/, an electronic database to which only the Central Agency has access.

Completeness Statements are to be made without further official request if one of the de minimis limits is exceeded.

Important points in a nutshell:

The Completeness Statement (CS) is an instrument of the Central Agency to verify and control the due execution of the German Packaging Act. For this purpose, the obligated companies proof with a CS audited by a certified public accountant, a tax consultant, a sworn auditor or an independent expert, that all quantities marketed in Germany and delivered to the end-user or equivalent sources of waste generation comply with the packaging act. The dual systems also have to provide information on the licensed packaging quantities in relation to the respective companies to the central office. The assignment is made by the registration number of the first distributor at the Central Agency.

The Central Agency compares the information provided by the first distributor and the information provided by the dual system. In addition, the Central Agency has programmed algorithms that check the plausibility of the reports with the market data of comparable companies.

Basically, the legal obligation to submit a Completeness Statement follows the obligations to license sales packaging and repackaging.

Thus, if a company is required to license sales packaging and exceeds the thresholds listed below in the calendar year, there is an obligation to submit a Completeness Statement:

  • more than 80,000 kg of glass
  • more than 50,000 kg paper, cardboard and board
  • more than 30,000 kg of ferrous metals, aluminium, beverage carton packaging or other composite packaging

Below these so-called “de minimis limits”, Completeness Statement are only to be made at the request of the Central Agency or regional authorities.

The Completeness Statement must be submitted by 15 May of the following year at the latest. Otherwise there is an administrative offense (§ 34 (1) no. 11 VerpackG in conjunction with § 69 (2) no. 15 KrWG).

The Completeness Statement refers to all sales packaging and repackaging that produces waste at households or equivalent sources of waste generation (e.g. hotels, canteens and hospitals) and which were placed on the market during the year under review. The Completeness Statement must contain the following information according to § 11 (2) Packaging Act:

  • the type and mass of all packaging and repackaging which has been placed on the market for the first time in the previous calendar year;
  • the type and mass of all packaging and repackaging which has been placed on the market for the first time in the previous calendar year but that typically didn’t produce waste at households and equivalent sources of waste generation (e.g. hotels, canteens and hospitals).
  • information on participation in dual systems with regard to the obliged packaging that was placed on the market in the previous calendar year for the first time;
  • the type and mass of all packaging and repackaging taken back in the previous calendar year via one or more industry solutions in accordance with § 8 Packaging Act.
  • the type and mass of all packaging taken back in the previous calendar year pursuant to § 7 (3) Packaging Act.
  • information on the fulfilment of the recycling requirements with regard to the sales packaging and repackaging taken back in the previous calendar year pursuant to § 15 (1) Packaging Act.
  • information on the fulfilment of the recovery requirement with regard to the packaging taken back in the previous calendar year pursuant to § 7 (3) Packaging Act.

According to § 11 (1) Packaging Act, the Completeness Statement requires verification and confirmation by a registered expert or by a certified public accountant, tax consultant or certified accountant pursuant to §27 (2) Packaging Act.

In general, all professions require that the examiner must be independent of the company to be audited.

Basically, the legal obligation to submit a Completeness Statement follows the obligation to license sales packaging.

If the licensing obligation is with the retailer, there is no obligation to submit a Completeness Statement.