Declaration of Completeness

Silvia Tholen

registered auditor
auditor ID: DE6479911904304

+49 541 77080-21

Our many years of expertise will help you achieve a legally compliant Declaration of Completeness.

Declarations of Completeness must be audited by a registered auditor.

Our publicly appointed and sworn experts for packaging disposal are registered as auditors with the Central Agency Packaging Register. In addition to expert knowledge in packaging, material classification, and delimitation of packaging not subject to system participation, we also have many years of experience examining Declaration of completeness and can support your company in its submission.


According to § 11 VerpackG, anyone who brings packaging into circulation for the first time that is subject to system participation is obliged to submit such a Letter of Representation on his packaging subject to system participation for the previous year by 15 May of the following year.


This obligation exists if at least one of the following thresholds has been exceeded:

  • > = 80 t glass or
  • > = 50 t paper, cardboard, carton or
  • > = 30 t light packaging (plastics, composites, metals)


Our Services


  • We ensure the quality of your Letter of Representation with our audit tool.
  • Our templates for handling your packaging quantities and system participation constructs help you to effectively and efficiently implement your obligations under the Packaging Act.
  • The inspection is carried out on the basis of the Packaging Act and the inspection guidelines for Declaration of completeness of the Central Packaging Registration Office. It comprises the inspection fields listed there, including inspection of the system participation contract, random sample inspections, check weighing and test run of a quantity determination.

The inspection is completed with the deposit of the following Declaration of completeness documents:

  • Your manufacturer's declaration
  • Test confirmation
  • Test report

All documents are provided with a qualified electronic signature.


We are also happy to support you ...


  • in the preparation of the Declaration of completeness audit, e.g. by:
    - the packaging classification according to the Packaging Act and distinction from non-packaging
    - the packaging classification according to the material types of the Packaging Act
    - the weighing of packaging in our weighing laboratory in Osnabrück
  • Evaluating contracts with systems and brokers for the participation of your sales packaging in a system according to § 7 VerpackG
  • Workshops and seminars for your employees on the requirements of the VerpackG


We are happy to offer various consulting services on:


  • General consultation on the definitions according to § 3 VerpackG (e.g., manufacturer, distributor, shipping packaging, packaging subject to system participation)
  • Individual consultation on company-specific case constellations for manufacturers and distributors within the meaning of the Packaging Act (including the definition of the first distributor of packaging, import business, fulfilment, drop shipping, trade export, and online trade)
  • Consultation on the classification of products according to the catalogue of packaging subject to system participation of the Central Packaging Register Office