compliance teamThe German completeness declaration: thresholds, audit and 15 May
Step 1
Measure last year by fraction
Step 2
Test each threshold separately
Step 3
Engage a registered auditor early
Step 4
File electronically by 15 May
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
Three thresholds, taken separately
An audited completeness declaration for the previous calendar year is due when a producer exceeded 80 tonnes of glass, 50 tonnes of paper and board, or 30 tonnes of the listed lightweight fractions taken together. That sum covers ferrous metals, aluminium, plastics, beverage cartons and other composites.
A standard cross-border e-commerce seller is far below all three. For that profile the honest answer is that no audit applies, and a provider quoting audit coordination as standard scope is selling something the seller does not need.
How it is filed
The declaration is submitted electronically in the packaging register by 15 May, and no extension is available. It must be certified by an auditor registered with the register, using a qualified electronic signature. The auditors who certify declarations may not act as authorised representatives, so the two roles never sit with the same party.
For a producer that crosses a threshold, the work starts months earlier: the auditor needs reconciled volumes, licence contracts, invoices and evidence, not a spreadsheet produced in May.
The thresholds are not a shield
The central agency or a competent state authority may require a completeness declaration regardless of the thresholds. Being below them is the normal case, not an exemption.
The reporting year 2026 sits across the change of law: the declaration is filed under the new act while its content follows the rules that applied during the year. Keep the year's evidence organised on that basis rather than assuming a clean cut on 12 August.
Conclusion
Scope comes before a form. Connect the legal entity, its German establishment, the product, the sales channel and the EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. The packaging register, the central agency, the dual systems and the marketplaces control their own procedures, timing and decisions.