EPR audit

Environmental Sustainability Tax Services

EPR (Extended Producer Responsibility) audits in Germany are conducted to ensure that producers and manufacturers comply with the legal obligations regarding waste management and recycling. Germany has a well-established EPR system that holds producers responsible for the proper handling and recycling of their products and packaging materials.

EPR Audits target group

The target group for EPR (Extended Producer Responsibility) audits includes producers and manufacturers who are subject to EPR regulations in a specific jurisdiction. EPR audits are conducted to ensure that these entities are complying with legal requirements related to waste management and recycling.

The key members in the target group for EPR audits:

Producers and Manufacturers

Brand Owners and Importers

Importers and exporters


Fufilment service providers

Distributors and Wholesalers 

It’s important to note that the specific members of the target group for EPR audits can vary depending on the jurisdiction and the scope of the EPR program in place. For example, some programs may focus solely on packaging materials, while others may cover a broader range of products. Producers and manufacturers should familiarize themselves with the specific regulations and requirements applicable to their industry and location.

Legal Framework:

EPR audits in Germany are governed by the Packaging Act (VerpackG) and related regulations. This legislation places the responsibility on producers to finance and organize the collection, sorting, and recycling of packaging waste.

Audit Process:

EPR audits typically involve a comprehensive examination of a producer’s compliance with the requirements set forth by the Packaging Act. This may include an assessment of the producer’s reporting, documentation, and financial contributions to the recycling system.

Audit Objectives:

  • Compliance Verification: Auditors check if producers have registered with the relevant authorities and fulfill their obligations under the Packaging Act.
  • Documentation Review: Auditors review the documentation related to the quantities and types of packaging materials placed on the market.
  • Financial Contributions: Auditors assess whether producers have made the required financial contributions to the waste management and recycling system.

When should the Declaration be submitted?

The declaration should be submitted annually by May 15 for the previous year.

Certified Auditors:

EPR audits are typically conducted by independent, certified auditors or auditing firms. These auditors have the expertise and authorisation to perform compliance assessments in accordance with the legal framework.

Penalties for Non-Compliance:

Non-compliance with EPR regulations can result in fines and penalties. Producers failing to meet their obligations may face legal consequences, including monetary sanctions.

Continuous Monitoring:

EPR audits are part of an ongoing process to ensure compliance. Producers are expected to regularly report their packaging data, and audits may be conducted periodically to verify this information.

Environmental Impact:

The EPR system in Germany is designed to reduce the environmental impact of packaging waste by promoting recycling and responsible waste management practices.

Public Transparency:

The results of EPR audits may be made public to promote transparency and hold producers accountable for their environmental responsibilities.

If you are a producer or manufacturer subject to EPR regulations in Germany. It is important to work closely with experienced professionals who understand the legal requirements and can assist with compliance and audit preparations. This might involve engaging with specialized EPR consultants or collaborating with accounting and advisory firms with expertise in environmental regulations and compliance.

Further details and specific measures outlined in the EPR Audit can be obtained from the official communication by FZCO Accountants, please contact the following:

Dr Faisul Alam, Sustainability Tax Services