Packaging disposal; application for confirmation of sufficient professional qualification of experts established abroad

Experts for packaging disposal established in other EU/EEA countries who wish to perform expert activities in Germany only temporarily and occasionally may apply for confirmation of sufficient professional qualification.


In order to guarantee their obligation to take back and recover such packaging, manufacturers of packaging subject to system participation do not need to participate in an officially established take-back system under certain conditions if they provide prior evidence, in the form of a certificate from an expert, in particular of the establishment of a suitable industry-related collection structure at all points of collection supplied and of the future recovery of the sales packaging collected in these structures in accordance with the Packaging Act (industry solution).

In addition, manufacturers of packaging subject to system participation must generally submit annual declarations of completeness regarding the sales packaging and secondary packaging placed on the market for the first time in the previous calendar year. And alternatively (instead of, for example, by a tax consultant), they must also have this checked and certified by an expert within the meaning of the Packaging Act.

Furthermore, (take-back) systems must document the recovery of the collected packaging on a calendar year basis (volume flow verification). The volume flow verification must be checked and certified by a registered expert.

These obligations are fulfilled if only the experts listed by the central office in the inspector register are commissioned with the inspection and certification. These experts include, on the one hand, experts who have been publicly appointed for packaging disposal in accordance with § 36 of the Industrial Code. However, such experts also include experts established in other EU/EEA countries who only temporarily and occasionally wish to carry out the expert activities provided for in the Packaging Act in Germany, if their sufficient professional qualification for this has been verified and confirmed by the public body responsible for the public appointment of such experts.


In the review procedure, it is examined whether the above-mentioned expert has the professional qualification required for a publicly appointed expert for packaging disposal.


The applicant does not have to observe any deadlines when filing the application for review.

Required documents

  • Proof of citizenship

    in certified copy and translation by a translator publicly appointed and sworn in the Federal Republic of Germany

  • Proof of legal establishment for the exercise of the activity of an expert for packaging disposal in an EU or EEA state, furthermore proof that this activity has not been prohibited, not even temporarily.

  • foreign proof of professional qualification for an expert in packaging disposal

    Proof of at least one year's activity as an expert for packaging disposal in the foreign country of establishment during the last 10 years


Please select a location in "Localization" so that the address of the responsible authority can be filled in.

  • Prefillable Form, Bavaria-wide: Formloser Antrag (mit Unterschrift)
    Please note

    This form has to be signed and sent to the responsible authority. You can sign the form manually and send it by email/fax or sign the form electronically with your qualified electronic signature an send it by (secure) email. If the responsible authority has set up a De-Mail account, you can also send the form by De-Mail using an sender-confirmed message.


  • see fee schedule of the IHK

Links to more information


Responsible for editing:Bayerisches Staatsministerium für Umwelt und Verbraucherschutz

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