from €999 net
The order and affected reporting period determine the scope.
UBA order
Audit requested by the German Environment Agency
The UBA may require an audit even when the regular quantity threshold is not reached. TAXORA audits the affected declaration in line with the specific order and the applicable requirements.
Provide documents
After engagement, send the relevant documents and quantity evidence to TAXORA.
Express audit: subject to availability, plus €999 net.
A lower threshold may apply to earlier periods. Manufacturers of exclusively the deposit-bearing beverage bottles specified by law may be exempt from the regular audit regardless of quantity. The UBA may require an individual audit even where an exemption applies. We clarify the period, product categories and reason for the audit before engagement.
Individual-case audit
Why may the UBA require an audit below the threshold?
Section 11(4) EWKFondsG allows the German Environment Agency to require verification and confirmation at any time, even where a declaration would otherwise be exempt from the regular audit obligation.
An order does not automatically mean that the declaration is incorrect. It provides additional independent assurance in the individual case. The wording of the order, the reporting year, the requested records and the deadline are decisive.
How a UBA order may arise
The statutory power is not tied to a minimum quantity or an exhaustive list of triggers. An audit can provide clarification whenever the derivation of a declaration requires further assurance. The following are illustrative scenarios, not an exhaustive description of UBA practice:
Plausibility questions
The reported total cannot readily be reconciled with product master data, sales data, product weights or values from other reporting periods.
Unclear product classification
It is uncertain whether individual items fall within a product category in Annex 1 EWKFondsG or may be excluded from the declaration.
Complex supply chains
Imports, exports, returns, intra-group supplies or direct sales from abroad make it difficult to delimit the quantities relevant in Germany.
Insufficient records
Documents requested do not resolve questions about the accuracy or completeness of the declaration. An independent audit can document the data trail.
The specific UBA order takes precedence. It determines which declaration must be audited and by when the report and confirmation must be provided.
Detailed example: 7.8 tonnes and still subject to audit
A German food producer reports 7,800 kg of covered single-use plastic products for 2026. The total is below 10,000 kg and would normally be exempt. Its range includes ice-cream cups, snack trays and flexible film packaging, while exports and returns are processed through several ERP reports.
Questions remain about the classification of certain product groups and the reconciliation from sales data to the reported mass. The UBA therefore requires verification and confirmation within a stated deadline.
1 · Analyse the order
The company sends TAXORA the complete order, the affected DIVID declaration and the records already submitted. We define the exact scope and deadline.
2 · Trace the data
Product master data, packaging weights, sales and purchasing data, exports, returns and the calculation logic are brought together and checked for completeness.
3 · Resolve differences
Open classification issues and differences between ERP reports and the declared total are clarified and documented with the company.
4 · Provide evidence
After completion, the company receives the audit report and the qualified electronic signature confirmation for upload to DIVID within the deadline.
Request an audit
Enquire about your DIVID audit.
Provide your company name, country, reporting year, approximate total quantity and reason for the audit. Use the enquiry form when available or email info@taxora-steuerberatung.de.
Prepare an enquiryNon-binding · An engagement begins only after the offer has been accepted.