Yes, a product declaration can be issued for a cash register system even if the system does not have an integrated cash drawer. This must be stated when the product declaration is submitted.
It is important to be aware that such cash register systems can only be used by parties who are required to keep accounts when the exception for integrated cash drawers in Section 2-2 second and third paragraphs applies. The provision states:
The cash register system must have an integrated cash box at each point of sale. This requirement does not apply if the cash register system has functionality for registering cash sales etc. separately for each operator and the sales are not registered from a fixed point of sale. Nor does the requirement apply at a point of sale where it is not possible to pay using notes and coins.