Bitkom Compliance Solutions

The new ElektroG is in the final stages of amendment. The central point of the discussions about the amendments is always the collection rate of WEEE to achieve the climate targets. Once again it is said that the quota has not been met.

How reliable is the collection rate?

Let's take the current example: in 2019, the WEEE return rate increased by 10%; but so did the sales of EEE. And thus the collection rate remains almost unchanged, despite an increased WEEE return rate. And another concrete example: photovoltaic systems have a lifespan of 10-15 years. For the calculation of the collection rate, however, only three consecutive years are taken into account. Therefore, the informative value of the collection rate for e-waste remains limited, at least in the current form of the calculation.

Does anyone know what happens to the rest of the waste electrical equipment?

That is a good question. Unofficial collections, robbery and the export of old equipment are indeed ways for old equipment to be disposed of. It also happens that end-users do not dispose of WEEE properly. Finally, B2B equipment is often properly recycled but not always captured by reporting because take-back options are very diverse. Manufacturers are helping to improve knowledge about proper disposal. The information campaign of the ear foundation, the manufacturers' joint body, has been running since the end of 2019.

In your opinion, where is the most urgent need for action in the amendment of the ElektroG?

We see a need for change in the removal of batteries. We demand a clarification that the non-destructive removal refers to the battery and not to the device. According to the draft, it should be possible for independent specialists to remove batteries using standard tools. We demand that this requirement be limited to old appliances. Otherwise, the present draft of the ElektroG shows various approaches to meet the collection challenges described above: The possibilities for return are to be extended and the information obligations expanded.

Do you see any other levers besides the collection rate?

We are moving away from a purely waste-based approach. Of course it is important to have a good infrastructure for the collection of old appliances, as well as to provide reprocessing facilities, but the sense only really becomes apparent when we think in terms of the "circular economy".
This is not entirely new. Even today, appliances can be repaired, components can be replaced and old appliances are recycled. But if we look at the EU's Circular Economy Action Plan, the requirements will go much further. Extended repair options, longer lifetimes, the mandatory use of recyclates or the provision of comprehensive product data are just some of the proposals.

What do the manufacturers think about this?

Electrical and electronic devices are part of our everyday lives. And the trend towards electrification continues. Manufacturers offer a variety of solutions for this. When we talk about what manufacturers can do, we must not only think about closing loops, but also about product safety and consumer expectations. All these aspects have to be thought of together already at the design stage. But new business models are also conceivable, for example leasing models or rental offers. And what we must not forget: Together with digitalisation, electrical and electronic appliances contribute to the breakthrough of renewable energies and thus to achieving the goals of the EU Green Deal.

The interview was originally conducted with Christian Eckert, Managing Director ZVEI Batteries Division and Head of Environmental Policy Department of ZVEI – Zentralverband Elektrotechnik- und Elektronikindustrie e. V. and was translated into English.