International Review of Waste Management Policy - Department of ...

ominated flame retardants in any new electrical and electronic equipment that they
put on the market. Since the entry into force of the Electrical and Electronic
Equipment Act (ElektroG), manufacturers have had to take disposal costs of products
into account even in the design stage, as consumers can return old equipment to
local collection points free of charge. Manufacturers and importers have to pick up
waste equipment at these collection sites and take charge of subsequent
management. This has brought about a reduction in the pollutant load of municipal
waste. The volume of waste electrical and electronic equipment from these local
collection points is about 1.8 tonnes per year. 462 Following the introduction of the
ElektroG, less WEEE has since been disposed of in landfills. 463
However, a causal link cannot be drawn between the introduction of the ElektroG and
other impacts, e.g. an improvement in the product lifetime or enhancing the
recyclability of electric and electronic equipment (see lessons learned). Mr Hieronimy
from Hewlett-Packard (Germany) states that for his company, the effect of the
ElektroG producer responsibility system is such that it has led to no changes in their
product design. Improvements in product recyclability at HP have been a result of
product and brand ‘image’ requirements, rather than as a result of producer
responsibility. 464 Mr Hieronimy states that for him, the present implementation of
producer responsibility in the ElektroG does not lead to individual savings for
companies due to the design of their products, but would lead to any benefits being
distributed evenly among all producers. 465 This effectively implies a disincentive to
change product design owing to the free-rider problem created by the shared
responsibility approach.
Recycling Recycling of of waste
Statistics for the first year of ElektroG (2006) concerning recovery, recycling and reuse
of WEEE in Germany are given in Table 21-2.
Statistics show that for B2C equipment, the German collection amount of 8 kg WEEE
per person per year is double that of the EU collection target of 4 kg per person per
year. 466
Nevertheless, it remains questionable as to whether or not the main aims of the
ElektroG have so far been achieved. According to Art. 1 ElektroG, the law aims to
prevent waste from electrical and electronic equipment and to promote reuse,
recycling and other forms of recovery to reduce both the volume of waste. The
recovery and re-use of used equipment is hampered by the demolition of WEEE during
collection or transport. The waste management branch claims that the demolition
462 Federal Environmental Ministry, Fewer hazardous substances in electrical and electronical
equipment, press statement from 30.6.2006.
463 Sabine Enzinger, Bilanz ElektroG, Umweltmagazin, July-August 2007, p. 18.
464 EUWID from 17 th October 2008, p.3.
465 EUWID from 17 th October 2008, p.3.
466 Federal Environmental Ministry (BMU), Data on EEE in Germany in the year 2006 - BMU
Explanations for the report to the EU-Commission, 5.09.2008, p. 2.
412
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