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

21.6 Implementation Costs
Producers have to guarantee the financing of the collection and treatment of their
products by participating in a collective system or by setting up an individual
compliance scheme.
The ZVEI (German Electrical and Electronic Manufacturers' Association) estimated
that the WEEE policy would cost industry €5,000,000 per annum. In 2007, the
members of the BVSE (“Bundesverband Sekundärrohstoffe und Entsorgung e.V.”)
registered a cut in prices for the collection and recycling of WEEE of up to 30 %. With
the second amendment of the “Ordinance on fees regarding the ElektroG” (Zweite
Änderungsverordnung zur Kostenverordnung zum ElektroG) having entered into force
on 1 st January 2008, the Federal Environmental Ministry has proposed a further
decrease in fees of up to 40%. Nonetheless, for 2008, the Federal Environmental
Ministry predicts that the overall costs of the system, as financed by fees from
producers, to be approximately €5,800,000. 468 Using the total tonnes of WEEE
collected in Table 21-1, the estimated cost per tonne of WEEE collected is therefore
€7.69.
21.7 Effects on Technical Change / Innovation
In the “Business to Consumer” sector, producers are obliged to finance the WEEE
costs associated with all products; there is no direct link to the recycling cost of the
specific product that has been made by the individual producer. The shared
responsibilities thus result in reduced interest by individual producers to produce
products of high quality, which have a long lifetime, and which would lead to a
reduction in collection and recycling costs. The picture is slightly different in the
“Business-to-Business” sector, as here products have to be taken back in clearly
defined ways by the producers.
21.8 Complementary Policies
The Electrical and Electronic Equipment Act (ElektroG) complements the general
regulation on waste - the Closed Substances and Recycling Act (Kreislaufwirtschafts-
und Abfallgesetz). The producer responsibility regulated in Article 22 of the Closed
Substances and Recycling Act commits producers and distributors to design their
products in a way that prevents waste in the manufacture and usage of a product.
A further complementary policy in place is the Landfill Ordinance (Deponie-
Verordnung - DeponieV); this policy still contains loopholes which weakens the landfill
ban of, inter alia, the WEEE-derived shredder light fraction (SLF).
468 Second Amending Ordinance on the Cost Ordinance on the Electrical and Electronic Equipment Act,
in the version of 6 July 2005 (Federal Law Gazette I year 2005 p 2020), last amended by Article 1 of
the 2nd Ordinance Amending the Cost Ordinance on the Electrical and Electronic Equipment Act of 5
December 2007 (Federal Law Gazette I year 2007 p. 2825).
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