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

A serious problem is the illegal export of WEEE which, according to some estimations,
ranges from 10 to 15 % in Germany, and which adds pressure to recycling prices. 469
Governments should ensure that the WEEE streams will reach recycling facilities
operating to appropriate standards and that recycling capacities are being fully
utilised. Here, the minimum and insufficient border control of WEEE exports appears
to be a significant problem.
21.9 Effect of the Policy on Pricing of Resources / Services
The consequences and behaviour of business and communities after two years
experience with the new regulation can be summarized as follows:
Following the full implementation of free of charge disposal (24 th March 2006),
producers announced that they would re-finance the costs with price increases for
new products. It is still unclear whether this has happened and to what extent.
Gotthard Graß (General Executive Manager of the ZVEI) was reported as saying: "I
expect that the prices for new appliances will increase." For some electric appliances
like washing machines, recycling has probably been cost-neutral due to the high price
received for scrap metal, of which there is a considerable quantity . In contrast the
recycling of fluorescent tubes or energy saving light bulbs is more complicated
because of the mercury content. For the latter product types, the recycling revenue
can amount to 20 to 60 % of the product price. Nevertheless according to Bitkom, 470
the producers of PCs, computer equipment, mobile phones and entertainment
electronics have only small leeway regarding price increases, due to a drop in prices
in those branches resulting from competition in the EEE market, and a general
decline in prices in real terms.
Experts have different opinions on whether the free of charge collection system for
WEEE will lead to falling or even rising waste disposal charges being levied by local
authorities on householders. It is reported that some municipalities will increase
waste disposal charges, arguing that they will have to enlarge and reconstruct their
collection points in order to comply with the ElektroG. By contrast, the German
Environmental Ministry and the Bitkom-expert Mario Tobias, are of the opinion that
waste disposal charges should fall, because following the new regulations,
communities no longer have to pay for the transport and recycling of the WEEE
anymore, they only have to collect it. A speaker of the German Environmental Ministry
is cited as saying that waste disposal charges are not very transparent anyway, as it is
not known which other costs are covered as part of the charges.
21.10 Evasion and Enforcement
The problem of free-riders is believed to be a significant one in Germany. Although all
affected companies according to the ElektroG should have been registered since
469 EUWID from 21 st January 2008, p.4.
470 BITKOM represents 1,300 companies, some 700 of which are direct members. These include
almost all of the leading players in the industry, as well as more than 500 smaller, medium-sized and
new businesses, see: http://www.bitkom.org/ .
415
International Review of Waste Policy: Annexes