E Waste Management in Germany

E-waste Management in Germany
20 July 2011
2
3
Author
Otmar Deubzer
United Nations University

Institute for Sustainability and Peace (UNU-ISP)
Operating Unit SCYCLE
UN Campus Bonn - Langer Eugen
Hermann-Ehlers-Str. 10
D-53113 Bonn
Germany
E-Mail: [email protected]
Tel.: +49-30-417 258 33
Fax: +49-228-815-0299
Website: www.unu.edu
United Nations University (UNU) is an autonomous organ of the UN General

Assembly dedicated to generating and transferring knowledge and strengthening
capacities relevant to global issues of human security, development, and welfare. The
University operates through a worldwide network of research and training centres and
programmes, coordinated by UNU Centre in Tokyo.
Disclaimer
The designations employed and the presentation of the material in this publication do
not imply the expression of any opinion whatsoever on the part of the United Nations
University concerning the legal status of any country, territory, city or area or of its
authorities, or concerning delimitation of its frontiers or boundaries. Moreover, the
views expressed do not necessarily represent the decision or the stated policy of the
United Nations University, nor does citing of trade names or commercial processes
constitute endorsement.
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Acknowledgements
The author would like to thank the following persons for their support with information
and critical advice:
 Mr. Jan Bellenberg, Bosch-Siemens Hausgeräte GmbH, Germany
 Mrs. Heike Buschhorn and Mrs. Gabriele Markmann-Werner,

Niedersächsisches Ministerium für Umwelt und Klimaschutz, Hannover,
Germany
 Mrs. Perrine Chancerel, TU Berlin, Berlin, Germany
 Mr. Mathias Dammer, Stiftung Elektro-Altgeräteregister, Nürnberg, Germany
 Mr. Arturo Gavilan Garcia, Mrs. Frineé Kathia Cano Robles, and Mr. Victor
Alcantara Concepcion, Instituto Nacional de Ecología, Mexico
 Mrs. Silke Hossenfelder and Mr. Franz Heistermann, Bundeskartellamt, Bonn,

Germany
 Mrs. Kristine Koch and Mr. Joachim Wuttke, Umweltbundesamt, Dessau,

Germany
 Mr. Kai Kramer, Elektrocycling GmbH, Goslar, Germany
 Mr. Ruediger Kuehr, United Nations University, Bonn, Germany
 Mr. Pascal Leroy, WEEE Forum, Brussels, Belgium
 Mr. Sören Rüd, Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH,

Mexico City, Mexico
 Mr. Christoph Werth-Kreienberg, NOEX AG, Germany

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List of Contents
List of Contents......................................................................................................................... 5
List of Figures ........................................................................................................................... 7
List of Tables ............................................................................................................................ 8
List of Definitions...................................................................................................................... 9
List of Abbreviations ............................................................................................................... 12
1 Executive Summary ........................................................................................ 13
2 Background on Waste Management in Germany ........................................... 15
2.1 Political and Administrative Competences and Responsibilities for Waste Management in
Germany ................................................................................................................................ 16
2.2 Management of Wastes from Private Households ........................................................ 18
2.3 Milestones of Waste and e-Waste Management in Germany ........................................ 21
2.3.1 Waste Management before 1972 ................................................................................................... 21
2.3.2 The 1972 and 1986 Waste Management Acts ................................................................................ 22
2.3.3 Waste Management in East Germany until 1990 ........................................................................... 23
2.3.4 The Discovery of the Ozone Hole and First E-waste Management Activities ................................. 24
2.3.5 The 1994 Substance Cycle and Waste Management Act ................................................................ 25
2.3.6 The European WEEE Directive and the German “ElektroG” ........................................................... 27
2.3.7 Recast of the WEEE-Directive .......................................................................................................... 33
3 E-waste Management in Germany According to the ElektroG ......................... 35

3.1 Key Players and their Roles .......................................................................................... 35
3.1.1 The Public Waste Management Authorities ................................................................................... 35
3.1.2 Producers ........................................................................................................................................ 38
3.1.3 Distributors and Consumers ............................................................................................................ 44
3.1.4 The Clearing House ......................................................................................................................... 45
3.2 Coordination and Interaction of the Key Players ........................................................... 46
3.2.1 Interaction of Producers and the Clearing House ........................................................................... 46
3.2.2 Interaction of Public Waste Management Authorities, Clearing House and Producers ................. 50
4 The German E-waste Management System in Practice ................................... 52

4.1 Collection and Treatment Performance ........................................................................ 52
4.1.1 Amounts of E-Waste Put on the Market, Collected and Treated in Germany ................................ 52
4.1.2 Achievement of the Collection and Treatment Targets .................................................................. 56
4.1.3 Quality of Collection ........................................................................................................................ 60
4.1.4 Quality of Treatment ....................................................................................................................... 62
4.2 Producer Takeback Schemes Operating in Germany ..................................................... 63
4.2.1 Individual Non-selective Takeback Schemes ................................................................................... 63
4.2.2 Collective and Individual Brand-Selective Takeback Schemes ........................................................ 64
4.2.3 Cost of Logistics and Treatment ...................................................................................................... 66
4.3 Achievement of the German Transposition Priorities .................................................... 67
6
4.4 Transboundary Shipments of E-Waste out of the EU ..................................................... 68

4.5 Measures and Incentives for Improvements ................................................................. 70
4.5.1 Increased and Better Quality Collection ......................................................................................... 70
4.5.2 High Quality Treatment of E-waste ................................................................................................. 72
5 Technical, Economical and Ecological Principles of E-waste Treatment ........... 74

5.1 Basic Objectives of E-waste Treatment ......................................................................... 74
5.1.1 Pollution Prevention........................................................................................................................ 74
5.1.2 Recycling.......................................................................................................................................... 75
5.2 Treatment of E-waste .................................................................................................. 76
5.2.1 Overview on the Treatment ............................................................................................................ 76
5.2.2 Treatment of the Fractions from Pre-processing ............................................................................ 79
5.2.3 Performance of Pre-processing ....................................................................................................... 81
5.2.4 Economical and Ecological Implications of Recycling ...................................................................... 83
6 References ..................................................................................................... 86
Annex E-waste related Contacts ..................................................................... 92
7
List of Figures
Figure 1: Outline of Germany’s administrative and political structure .......................16
Figure 2: Logo of the “VEB Kombinat Rohstofferfassung” SERO in the GDR ...........23
Figure 3: E-waste management in Germany until 2006 ............................................27
Figure 4: Financial incentives driving Design for EoL in producer responsibility ........29
Figure 5: Symbol for the marking of electrical and electronic equipment according to
(WEEE Directive 2003) .............................................................................................31
Figure 6: Minimum recovery and recycling targets for separately collected e-waste ..31
Figure 7: Possibilities for producers to implement their extended producer

responsibility in Germany ..........................................................................................39
Figure 8: Individual brand-selective takeback scheme ..............................................40
Figure 9: Individual Non-selective Takeback Scheme ...............................................41
Figure 10: Collective Takeback Scheme for e-waste of collection group 3 ................42
Figure 11: Label to be put on EEE in Europe indicating the necessity of separate
collection (WEEE Directive 2003, ElektroG 2005) .....................................................44
Figure 12: Responsibilities of the clearing house EAR and the individual producers 46
Figure 13: Interaction of individual producers and the clearing house ......................47
Figure 14: Interplay of PuWaMA, clearing house, producers and EoL service
providers ..................................................................................................................51
Figure 15: EEE put on market, and e-waste reported as collected and treated in
Germany (based on BMU 2011) ...............................................................................53
Figure 16: Categories of EEE put on the German market and collected from 2006 to
2008..........................................................................................................................55
Figure 17: EEE put on the German market and collected in kg per inhabitant and year
.................................................................................................................................56
Figure 18: Collection rates of e-waste from private households in Europe in 2008 ...58
Figure 19: Rear part of a flat panel display with broken backlights ............................61
Figure 20: End-of-life cost of e-waste in Germany (September 2010) .......................66

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Figure 21: Reimbursement model providing collection incentives .............................72
Figure 22: Overview on e-waste treatment ................................................................76
Figure 23: Example of shares of different metals in a low grade (top) and a high grade
printed wiring board; percentages missing to 100 %: epoxy resin, glass fibres, plastics
and other metals (Deubzer 2007) ..............................................................................78
Figure 24: Recycling rate of metals from e-waste copper fractions (Deubzer 2007) ..80
Figure 25: Example of pre-processing with shredding and mechanical separation

(EMPA, Switzerland; modified) ..................................................................................82
List of Tables
Table 1: Electrical equipment in West German households in 1988 (Hampel 1991) ..25
Table 2: E-waste collection groups in Germany (Espejo 2011, modified) ..................36
Table 3: EEE put on market in Germany, and collection and treatment of e-waste (BMU
2011) .........................................................................................................................52
Table 4: Collection rate for e-waste from private households ....................................57
Table 5: Rates for recovery, recycling and reuse of e-waste in Germany in 2008
(BMU 2011) ..............................................................................................................59
Table 6: Recycling rates for gold, silver and palladium with removal and direct
treatment of PM-rich components in copper smelters (Schöps 2010)........................83
9
List of Definitions
Collection group
One or more categories of e-waste collected in one container according to the
(ElektroG 2005)
Category of electrical and electronic equipment (EEE)

Category of EEE according to Annex IA of the (WEEE Directive 2003)
Disposal
Any operation, which is not recovery even where the operation has as a secondary
consequence the reclamation of substances or energy. Annex I of (Waste Directive
2008) sets out a non-exhaustive list of disposal operations. (WEEE Directive 2008)
Distributor
Any person or legal entity that provides new electrical or electronic equipment on a
commercial basis to the user. Any distributor who knowingly sells new electrical and
electronic equipment from a non-registered producer is deemed a producer.
(ElektroG 2005)
End-of-life full service provider (ESP)

An entity providing services related to the end of life of electrical and electronic
equipment. This may comprise operative services such as logistics, storage,
treatment, and disposal, as well as administrative services like producer registration
at the clearing house, and reporting to the clearing house
Extended producer responsibility (EPR)

Inclusion of further life cycle phases of a product beyond the manufacturing and the
safety and reliability in use into the producer’s responsibility; in the context of the
WEEE Directive inclusion of the end-of-life of products into the producer’s
responsibility
E-waste
Electrical and electronic equipment in its end-of-life phase starting from the time
when the last user disposes of or intends to dispose of electrical and electronic
equipment
E-waste from private households

E-waste, which comes from private households and from commercial, industrial,
institutional and other sources which, because of its nature and quantity, is similar to
that from private households
10
Monopsony
Market with one buyer, but many sellers of a certain product or service, a form of
incomplete competition
Producer
Any person or legal entity, irrespective of the selling technique used, including
distance communication, who (ElektroG 2005)
 manufactures and places electrical and electronic equipment under an

own brand on the market for the first time in Germany
 resells under an own brand in Germany equipment produced by other
suppliers. A reseller is not being regarded as the 'producer' if the brand
of the producer appears on the equipment
 imports for the first time electrical and electronic equipment into
Germany and places it on the market or exports it to another EU
Member State and provides it directly to a user in that country
Recovery
Any operation the principal result of which is waste serving a useful purpose by
replacing other materials which would otherwise have been used to fulfill a particular
function, or waste being prepared to fulfill that function, in the plant or in the wider
economy. Annex II of (Waste Directive 2008) sets out a non-exhaustive list of
recovery operations. (Waste Directive 2008)
Recycling
Any recovery operation by which waste materials are reprocessed into products,
materials or substances whether for the original or other purposes. It includes the
reprocessing of organic material but does not include energy recovery and the
reprocessing into materials that are to be used as fuels or for backfilling operations.
(Waste Directive 2008)
Small e-waste appliance

E-waste from small domestic electrical and electronic equipment, such as electrical
shavers, mixers, toasters, coffee machines, mobile phones, radios
Treatment
Any activity after the e-waste has been handed over to a facility for preparation for
re-use, depollution, disassembly, shredding and mechanical separation, recovery or
preparation for disposal and any other operation carried out for the recovery and/or
the disposal of the e-waste (WEEE Directive); collection, transport and storage are
not part of the treatment
11
Type of equipment
Equipment within a category of electrical and electronic equipment, which has
comparable characteristics in terms of its uses or functions; examples for types of
equipment in the 10 categories of EEE are listed in Annex IB of the (WEEE
Directive), and Annex I of the (ElektroG 2005)
12
List of Abbreviations
B2B business to business
B2C business to consumer
CG collection group
CTS collective takeback scheme
EEE electrical and electronic equipment
EoL end of life
ESP end-of-life full service provider
EPR extended producer responsibility
EU European Union
FCA “Bundeskartellamt”, Federal Cartel Authority
FNA “Bundesnetzagentur”, Federal Network Agency
GDR German Democratic Republic
ICT information and communication technology
IBTS individual brand-selective takeback scheme
INTS individual non-selective takeback scheme
PBB Polybrominated biphenyls
PBDE Polybrominated diphenyl ethers
PCB polychlorinated biphenyls
PM precious metal (gold, silver)
PoM put on market
PuWaMA public waste management authorities
PWB printed wiring board
UBA “Umweltbundesamt”, Federal Environment Agency

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1 Executive Summary
In 2008, around 10 million tonnes of electrical and electronic equipment (EEE) were
put on the markets of the European Union member states. With some delay, the
amounts of waste from these devices, the e-waste, has grown as well to the
magnitude of around 10 million tonnes a year, and according to (Huisman 2007), the
amount of EEE sold in the EU still grows with 2.5 % to 2.7 % every year. As a
reaction, in order to environment-friendly collect and treat the e-waste, the (WEEE
Directive 2003) was enacted in the EU in 2003. It extends the producers’
responsibility towards the end of life of their products and sets minimum targets for
collection, recovery and recycling of e-waste.
The EU member states transposed the WEEE Directive into their national legislations.
The member states have certain freedoms in how they transpose and implement the
provisions of the WEEE Directive so that each member state has individual e-waste
legislation with the WEEE Directive as the common denominator.
This report describes the German e-waste management system in the European
context. It explains the key players and their roles, shows the performance of the
system, and discusses the positive and negative experiences obtained during the five
years operation of the German e-waste management system.
Prior to the WEEE Directive, Germany collected and treated e-waste within the
legislative and infrastructural framework for wastes. The public waste management
authorities (PuWaMA) were responsible for the collection and treatment of e-waste,
and consumers were charged for its treatment and disposal.
The (ElektroG 2005), the German transposition of the (WEEE Directive 2003), shifted
responsibilities to the producers. Since 2006, consumers can bring e-waste free of
charge to the municipal collection points. The PuWaMA are further on responsible for
collection. Their responsibility ends with the handover of the collected e-waste to the
producers who organize and finance the logistics, treatment and disposal of this
waste.
Each producer putting EEE on the German market is responsible to take back the
amounts of e-waste corresponding to his market share in the EEE put on the market
(PoM). Producers establish takeback systems or otherwise organize the takeback of
the e-waste. Different from most other EU member states, collective takeback
systems are not common in Germany. Producers normally directly contract end-of-life
service providers (ESPs) organizing the logistics, treatment and disposal of e-waste,
for which each producer is responsible in accordance to his market share in PoM.
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The German e-waste management system exceeds the minimum collection, recovery
and recycling targets stipulated in the (WEEE Directive 2003). Nevertheless,
Germany collects less than 50 % of e-waste arising, and treatment operators
complain about the quality of collection because of damaged e-waste hindering
proper treatment. The collection of e-waste needs better financing mechanisms to
increase the rates and quality of collection. Higher collection rates could also help
reducing the illegal transboundary shipments of e-waste to developing countries,
which are a persisting problem in Germany like in all other developed countries.
The treatment operators are audited and certified annually by third party auditors in
order to ensure they have adequate technology, knowhow and organization for a
state-of-the-art treatment of e-waste. It is, however, difficult to prove whether
treatment operators actually make use of their abilities in daily operation. Competition
and cost pressure may compromise the treatment quality. Quality standards for the
treatment of e-waste are therefore upcoming instruments to increase the
transparency on the performance of treatment operators.
The treatment of e-waste requires excellent expertise and experience. The treatment
must be adapted to the type of e-waste processed in order to achieve an
economically and environmentally good result. Due to the high labor cost in Germany
and in most other European countries, the treatment is highly mechanized.
Nevertheless, environment-friendly treatment of e-waste requires a mix of manual
labor and high-tech processing of e-waste balancing the legislative and the
economical requirements.
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2 Background on Waste Management in Germany
Electrical and electronic equipment (EEE) since the fifties of the last century more
and more has influenced people’s lives in particular in the developed countries. In the
private and professional context, EEE until now progressively became an integral and
indispensable part of everyday life. In 2008, around 10 million tonnes of EEE were put
on the markets of the EU member states.1
Over the years, the amounts of waste from these devices, the e-waste, have grown
as well to the same magnitude of around 10 million tonnes a year in the EU.
According to (Huisman 2007), the amount of e-waste in the EU grows with around 2.5
to 2.7 % every year. E-waste is a highly variable mix of different types of equipment
ranging from washing machines to computers and mobile phones. The construction
and composition of EEE is highly complex. EEE contains toxic substances such as
lead and cadmium as well as scarce and valuable resources like precious metals. 2
Avoiding pollution and saving the valuable resources requires specific treatment of
the e-waste.
In the nineties of the last century, some member states and the European
Commission started thinking about how to appropriately collect and treat the
increasing amounts of e-waste. In 2003, this resulted in the enactment of the (WEEE
Directive 2002), which the EU member states transposed into their national
legislation. The WEEE Directive, however, allows the member states setting own
priorities in this transposition process so that each EU member state has its own
specific e-waste management system based on the WEEE Directive.
This report describes the German e-waste management system in the European
context. It explains the key players and their roles, shows the performance of the
system, and discusses the positive and negative experiences obtained during the five
years operation of the German e-waste management system.
1
Eurostat: http://epp.eurostat.ec.europa.eu/portal/page/portal/waste/data/wastestreams/weee;
last accessed 29 May 2011
2
StEP-Initiative, What is e-waste?, http://www.step-initiative.org/initiative/what-is-e-waste.php;
last accessed 25 June 2011
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2.1 Political and Administrative Competences and

Responsibilities for Waste Management in Germany
In Germany, the responsibilities and roles of the Federal and states Governments and
other public authorities for the management of e-waste and other wastes is
interlinked. Understanding the e-waste management in Germany hence requires
some background on the political and administrative construction as well as on the
competences and responsibilities in waste management.
Figure 1 provides an overview on the administrative and political structure in

Germany.
3
Figure 1: Outline of Germany’s administrative and political structure
Germany is a federal republic with the Federal Government in Berlin, the federal
capital city. The federation consists of 16 “Bundesländer“ (federal states), which have
their own governments and parliaments. Below the federal level, the administrative
3
Ernst Klett Verlag GmbH, Stuttgart: Online-Magazin Politik/Wirtschaft;
http://www.klett.de/sixcms/list.php?page=miniinfothek&node=Deutschland+-
+Politisches+System&miniinfothek=Online-
Magazin%20Politik/Wirtschaft&article=Infoblatt+Administrativer+Aufbau+der+Bundesrepublik+
Deutschland; last accessed 11 May 2011; in German language only
17
and political structure differs between the federal states. Rural and urban districts, as
well as cities and municipalities, however, are common administrative units.4
Legislative Competences of the Federal Government and the Federal States
Both the Federal Government and the federal state governments have legislative
competences, which are specified in the “Grundgesetz” (Basic Constitutional Law),
the constitution of the Federal Republic of Germany.5
In some areas, such as foreign affairs and defense, the Federal Government has the
exclusive legislative competence. In other affairs such as education and culture, the
sole legislative competence is with the federal states.6 In a broad range of affairs, the
Federal Government and the federal states share legislative competences 7:
 The federal government may enact framework legislation, which each federal
state then details and specifies with own legislation for its territory. This is the
case for example for water management and for nature conservation. The
resulting federal state legislation then differs between the 16 federal states.
 The concurrent legislation entitles the federal states to enact own legislation
unless the Federal Government makes use of its legislative competence. The
federal legislation then overrides the federal states’ legislation. Since 1972,
waste management falls into the field of the concurrent legislative
competence.
4
5
Bundeszentrale für politische Bildung (BPB, Federal Center for Political Education): Infoblatt
Gesetzgebungskompetenzen (Info Sheet Legislative Competences;
http://www.bpb.de/files/QR63OR.pdf; last accessed 11 May 2011, in German language only
6
Bundeszentrale für politische Bildung (BPB, Federal Center for Political Education): Infoblatt
Gesetzgebungskompetenzen (Info Sheet Legislative Competences;
http://www.bpb.de/files/QR63OR.pdf; last accessed 11 May 2011, in German language only
7
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Roles and Responsibilities for Waste Management in Germany
In 1994, the Federal Government enacted the “Act for Promoting Closed Substance
Cycle Waste Management and Ensuring Environmentally Compatible Waste
Disposal” (Substance Cycle Act 1994), which still nowadays, with some amendments,
substantially and comprehensively regulates the waste management in Germany.
(Wuttke 2011)
The federal states implement the regulations of the federal Substance Cycle Act
(Wuttke 2011)
 appointing the competent authorities for the administrative implementation of

the Substance Cycle Act within the federal state, and
 appointing the public waste management authorities for the operative

implementation conducting the collection, transport, treatment and disposal of
wastes on local level.
On this behalf, each federal state enacted legislation enforcing the federal level
Substance Cycle Act. In all federal states, the rural and urban districts conduct the
treatment and disposal of the wastes, whereas the local collection and the transport
of wastes to the district recycling and disposal facilities in several federal states is the
cities’ and municipalities’ competence. (Wuttke 2011)
The rural and urban districts and the cities and municipalities complement the federal
state legislation with local regulations. These determine details such as the frequency
and other modalities of collection, the installation of municipal waste collection points,
how businesses and private households have to make their wastes available to the
public waste management authorities (PuWaMA), and the fees they have to pay for
the collection, treatment and disposal of their wastes. (Wuttke 2011)
As the ElektroG, the transposition of the WEEE Directive into German legislation,
appoints the PuWaMA as the competent authorities for the collection of e-wastes in
Germany, the implementation of the ElektroG uses the political and administrative
structure in Germany, and the Substance Cycle Act’s provisions apply to the
collection and storage of e-waste as well unless the ElektroG stipulates otherwise.
2.2 Management of Wastes from Private Households
Waste management in Germany is mainly based on the (Substance Cycle Act 1994)
and its enforcement regulations in the federal states. The public waste management
authorities (PuWaMA) generally are responsible for the collection, transport, proper
treatment and disposal of wastes. The Substance Cycle Act obliges private
19
households to make their wastes available to the PuWaMA. Private households are
not allowed to contract third parties for the collection, treatment and disposal of
wastes. This had actually happened for wastes, whose treatment or sales are
economically profitable, such as waste paper and the newly introduced “Valuables
Bins”. The German Federal Administration Court recently stopped this practice.8
Generally, the (Substance Cycle Act 1994) allows PuWaMA to contract third parties
for the collection, treatment and disposal of wastes. The responsibility, however,
remains with the PuWaMA. Several private companies meanwhile are active in the
collection and treatment of wastes throughout Germany.
Separation of Wastes in and at Private Households
German households separate their wastes into several categories. Even though there
may be differences between the districts and municipalities, common separation
categories are
 packaging materials (“Gelbe Tonne”, Yellow Bin, financed by producers using

packaging materials for their products)
 glass (different containers for white, green and brown glass)
 organic waste
 paper and cardboard
 residual waste (household waste other than the above ones)
Some municipalities are about to introduce an additional container (“Wertstofftonne”,

Valuables Bin9), into which private households can drop of metals, woods, textiles,
plastics that are not packaging materials, and small e-waste appliances such as
toasters, mixers, shavers, mobile phones, after removal of the batteries. Further
8
Federal Administrative Court decree BVerwG 7 C 16.08,
http://www.bverwg.de/enid/0,ff33a4655f76696577092d0964657461696c093a09636f6e5f6964
092d093132313738093a095f7472636964092d093133333232/Entscheidungen/Entscheidung
_8n.html, and http://www.kostenlose-urteile.de/BVerwG-Kampf-ums-Altpapier-Entsorgung-
grundsaetzlich-durch-oeffentlich-rechtlichen-Entsorgungstraeger.news8025.htm; last
accessed 6 May 2011; both sources in German language only
9
http://www.bmu.de/abfallwirtschaft/abfallpolitik/kreislaufwirtschaft/doc/47205.php; last
accessed 16 May 2011, in German language only
20
approaches are to allow private households the disposal of small e-waste appliances
and other valuable materials together with packaging materials in the Yellow Bins10.
The residual waste containers generally are located on private premises at the
households, while the other containers may sometimes be placed on public places
close to the households instead.
Pickup of Wastes under Public Authority
The PuWaMA pick up residual waste containers and other containers – besides those
for the packaging materials - directly at the households and from the public places
(collect system). Each household pays an annual fee for this service to the
municipalities, at least for the residual waste container. The fees are different in the
various municipalities, but they generally depend on the volume of the container. For
the other containers, there may be payments as well depending on the PuWaMA.
Besides the collect systems, PuWaMA additionally run municipal collection points
where consumers can hand in specific wastes like bulky objects, furniture, carpets,
chemicals, and all kinds of e-waste (bring system).
Some municipalities offer household collections of such specific items from time to
time. They announce the date, and private households can place their waste items on
the street for pickup. Private households can also call up the municipal waste
collection authorities to pick up items from their household. This service normally has
to be paid for.
Wastes Collected and Treated under Producer Responsibility
Packaging materials in the “Yellow Bins” are collected, treated and disposed of under
the responsibility of Dual Systems. Manufacturers using packaging materials for
products put on the German market pay a fee for the collection, treatment and
disposal of the packaging materials to one of the Dual Systems11. Producers integrate
these fees into the product price at the point of sale.
Batteries are not allowed in any of the described waste containers. Consumers shall
hand them in free of charge to shops selling batteries, or at special collection points.
Producers have established a collective takeback system for the takeback, treatment
10
Gelbe Tonne Plus, http://www.gelbe-tonne-plus.de/; last accessed 16 May 2011, in German
language only
11
List of officially acknowledged Dual Systems in Germany (https://www.ihk-ve-
register.de/inhalt/duale_systeme/index.jsp); last accessed 9 May 2011
21
and disposal of these batteries (GRS Batterien12) to comply with the (Battery Act
2009), the transposition of the European (Battery Directive 2006) into German
legislation.
Since March 2006, e-waste in Germany is managed under the shared responsibilities
of the PuWaMA and the producers, while before e-waste management was the
PuWaMA’s sole responsibility.
2.3 Milestones of Waste and e-Waste Management in

Germany
The history of e-waste management in Germany must be considered together with

the general waste management, as until 2005 no e-waste specific legislation was in
place. Until the reunification of the Federal Republic of Germany (West Germany) and
the German Democratic Republic (GDR, East Germany), each of the German states
had its own legislation for waste management. Starting with the reunification on 3
October 1990, the West-German legislation including the waste management was
gradually transferred to the territory of the former GDR. The following sections will
therefore focus on West Germany.
2.3.1 Waste Management before 1972
Waste management including e-waste has been the responsibility of the

municipalities. There was not much awareness of the pollution and resource
implications related to wastes. Still in the early seventies of the last century, wastes
from private households and from businesses, including hazardous wastes, were
dumped untreated on around 50,000 (Wuttke 2011) municipal landfills in West
Germany. Many of these landfills were unsecured. (Wuttke 2011)
The use of small and big domestic electrical appliances such as washing machines
and refrigerators in private households, even though started in the early fifties
already, had taken off in the late sixties (Handrick 2004). Electronic devices beyond
12
Stiftung Gemeinsames Rücknahmesystem Batterien (GRS Batterien), http://www.grs-
batterien.de/; in German language only; last accessed 8 May 2011
22
TVs, radios and tape recorders, later stereo equipment and video players, were not
common in the households. The volumes of e-waste hence must have been low in
the fifties until the early seventies. Statistics on this could not be found.
Weekly collection of household wastes by districts or municipalities was not yet

common everywhere in Germany. At least on the countryside, it sometimes was
limited to collection of bulky objects a few times a year (“Sperrmüllabfuhr“), which
were then disposed of untreated on landfill sites as well.
E-waste including accessories such as batteries was collected and disposed of

untreated with other wastes on the landfills. The author still experienced on the
countryside side in West Germany how at least until the early seventies households
disposed of all kinds of wastes such as household wastes, construction wastes, and
bulky objects. This included all kinds of e-waste like old fridges and freezers, washing
machines, electrical ranges, TVs, and radios.
2.3.2 The 1972 and 1986 Waste Management Acts
In 1972 in West Germany, after an amendment of the constitution, waste

management became subject to concurrent legislation. The Federal Government thus
for the first time was in a position to enact waste legislation for the whole of West
Germany. The Federal Government made use of this new competence with the
adoption of the Waste Management Act in 1972. The main objective was to stop the
uncontrolled waste dumping in the German municipalities and districts. The act hence
was designed as a regulation for organizing and planning the disposal of wastes.
(Wuttke 2011) Treatment and recycling of wastes were not specifically addressed.
The act clearly regulated the responsibilities for waste management, and in
consequence, the number of landfills was reduced. In 1998, only 2.341 landfill sites
were still in operation in the then reunited Germany. (Wuttke 2011)
In 1986, the Federal Act on Prevention and Disposal of Wastes was enacted, which
for the first time stipulated basic principles for the prevention, treatment and recycling
of wastes. E-waste still was not addressed in particular. (Wuttke 2011)
The 1986 act entitled the Federal Government to enact further regulations for
prevention and recycling in order to reduce the amounts of wastes. The packaging
ordinance as the regulative background for the German Dual Systems for packaging
materials is an example for such measures. (Wuttke 2011)
23
2.3.3 Waste Management in East Germany until 1990
Amounts of Waste and Recycling
Compared to West-German households, the amounts of domestic waste generated in

the GDR was low.13 The GDR had established a system for collection and recycling,
SERO, where consumers could hand in waste such as old paper, textiles, glass,
bottles, metals and plastics.14 The East-German Government strongly promoted the
system. Persons handing in wastes were paid. On small scale, children generated a
pocket-money level income, and small private businesses collected wastes on large
scale level.
15
Figure 2: Logo of the “VEB Kombinat Rohstofferfassung” SERO in the GDR
Compared to West Germany, the SERO system was more successful in collecting
and recycling wastes. The background was that the East-German currency was not
convertible on the world market. Raw materials hence had to be purchased in foreign
convertible currencies and were hence scarce and expensive. After the reunification,
under the new economic conditions, the SERO system became too expensive and
was not continued.
13
Umweltbewegung in der DDR, http://umwelt-ddr.argus-potsdam.de/index.php?abfall, last
accessed 22 June 2011, in German language only
14
15
Wikipedia, http://de.wikipedia.org/wiki/SERO, last accessed 22 June 2011, in German
language only
24
Disposal of Waste
The disposal of wastes was the main problem of waste management in the GDR. The
landfill sites had a low environmental and security standard until the end of the GDR
in 1990. The disposal sites often were openly accessible, leachate water was not
collected and cleaned. Groundwater contaminations were common. In 1985, 4,870
controlled landfills were counted in the GDR, of which only 920 complied with the low
standards, and 7,437 unsecured landfills. The landfills were often located close to
rivers or in areas from which drinking water was pumped. Imports and disposal of
hazardous wastes, for example from West Germany, aggravated the problem. Even
though the GDR did not have the capacities for adequate treatment and disposal, it
imported around 5 million tonnes of wastes including hazardous wastes from West
Germany. East Germany made “hard currency” money with these imports, and West
Germany saved money with these exports. 16
With the reunification, however, the East-German landfill problem befell the West
Germany, and the reunified Germany invested billions of Euros, among others for the
sanitation of the East-German landfills.
No information on e-waste specific waste management activities in the GDR could be

found. Taking into account that in West Germany such measures started in the late
eighties of the last century only after the discovery of the ozone hole, it must be
assumed that the first e-waste-specific attempts on former East-German territory
already were undertaken after the reunification.
2.3.4 The Discovery of the Ozone Hole and First E-waste Management
Activities
In 1974, (Molina 1974) had published his research results about the ozone depletion
effects of chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs). This
important research had only gained wider publicity when the stratospheric ozone hole
was discovered in 1985. 17
The use of CFCs and HCFCs as cooling agents and as propellants in plastics was
state of the art before their use was restricted in the Montreal Protocol signed in
16
17
See http://www.antarctica.ac.uk/press/press_releases/press_release.php?id=66; last
accessed 8 May 2011
25
1987 18. Table 1 illustrates that almost every West German household was equipped
with a refrigerator in 1988, and two thirds of the households had a freezer.
Table 1: Electrical equipment in West German households in 1988 (Hampel 1991)
Type of Equipment Prevalence in Private Households
Refrigerator 98 %
Vacuum Cleaner 98 %
Electric Iron 96 %
Washing Machine 91 %
Electric Hand Mixer 86 %
Coffeemaker 85 %
Electric Cooker 77 %
Freezer 66 %
Dish Washer 29 %
Tumble Dryer 18 %
In the late eighties and early nineties, as first e-waste specific activities the German
PuWaMA started collecting and treating cooling and freezing equipment to prevent
stratospheric ozone depletion.
2.3.5 The 1994 Substance Cycle and Waste Management Act
In the early nineties, the Federal Government had to transpose the European Waste
Framework Directive and the European Directive on Hazardous Waste into German
waste legislation. On this opportunity, the waste management was further developed
from linear substance flows towards substance cycles. The 1994 “Act for Promoting
Closed Substance Cycle Waste Management and Ensuring Environmentally
Compatible Waste Disposal” (Substance Cycle Act 1994) targeted natural resource
18
See http://www.epa.gov/Ozone/intpol/; last accessed 8 May 2011
26
conservation and environment-friendly treatment and disposal of wastes. (Wuttke

2011)
Corner Stones of the 1994 Substance Cycle Act
Corner stones of this new legislation were the extended producer responsibility
towards the end of life of products, and the partial reorganization of the
responsibilities with more possibilities for privatization in the collection, treatment and
disposal of wastes. The producer responsibility principle was intended motivating
producers to adapt the design of their products to the requirements of a substance
cycle economy. The producer responsibility was, however, not enacted automatically
for all products with the enactment of the Substance Cycle Act, but required further
specific regulation. (Wuttke 2011)
Still nowadays, the Substance Cycle Act including some amendments is the main
base of waste management in Germany. E-waste was not yet addressed specifically
in the Substance Cycle Act. Nevertheless, this regulation was the base for the
collection, treatment and disposal of e-waste between 1994 and 2006, prior to the
enactment and implementation of the European WEEE Directive in Germany.
E-Waste Management until March 2006
Consumers could hand in e-waste at the municipal collection points. Some PuWaMA
also collected e-waste from private consumers, either periodically or on demand. The
municipalities then were responsible for the environment-friendly treatment and
disposal according to the principles of the (Substance Cycle Act 1994). Depending on
the municipalities, they handed over part or all the e-waste to private treatment
operators, or conducted the treatment fully or partially themselves. Charity and other
non-profit and mostly small profit organizations were also active in the field repairing
and refurbishing used EEE such as washing machines, refrigerators, TVs, later also
computers. They received such equipment from the PuWaMA, or sometimes
collected it themselves attracting consumers to hand the equipment over to them. The
used equipment was donated to schools (computers), and/or sold in second hand
shops. Figure 3 illustrates the system.
Private consumers generally had to pay fees at the municipal collection point when
handing in e-waste, at least for those types of equipment where the sales of the
recycled materials could not cover the cost of treatment and disposal.
27
19
Figure 3: E-waste management in Germany until 2006
Cooling and freezing equipment was exchanged old-for-new at the customer on

delivery of a new refrigerator or freezer. This service was free of extra charge for the
customer.
2.3.6 The European WEEE Directive and the German “ElektroG”
Reacting on the growing amounts of e-waste from electrical and electronic equipment
(EEE), and the increasing integration of the European market, the European WEEE
Directive was enacted in 2003. The WEEE Directive and its implementation into
19
Gabriele Markmann-Werner, Ministry of Environment and Climate Protection of Lower
Saxonia, Germany; modified
28
German national legislation, the “ElektroG” in 2005 marked an important further

milestone for the management of e-waste in Germany.
Responsibilities for E-Waste in the European WEEE Directive
The WEEE Directive’s scope covers 10 categories of electrical and electronic

equipment (EEE) as defined in Annex IA of the (WEEE Directive 2003):
1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools (with the exception of large-scale stationary

industrial tools)
7. Toys, leisure and sports equipment
8. Medical devices (with the exception of all implanted and infected products)
9. Monitoring and control instruments
10. Automatic dispensers
Responsibilities of Member States
The member states of the European Union (EU) shall make sure that the e-waste
from the above ten categories of EEE is collected and treated separately. As a
minimum, each member state must achieve an annual collection rate of 4 kg per
inhabitant from 2006 on. Some member states, in particular the new Eastern
European members, had more time to match with this minimum rate. Moreover,
member states must ensure that collection facilities are available and accessible for
final users and distributors, where they can hand in e-waste from private households
free of charge.
29
Responsibilities of Distributors
When supplying a new product, distributors shall ensure that end users can return
waste from such products to the distributor at least free of charge on a one-to-one
basis. This obligation applies as long as the waste equipment is of equivalent type
and has fulfilled the same functions as the newly supplied equipment. Member
States, however, may depart from this provision if returning the WEEE is not thereby
made more difficult and remains free of charge for the final holder.
Responsibilities of Producers
The WEEE Directive is based on the core principle of producer responsibility.

According to (WEEE Directive 2003) “[…] producer responsibility is one of the means
of encouraging the design and production of electrical and electronic equipment
which take into full account and facilitate their repair, possible upgrading, reuse,
disassembly and recycling.”
The core idea behind the producer responsibility approach is that producers will try to
minimize the end-of-life (EoL) cost of their products, if they have to organize and
finance collection and treatment of the waste from the EEE they put on the market.
Producers can influence the EoL-cost of their products by Design for End-of-Life. The
producer responsibility thus is assumed to make producers optimizing the product
design for the EoL of their products. Figure 4 illustrates the principle.
Figure 4: Financial incentives driving Design for EoL in producer responsibility
EoL end of life

30
A measure of design for EoL could be to make components and substances easily
accessible that need to be removed from e-waste prior to further treatment according
to Annex II of the (WEEE Directive 2003). Designing LCD flat panel displays that
contain mercury backlights, for example, so that they can be removed more easily
and quickly, would save expensive labor and thus reduce the EoL cost for this
equipment. Such cost incentives would hence drive producers to continuously
improve the design for EoL of their products, if the producers have to finance the EoL
of their products.
Producer responsibility according to the (WEEE Directive 2003) comprises the

following operational and financial aspects:
 Producers shall set up systems for the treatment of e-waste using best
available treatment techniques.
 Producers shall at least finance the collection, treatment and environmentally

sound disposal of e-waste from private households disposed of at collection
facilities.
 Each producer shall finance the treatment of the waste from its own products
put on the market after 13 August 2005.
Producers can choose to fulfill their above obligations either individually or by joining
a collective scheme.
Additionally to the above obligations, producers have to comply with further

requirements:
 Each producer must provide a guarantee when placing a product on the

market to ensure that the collection, treatment and disposal of this product will
be financed. The guarantee may take the form of the producer’s participation
in appropriate schemes for the financing of the management of WEEE, a
recycling insurance or a blocked bank account.
 Producers must clearly mark the products they put on the market after 13
August 2005 with the symbol shown in Figure 5.
31
Figure 5: Symbol for the marking of electrical and electronic equipment according to (WEEE
Directive 2003)
 Producers must achieve certain minimum targets for recovery and recycling of
the e-waste collected separately. These targets vary depending on the
category of EEE in Annex IA of the WEEE Directive. Figure 6 on page 31
details the requirements.
Figure 6: Minimum recovery and recycling targets for separately collected e-waste
Recovery and recycling are defined in the (Waste Directive 2008). Recovery means
any operation the principal result of which is waste serving a useful purpose. Waste
may replace other materials, which otherwise would have been used to fulfill a
particular function, or it may be prepared to fulfill that function, in the plant or in the
wider economy.
32
Recycling is any recovery operation reprocessing waste into products, materials or

substances whether for the original or other purposes. Recycling does not include
energy recovery and the reprocessing into materials that are to be used as fuels or for
backfilling operations. (Waste Directive 2008)
Annex II of the (WEEE Directive 2003) stipulates the selective treatment of specific
materials and components of e-waste. These provisions comprise
 the removal of certain substances, preparations and components from

separately collected e-waste, and
 the specific treatment of certain e-waste components.
These specific operations shall be conducted without hindering the reuse of

components or entire devices.
European directives like the WEEE Directive do not apply directly to the member
states. The member states must transpose them into national legislation. The
member states have certain freedoms how they implement the provisions of the
WEEE Directive resulting in implementation differences between the EU member
states.
Transposition of the WEEE Directive into German Legislation – the ElektroG
The German e-waste management is based on the Act Governing the Sale, Return
and Environmentally Sound Disposal of Electrical and Electronic Equipment (ElektroG
2005). The ElektroG is the transposition of both the European (WEEE Directive 2003)
and of the European (RoHS Directive 2003) into German national legislation. The
ElektroG entered into force on 13 August 2005. Some e-waste-related stipulations,
such as the operation of the takeback systems, however, were delayed to 23 March
2006. The restriction of the hazardous substances entered into force on 1 July 2006,
as foreseen in the (RoHS Directive 2003).
Priorities for the Implementation of the WEEE Directive in Germany
The implementation of the (WEEE Directive 2003) into the German (ElektroG 2005)
was influenced by the experiences made with another producer responsibility
scheme. The “Duales System Deutschland” (DSD), the organization responsible for
the collection, treatment and disposal of packaging materials, from the time of its
introduction in 1990 until recently was a monopoly. Industry complained about high
prices as a consequence.
33
This experience resulted in the following implementation priorities:
 Promotion of competition
The e-waste management system shall avoid monopolies, and allow
producers maximum freedom to decide how to comply with their extended
producer responsibility (EPR).
 Prevention of freeriders
The system shall ensure that all producers contribute to the treatment and
financing of the e-waste in proportion to their market share in Germany.
 Prevention of cherry picking

Each producer must collect from all over Germany thus avoiding that some
producers focus on bigger cities, while other producers have to collect from
rural areas with high logistics cost.
The stipulations of the ElektroG will be explained in chapter 3 describing the German
e-waste management system.
2.3.7 Recast of the WEEE-Directive
The still ongoing recast of the WEEE Directive will mark the next milestone for e-
waste management in Germany. The European (Commission 2008), the (European
Parliament 2011) and the European (Council 2011) have submitted proposals for the
revision of the WEEE Directive. No political agreement could be achieved yet
between these institutions of the European Union and the member states. Based on
the above-mentioned different proposals presented, the following important
amendments may be expected:
 Open scope
While the scope of the current (WEEE Directive 2005) is limited to the 10
categories in its Annex I, the new WEEE Directive will probably have an open
scope covering all electrical and electronic equipment (EEE) with few
exclusions only.
 Increased minimum collection target

The current collection target of four kilograms per year and inhabitant in each
member state will probably be amended. A certain percentage of the average
amounts of EEE put on the market in each member state in the preceding
years may have to be collected in each member state. Alternatively, the e-
waste arising in each member state is proposed as a reference for the
percentages of collection. The collection targets might also be differentiated
34
depending on the environmental relevance of the various types of equipment

resulting in higher collection targets for environmentally more relevant types of
e-waste.
 Increased minimum targets for reuse, recovery and recycling

The minimum targets for recovery and recycling (see Figure on page 31) will
probably be increased. Possibly, an additional minimum target for reuse of
entire devices will be introduced.
 Financing of collection
Consumers, distributors and producers together may have to finance a certain
fee at the point of sale, which the PuWaMA or other parties responsible for
collection may then use for the collection of e-waste, improving the collection
infrastructure, and for awareness raising campaigns. Alternatively, member
states may oblige producers to take over more financial responsibility for the
e-waste collection directly from private households.
 Harmonization of registration and reporting

The registration of producers in the member states may be simplified. Via
interoperable registers, registration in one member state may be sufficient to
be registered in all member states. Producers’ reporting obligations to the
member states may be harmonized in terms of reporting frequencies and
formats.
 Prevention of Illegal Exports

Exporting e-waste from EU member states to developing countries is illegal,
but still ongoing. In the face of the severe environmental and health impacts of
e-waste treatment in the developing countries, the European Commission, the
Council and the Parliament all promote provisions to stop illegal exports of e-
waste in their recast proposals for the WEEE Directive.20 Testing certificates
proving that the exported used electrical and electronic equipment is still
functional and other accompanying documentation shall help to differentiate
the illegal exports of waste from the legal shipments of used EEE for reuse.
The next important step in the political process is the European Parliament’s plenary
session voting on the recast WEEE Directive, probably on 30 November 2011.21
20
European Parliament Legislative Observatory,
http://www.europarl.europa.eu/oeil/file.jsp?id=5723502; last accessed 15 May 2011
21
European Parliament Legislative Observatory,
http://www.europarl.europa.eu/oeil/file.jsp?id=5723502; last accessed 15 May 2011
35
3 E-waste Management in Germany According to the

ElektroG
The following sections will explain the key players’ responsibilities and the
possibilities of compliance the ElektroG provides.
3.1 Key Players and their Roles
The key players in the operation of the German e-waste management system are:
 the public waste management authorities (PuWaMA, public),
 the producers of electrical and electronic equipment (private),
 the clearing house EAR (private with governmental authorization).
Further important players are the retailers and the consumers, even though the
(ElektroG 2005) does not assign them specific responsibilities.
3.1.1 The Public Waste Management Authorities
Collection of E-waste from Private Households
According to the (ElektroG 2005), the public waste management authorities

(PuWaMA) are responsible for the collection of e-waste. They must set up collection
points in their districts to which final holders and distributors may return e-waste from
private households in the vicinity (bring back system). The municipalities must not
36
levy any charges to the consumers for such e-waste returns to the collection points.
The number of collection points depends on the population density and the local
conditions. The PuWaMA may also collect WEEE directly from private households
(collection system), but the ElektroG does not make this obligatory.
The PuWaMA may refuse to accept e-waste if it is contaminated in such a way as to

pose a safety risk or a hazard to human health. The same applies to the delivery of
more than 20 pieces of equipment in EEE categories 1 to 3. Such deliveries must be
coordinated with the public waste management authorities. (ElektroG 2005)
Commercial collection by private collectors is not allowed. The PuWaMA, however,

may delegate the collection to third parties, which may be private companies. The
final accountability, however, remains with the PuWaMA. (Koch 2011) The
involvement of private companies in the collection of e-waste thus is decided on the
district and municipal level and may therefore differ from district to district.
Collection Groups
The (ElektroG 2005) differentiates the EEE into the same 10 categories with the
same types of equipment like the (WEEE Directive 2003). Like in the WEEE Directive,
the listing of equipment types under each of the categories is not exclusive, but just
gives examples of types of equipment.
The ElektroG requires the PuWaMA to collect and store the e-waste arising from
these 10 categories of EEE in five collection groups as shown in Table 2.
Table 2: E-waste collection groups in Germany (Espejo 2011, modified)
Corresponding
Collection
category of EEE
group Example types of equipment
(Annex I ElektroG 2005
(ElektroG according to (Annex I ElektroG 2005, WEEE Directive 2003)
and WEEE Directive
2005)
2003)
Washing machines; clothes dryers; dish washing machines; cooking electric stoves;
electric hot plates; microwaves; other large appliances used for cooking and other
Large Household
1 processing of food; electric heating appliances; electric radiators; other large
Appliances
1 appliances for heating rooms, beds, seating furniture; electric fans; air conditioner
appliances; other fanning, exhaust ventilation and conditioning equipment
Automatic Automatic dispensers for hot drinks, hot or cold bottles or cans, solid products or
10
Dispensers money; all appliances which deliver automatically all kind of products
Large Household Large cooling appliances; refrigerators; freezers; other large appliances used for
2 1
Appliances refrigeration, conservation and storage of food
Centralized data processing: mainframes, minicomputers, printer units;
Information and
personal computing: personal computers (CPU, mouse, screen and keyboard
3 3 Telecommunication
included), laptop computers (CPU, mouse, screen and keyboard included), notebook
Equipment (ICT)
computers, notepad computers, printers; copying equipment; electrical and electronic
37
typewriters; pocket and desk calculators; other products and equipment for the
collection, storage, processing, presentation or communication of information by
electronic means; user terminals and systems; facsimile; telex; telephones; pay
telephones; cordless telephones; cellular telephones; answering systems; other
products or equipment of transmitting sound, images or other information by
telecommunications
Radio sets; television sets; video cameras; video recorders; hi-fi recorders; audio
Consumer amplifiers; musical instruments; other products or equipment for the purpose of
4
Electronics recording or reproducing sound or images, including signals or other technologies for
the distribution of sound and image than by telecommunications
Luminaries for fluorescent lamps with the exception of luminaries in households,
straight fluorescent lamps, compact fluorescent lamps (“energy saving lamps”), high
4 5 Lighting Equipment intensity discharge lamps, including pressure sodium lamps and metal halide lamps,
low pressure sodium lamps, other lighting or equipment for the purpose of spreading
or controlling light with the exception of filament bulbs
Carpet sweepers; other appliances for cleaning; appliances used for sewing, knitting,
weaving and other processing for textiles; irons and other appliances for ironing,
mangling and other care of clothing; toasters, fryers, grinders, coffee machines and
Small Household
2 equipment for opening or sealing containers or packages; electric knives; appliances
Appliances
for hair-cutting, hair drying, tooth brushing, shaving, massage and other body care
appliances; clocks, watches and equipment for the purpose of measuring, indicating
or registering time; scales
Drills; saws; sewing machines; equipment for turning, milling, sanding, grinding,
sawing, cutting, shearing, drilling, making holes, punching, folding, bending or similar
Electrical and processing of wood, metal and other materials; tools for riveting, nailing or screwing
6
Electronic Tools or removing rivets, nails, screws or similar uses; tools for welding, soldering or similar
use; equipment for spraying, spreading, dispersing or other treatment of liquid or
5 gaseous substances by other means; tools for mowing or other gardening activities
Electric trains or car racing sets; hand-held video game consoles; video games;
Toys, Sports and
7 computers for biking, diving, running, rowing, etc.; sports equipment with electric or
Leisure Equipment
electronic components; coin slot machines
Radiotherapy equipment; cardiology; dialysis; pulmonary ventilators; nuclear
medicine; laboratory equipment for in-vitro diagnosis; analyzers; freezers; fertilization
8 Medical Products
tests; other appliances for detecting, preventing, monitoring, treating, alleviating
illness, injury or disability
Monitoring and Smoke detectors; heating regulators; thermostats; measuring, weighing or adjusting
9 Control appliances for household or as laboratory equipment; other monitoring and control
Instruments instruments used in industrial installations (e.g. in control panels)
Each of the five collection groups is stored in a separate container at the municipal
collection points consuming space. The limitation to five collection groups hence is a
compromise allowing sufficient separation of e-waste with respect to efficient
treatment on the one hand, and taking into account the practicability at the municipal
collection points on the other hand.
38
Handover of E-waste to the Producers
The public waste management authorities hand over the e-waste in these five
different containers to the producers of EEE free of charge. The producers have to
provide the containers free of charge to the PuWaMA.
Each PuWaMA may choose, however, not to make the e-waste of a specific
collection group available to the producers. The PuWaMA must provide three months'
notice to the clearing house EAR and then enter into the producers’ obligations
including the recovery and recycling targets and the reporting obligations to the
clearing house EAR.
3.1.2 Producers
The ElektroG adopted the provisions on the extended producer responsibility of the
(WEEE Directive 2003). In Germany, like in most other EU member states, the
producer responsibility starts with the handover of the e-waste to the producers at the
municipal collection points, or with the takeover from distributors such as retailers.
Producer Takeback According to the ElektroG
The ElektroG leaves the producers three principle possibilities to take back e-waste.
Producers may set up individual brand-selective takeback schemes (IBTS), individual
non-selective takeback schemes (INTS) or join a collective takeback scheme (CTS),
as depicted in Figure 7.
39
Figure 7: Possibilities for producers to implement their extended producer responsibility in

Germany
ESP: EoL Service Provider
Producers normally will not operate the EoL of the e-waste themselves, but contract
end-of-life service providers (ESPs) for the logistics, treatment and disposal of the e-
waste. In IBTS and in INTS, the producers individually will make contracts with ESPs,
while CTS will take over this task, if the producer joins such a system.
In individual brand-selective compliance schemes, producers will only take back e-

waste of their own brands. On this behalf, they will need to make additional contracts
with the PuWaMA and possibly with the distributors taking back e-waste from private
consumers, as they must sort out the producers’ brands from e-waste collected. In
INTS and CTS, producers will have to take back all brands of e-waste in their
collection group according to each producer’s market share. The next section
describes the different takeback schemes in more details.
40
Takeback in the Different Producer Takeback Schemes
Individual Brand-Selective Takeback Schemes
A producer can set up an individual brand-selective takeback scheme (IBTS), which

then only assumes responsibility for e-waste of his own brands. As a result,
producers setting up an IBTS receive back and have to take care of their own brands
e-waste only. Figure 8 illustrates an IBTS for an example “Producer A” and his brands
of EEE put on the German market.
Figure 8: Individual brand-selective takeback scheme
An IBTS requires the PuWaMA to collect separately or sort out the e-waste of
producer A’s brands. The e-waste must then be stored separately after collection to
make it available to producer A’s ESPs. Alternatively, producer A may establish his
own collection point, where the PuWaMA and consumers may bring producer A’s
brands e-waste.
The producer will have to reimburse the PuWaMA for all additional efforts going
beyond the PuWaMA’s obligations, which are stipulated in the ElektroG.
The producer will directly contract one or several end-of-life full service providers
(ESPs). It is important to note, however, that the legal responsibility for the e-waste
always remains with the producer.
The producers are responsible for the amounts of e-waste collected according to their
market share in EEE put on the German market. The market share is calculated by
the clearing house EAR. The EAR will periodically assess whether the amount of e-
41
waste the producer collected in his IBTS corresponds to the amounts of e-waste the
producer has to collect and treat according to his market share. In case the producer
has collected less than its share, it has to pick up and treat the missing share
additionally.
Producers operating an IBTS take back e-waste of their own brands only, as long as
they collect the amounts of e-waste at least in accordance to their market share.
Individual Non-selective Takeback Schemes
For an individual non-selective takeback scheme (INTS), like for an IBTS, producers
will directly contract ESPs to organize and conduct the EoL of their products. Contrary
to an IBTS, however, the producer will not take back its own brand products only, but
just the share of e-waste that falls under his responsibility within each collection group
according to his market share.
Figure 9 below shows an example for such an INTS for a producer A putting products
of EEE category 3 and 4 on the German market. These products are collected in the
e-waste collection group 3.
Figure 9: Individual Non-selective Takeback Scheme
POM put on the market
The amounts of e-waste collected in the official e-waste management system are
lower than what is put on the market (POM). Each producer, however, must take care
of this collected e-waste based on his market share in POM. If producer A’s market
42
share in category 3 and 4 is 20 % in total, producer A must assume responsibility for

20 % of e-waste collected in collection group 3. The other 80 % of e-waste must be
taken care of by the other producers’ takeback schemes.
The PuWaMA collect and store the e-waste of category 3 in containers at their
municipal collection points. The content of these containers is composed of all
products of all producers’ brands collected in collection group 3 besides those brands
collected under individual brand-selective takeback schemes. Producers operating an
INTS therefore take back containers with e-waste of all producers that produce EEE
collected in the same collection group.
Collective Takeback Schemes
Several producers may set up a collective takeback scheme (CTS) to jointly organize
and finance the EoL of their EEE. Figure 10 shows an example CTS set up by two
producers A and B manufacturing ICT and consumer equipment (EEE categories 3
and 4).
Figure 10: Collective Takeback Scheme for e-waste of collection group 3
CG collection group
POM put on the market
43
ICT and consumer equipment are collected in collection group 3. Producers A’s and
B’s CTS is responsible for 60 % of all e-waste collected in this collection group all
over Germany according to their added market shares in POM of 30% each.
Producers operating in CTS receive back containers with e-waste from all producers
manufacturing EEE collected in the same collection group. In principle, CTS may
decide to take back its own members e-waste only. Like in IBTS, the CTS would then
have to remunerate the municipal collection points for sorting out its members’ brands
e-waste from the general e-waste stream and store it in separate containers, or
establish its own collection points.
Specific Limitations for Collective Takeback Schemes in Germany
Most EU member states have only one CTS in place taking back all kinds of e-waste,
or several CTS each taking back e-waste from certain categories of EEE. In
Germany, in order to maintain complete competition, the market shares of CTS are
limited. The German “Bundeskartellamt” (Federal Cartel Authority, FCA) advised, for
example, the producers of large white goods (category 1) not to set up a CTS
covering more than 25 % of market share of EEE in collection group 1 (Heistermann
2011).
This 25 % limit, however, is not a general restriction for CTS in Germany, even
though the FCA would not allow a single CTS covering an entire category of e-waste.
The exact limit of a CTS’ share in its collection group would depend on an in-depth
case-by-case analysis of how a cooperation affects competition. (Bundeskartellamt
2005)
Specific Stipulations for Historical E-waste and E-waste from Other Sources
than Private Households
Historical e-waste is waste from EEE put on the market before 13 August 2005, the
date when the ElektroG was enacted in Germany. Producers are responsible for the
financing and treatment of this historical e-waste based on their market share like for
the other e-waste collected separately. This obligation applies even if a producer had
not put any EEE on the German market prior to 13 August 2005.
Besides e-waste from private households, producers are also responsible for e-waste
from other than private households. This is e-waste from business-to-business (B2B)
equipment. Such EEE is not or normally not used in private households. Examples
are gas chromatographs, professional kitchen and laundry equipment, high end
servers used in data centers, industrial tools, etc. For such B2B e-waste from EEE
put on the market after 13 August 2005, the producer must offer a reasonable option
for the return and disposal. The producer thus has the same obligations for this B2B
e-waste like for e-waste from private households. The producer and the holder of
EEE, however, may reach an agreement, which departs from these provisions.
44
For e-waste from EEE put on the market before 13 August 2005 – historical B2B e-
waste - the holder is responsible.
3.1.3 Distributors and Consumers
Distributors such as retailers may take back e-waste voluntarily. Unlike in some other
EU member states, they are not legally obliged to accept e-waste. Distributors
offering this takeback service in Germany practice it as trade-in. Consumers may
hand in their old equipment if they buy a new one of the same type.
The (ElektroG 2005) obliges consumers like any other owner of e-waste to place it in
a collection separate from that for unsorted domestic waste. Disposal of e-waste into
household waste containers thus is illegal, but difficult to control. Consumer
awareness hence is a key to obtain access to e-waste. The PuWaMA shall therefore
notify private households of their obligations and about
 options in their district for the return or collection of e-waste,
 their role in the reuse, recycling and other forms of recovery of e-waste,
 the possible impacts on the environment and human health from the disposal
of harmful substances contained in electrical and electronic equipment, and
 the meaning of the symbol shown in Figure 11.
Figure 11: Label to be put on EEE in Europe indicating the necessity of separate collection
(WEEE Directive 2003, ElektroG 2005)
Producers must label all EEE put on the market after 13 August 2005 with the above
label to indicate to consumers that e-waste must not be disposed of in the domestic
waste container.
45
The obligation for separate disposal of e-waste applies to the distributors as well.
They are, however, not obligated to hand over the e-waste to the PuWaMA or to
producer takeback schemes, but may use other possibilities like e-waste brokers. The
same in principle applies to consumers, but only is of relevance for corporate
consumers. Corporate consumers may hold large amounts of used EEE, which they
want to sell as used equipment, where, however, it is not always clear whether it is
actually e-waste or functioning second hand products.
3.1.4 The Clearing House
The functioning of the overall e-waste management system requires the coordination
of the PuWaMA and the producers on the one hand, and of the individual producers’
efforts on the other hand. The producers hence set up and finance the clearing
house, the “Elektro-Altgeräteregister” (EAR), which is constituted as a foundation. It
assumes coordinative and superordinated tasks such as producer registration,
reporting and the calculation of the producers’ market shares. These tasks will be
described in detail in the chapter 3.2.1 on page 46.
In case of doubts, the EAR decides about which types of EEE are covered by the
ElektroG. Annex I of the (ElektroG 2005) shows the 10 categories of EEE and lists
specific types of EEE under each category. These types of EEE are in the scope of
the ElektroG. The listing of types of EEE in Annex I, however, is not exclusive. If a
specific type of EEE is not mentioned in Annex I, it cannot be concluded that the
ElektroG does not cover such a type of EEE. In cases of doubt, the EAR decides, and
the producers may challenge this decision in court in case they do not agree, which
actually has already happened.
As the clearing house takes over sovereign powers, e.g. with the mandatory producer
registration, it is authorized by the competent governmental authority, the Federal
Ministry for the Environment, Nature Conservation and Nuclear Safety (BMU), and
supervised by the “Umweltbundesamt” (UBA, Federal Environment Agency). The
EAR is constituted as foundation and as such does not make profits. It charges,
however, the producers for the sovereign power acts according to the (Cost
Ordinance).
The EAR’s competences are strictly limited to the tasks required to the coordination of
the system. It may not interfere with how the other key players comply with their
obligations within the legally foreseen leeway.
46
3.2 Coordination and Interaction of the Key Players
3.2.1 Interaction of Producers and the Clearing House
Figure 12 shows the tasks of the producers and the clearing house EAR and their
coordination and demarcation.
22
Figure 12: Responsibilities of the clearing house EAR and the individual producers
The EAR registers the producers and their sales of EEE, and it allocates the
containers of e-waste collected in Germany to the producers. It monitors and certifies
that the producers comply with their extended producer responsibility within the
legally foreseen leeway. The EAR is, however, strictly forbidden to tamper with how
the producers organize their extended producer responsibility within the legally
foreseen leeway. The EAR has to remain neutral. It must make contracts neither with
any ESPs nor with producers.
22
Source: Gebriele Markmann-Werner, Ministry of Environment and Climate Protection of
Lower Saxonia, Germany; modified
47
Figure 13 illustrates the interaction between producers and the EAR in more detail.
23
Figure 13: Interaction of individual producers and the clearing house
The interactions are explained in more details in the following sections.
Registration and Financial Guarantee
Before placing EEE on the German market, producers have to register with the EAR.
Producers must register each of their brands. The EAR in return issues a registration
number, which the producer has to use in all business transactions. Each registered
producer will, however, only have one registration number, even if he registers
several brands. The (ElektroG 2005) prohibits producers who fail to register or whose
23
Source: Gabriele Markmann-Werner, Ministry of Environment and Climate Protection of
48
registration is withdrawn to place EEE on the German market. The EAR publishes the
registered producers in the EAR Producer Register. 24
The first time with the registration, and then on an annual base, the producer has to
provide an insolvency-proven guarantee for the EEE, which the producer intends to
place on the German market in that year. In case a producer goes bankrupt, the
financial guarantee shall prevent that other producers or the general public have to
finance this producers’ e-waste. The amounts of EEE the producers estimate to sell
are adjusted at the end of the annual period with the amounts of EEE the producer
actually has sold. (ElektroG 2005) The financial guarantee, however, does not need
to cover EEE, for which the producer plausibly documents that it is not commonly
used in private households. (ElektroG 2005) The guarantee may be provided in the
form of an insurance policy, a frozen bank account or the producer's participation in
an appropriate system to fund e-waste.
The PuWaMA enlist their municipal collection points at the EAR. This is, however,
different from the producer registration and shall just enable the EAR to allocate the
containers with e-waste at the municipal collection points to producers.
Reporting of EEE Put on Market and Allocation of E-waste
On a monthly basis, each registered producer reports to the EAR the type and
amounts of EEE it places on the German market. The amounts reported must be
differentiated in EEE, for which the (ElektroG 2005) requires a financial guarantee –
EEE for private households – and other EEE. As all producers report these amounts
to the EAR, it can calculate the market share of each producer in the ten categories of
EEE.
The (ElektroG 2005) offers two possibilities of how to assess this share:
 based on the market share a producer achieves in a category of EEE (see

Table 2 on page 36) on the German market,
 based on the verified share of clearly identifiable e-waste, arrived at through
sorting or application of scientifically recognized statistical methods, in the
total quantity of WEEE according to equipment type.
This option, however, is only eligible for e-waste put on the German market
after 13 August 2005.
24
EAR Producer Register Stiftung Elektroaltgeräte (EAR): List of producers registered at
EAR; http://www.stiftung-ear.de/hersteller/verzeichnis_registrierter_hersteller (in German
only); last accessed 20 February 2011
49
Each producer can freely decide how the EAR should calculate its share of e-waste
for which it has to assume responsibility.
The calculation of each producer’s market share was already shown in section
“Takeback in the Different Producer Takeback Schemes” on page 40. Each producer
is responsible for financing and treatment of the e-waste collected in accordance with
his market share in the equipment put on the German market.
Regardless of whether a producer sells EEE locally, regionally or across Germany, he

must pick up separately collected e-waste from all over Germany. Within each
producer’s market share, the EAR geographically allocates the containers to be
picked up to the producers so that over time each producer has picked up containers
from municipal collection points all over Germany, from the countryside as well as
from big cities. The allocation is based on a scientifically approved method, which is
published on the internet.25
Monitoring and Controlling
Producers have comprehensive reporting obligations to the clearing house EAR to

enable the EAR to monitor and control the producers’ compliance. Each producer
informs the EAR for each calendar year about:
1. the quantities per collection group of e-waste (see Table 2 on page 36)
collected from public waste management authorities,
2. the types and quantities of e-waste collected in an individual or a collective
takeback scheme,
3. the quantities per EEE category of e-waste the producer has
o reused,
o recycled,
o recovered,
o exported.
25
Stiftung EAR: Calculation of market shares and container allocation; http://www.stiftung-
ear.de/e1767/e1044/e2235/051123Berechnungsweise_ger.pdf; last accessed 13 March 2011;
available in German language only
50
4. Each producer submits to the clearing house an annual report by 30 April

each year. This report contains the data for the previous year for total
quantities from primary treatment facilities about the mass of e-waste, its
components, materials or substances when
o entering the treatment facility (input),
o leaving the treatment facility (output), and
o entering the recovery or recycling facility (input).
Quantities are to be stated by weight or, if this is not possible, by number of units. If
quantities cannot be reported, a well-founded estimate will suffice. The clearing house
EAR may also request that an independent expert verifies the information provided.
The data are the base for calculating whether the producer has picked up and treated
e-waste according to his market share, and whether he has achieved the minimum
recovery and recycling targets. Finally, the EAR certifies that the producer has
complied with his extended producer responsibilities according to the ElektroG.
3.2.2 Interaction of Public Waste Management Authorities, Clearing

House and Producers
The PuWaMA and the producers share the responsibility for the e-waste. The
PuWaMA collect the e-waste at municipal collection points in the five categories listed
in Table 2 on page 36 and hand it over free of charge to the producers. The
municipalities’ responsibility for the e-waste ends with the handover of this e-waste to
the producers or their authorized representatives, the EoL service providers.
When a collection volume of at least 30 m³ has been reached for collection groups 1,
2, 3 or 5, or at least three m³ for collection group 4 (for collection groups see Table 2
on page 36), the PuWaMA report to the clearing house EAR that containers are full
and ready for pickup. (ElektroG 2005)
Figure 14 illustrates the interaction of PuWaMA, clearing house, producers and the
ESPs.
51
26
Figure 14: Interplay of PuWaMA, clearing house, producers and EoL service providers
The EAR assigns the container to an individual producer of this collection group. The
producer informs the ESP he has contracted. The ESP picks up the container at the
municipal collection point and organizes or conducts the proper treatment and
disposal of the e-waste and reports back to the producer that he has picked up and
treated the container of e-waste. The producer hands on the information to the
clearing house EAR in the frame of his reporting obligations.
26
Source: Gabriele Markmann-Werner, Ministry of Environment and Climate Protection of
52
4 The German E-waste Management System in

Practice
The previous chapter explained the roles and the responsibilities of the key players
for e-waste management, and the compliance possibilities the ElektroG offers. This
chapter describes how the key players, in particular the producers, make use of their
compliance possibilities, and the experiences collected in the years since the
establishment of the e-waste management system in August 2006.
4.1 Collection and Treatment Performance
4.1.1 Amounts of E-Waste Put on the Market, Collected and Treated in

Germany
Table 3 shows the amounts of EEE put on the German market in each of the years
from 2006 to 2008, and the amounts of e-waste collected and treated. The data
originate from the producers. They reflect the amounts collected and treated in the
official e-waste management system. No data are available yet for the years 2009
and 2010.
Table 3: EEE put on market in Germany, and collection and treatment of e-waste (BMU 2011)
Put on Market Collected Treated

In Germany In other EU
Year Total (t) B2C (t) B2B (t) Total (t) Total (t)
(t) (t)
2006 1,836,912 709,785 44,113 753,900 722,865 19,055 741,920
2007 1,612,228 517,469 69,498 586,967 573,080 7,468 580,548
2008 1,883,545 642,287 51,488 693,775 678,346 6,640 684,986
53
In average, less than 10 % of e-waste collected is reported to be from other sources

than private households, meaning B2B equipment. A small portion of e-waste
accounting for around 1 % in average is reported to be treated in other EU member
states. (BMU 2011) does not indicate the amounts of e-waste exported to countries
outside the EU.
Figure 15 illustrates the amounts of EEE put on the market (PoM) in Germany, and
the amounts of e-waste collected and treated from 2006 to 2008.
Figure 15: EEE put on market, and e-waste reported as collected and treated in Germany
(based on BMU 2011)
At least 1.6 million tonnes of EEE in the categories 1 to 10 are put on the German
market every year. Exact data for the amounts of e-waste arising are not available.
The German market, however, has been saturated for almost all categories of EEE
for years already. Despite of a general growth of EEE consumption of around 2.5 %
to 2.7 % (Huisman 2007), it can be assumed that a high share of EEE put on the
market is purchased to replace old EEE. For such saturated markets, PoM both in
terms of total amounts as well as for the shares of the different categories can hence
give a gross indication for e-waste arising.
Based on this assumption, only around 37 % to 41 % of e-waste arising in Germany

is collected by the official e-waste management system. (Huisman 2007) forecast the
annual amounts of e-waste arising in Germany from 2006 to 2008 with around 1.5
million tonnes per year, which would mean that around 40 % to 50 % of e-waste
arising was collected and treated separately. Figure 15 indicates that almost all e-
waste collected separately is treated in the official e-waste management system.
54
Little is known about the rest of around 750,000 tonnes to 1,000,000 tonnes, which
does not appear in the official e-waste management system. Part of it is exported to
developing countries. (Sander 2010) quantifies up to 216,000 tonnes of such e-waste
exports every year (see section 4.4 on page 68). A certain share of it may be
refurbished and reused, or may undergo treatment in Germany, but outside the
official e-waste management system, such as possibly in plants processing used
vehicles. No data are available about the quantities and the quality of such treatment.
Private households also store used EEE, in particular smaller devices such as mobile
phones. This effect could not be quantified either.
Figure 16 shows the share of the 10 categories of EEE in PoM and in the e-waste
collected in each of the years from 2006 to 2008. In all three years, large household
equipment, consumer electronics and ICT form the major amounts both in PoM and in
collection, followed by small household equipment.
These four categories account for around 80 % of EEE in PoM. In collection, their
share is at least 90 %. Generally, the share in PoM is in the same range like the
share of collection for these four categories of EEE. The same applies to automatic
dispensers, which is mostly large, bulky B2B equipment.
An exemption is the share of big household appliances collected in 2006. According
to Figure 15 on page 53, the highest amount of e-waste was collected in that year,
even though consumers in Germany could only hand in e-waste free of charge since
March 2006. Figure 16 reveals that the collection of big household appliances was
around 50 % higher than in the following years, while PoM for big household
appliances is similar to the next years. There is no clear explanation for this
phenomenon.
The other categories of EEE account for around 20 % of PoM, and for around 10 % in
collection. Unlike for the above categories, PoM and collection differ greatly. This
effect is most striking for luminaries, where the collection is less than 10 % of PoM.
Most of the equipment in EEE categories 5 to 9 is smaller equipment, or is
equipment, such as toys, which consumers may not perceive as e-waste. Due to the
small size, consumers dispose of such smaller equipment with household waste
resulting in low collection rates for these categories of equipment, an effect which
(Huisman 2007) had already described. Part of such equipment may also be stored in
the households. Data on this are not available.
55
Put on Market Collected

2006
2007
2008
27
Figure 16: Categories of EEE put on the German market and collected from 2006 to 2008
ICT Information and Communication Technology

GDL Gas Discharge Lamps
27
Bundesministerium für Umwelt, Naturschutz und Reaktorsicherheit: Elektro-und
Elektronikgeräte in Deutschland,
http://www.bmu.de/files/pdfs/allgemein/application/pdf/daten_elektrogeraete_2007_2008_bf.p
df; last accessed 22 May 2011
56
As the data only cover three years, further conclusions on trends for PoM and
collection are not yet possible.
4.1.2 Achievement of the Collection and Treatment Targets
Figure 17 depicts the amounts of EEE put on the market and collected per inhabitant
and year. The figures comprise both B2B and B2C equipment.
28 29
Figure 17: EEE put on the German market and collected in kg per inhabitant and year
The collection rate ranging between around 7 kg and 9 kg, there is still considerable
potential for improvement considering PoM being well above 19 kg.
The WEEE Directive sets a minimum target of 4 kg per inhabitant and year for the
collection of e-waste from private households. The ElektroG has adopted this
28
Bundesministerium für Umwelt, Naturschutz und Reaktorsicherheit: Elektro-und
Elektronikgeräte in Deutschland,
http://www.bmu.de/files/pdfs/allgemein/application/pdf/daten_elektrogeraete_2007_2008_bf.p
df; last accessed 22 May 2011
29
Statistisches Bundesamt Deutschland:
http://www.destatis.de/jetspeed/portal/cms/Sites/destatis/Internet/EN/Content/Statistics/Bevoel
kerung/Aktuell,templateId=renderPrint.psml; last accessed 29 May 2011
57
minimum target. As the collection rates in Figure 17 above in PoM and collection
comprises B2B equipment, Table 4 shows the rate for collection from private
households only.
Table 4: Collection rate for e-waste from private households
Year 2006 2007 2008
Collection rate from

private households
8.7 6.3 7.8
in kg per inhabitant
and year
Germany clearly exceeds the minimum collection rate of 4 kg per year and inhabitant.
Figure 18 gives an overview on the 2008 collection rates in European countries.
Germany ranges in the middle field, but way behind the Scandinavian countries.
Some EU member states do not achieve the minimum collection rate of four
kilograms per inhabitant and year. It is, however, fair to state that in particular the new
EU member states in Eastern Europe in the past had and generally still have lower
amounts of EEE put on the market. The e-waste arising in these countries is thus
lower, and collecting the minimum four kilograms of e-waste therefore a higher
requirement compared to the Western EU member states. A collection target based
on a percentage of EEE put on the market is discussed for the recast WEEE
Directive, among other reasons in order to take into account these differences
between the member states (see section 2.3.7 on page 33).
58
30
Figure 18: Collection rates of e-waste from private households in Europe in 2008
Besides the minimum collection rate, the WEEE Directive stipulates minimum rates
for recovery and recycling (see Figure 6 on page 31) of the separately collected e-
waste. The ElektroG has adopted these minimum rates. Table 5 displays the recovery
and recycling rates achieved in Germany for e-waste sent to treatment in 2008.
30
Eurostat:
http://epp.eurostat.ec.europa.eu/portal/page/portal/waste/data/wastestreams/weee; last
accessed 29 May 2011
59
Table 5: Rates for recovery, recycling and reuse of e-waste in Germany in 2008 (BMU 2011)
Reuse of Entire
Recovery Minimum Recycling Minimum
Appliances (in % of
Product Category Rate Recovery Rate Recycling
B2B and B2C
Achieved Rate Achieved Rate
collected)
Big Household
1 94 % 80 % 85 % 75 % 0.7 %
Appliances
Small
2 Household 92 % 75 % 73 % 65 % 1%
Appliances
3 ICT 95 % 75 % 82 % 65 % 3%
Consumer
4 94 % 75 % 80 % 65 % 0%
Electronics
5 Luminaries 96 % 70 % 75 % 50 % 63 %
Gas Discharge
5a 99 % 80 % 99 % 80 % 0%
Lamps
Electrical and
6 94 % 70 % 76 % 50 % 1%
Electronic Tools
Toys, Sports
7 and Leisure 93 % 70 % 77 % 50 % 2%
Equipment
Medical
8 95 % 70 % 81 % 50 % 15 %
Devices
Monitoring and
9 Control 95 % 70 % 79 % 50 % 4%
Instruments
Automatic
10 96 % 80 % 92 % 75 % 7%
Dispensers
For 2008, the producers in Germany exceeded the minimum recovery and recycling
rates for the e-waste collected from private households. According to (BMU 2011),
this applies as well for the years 2007 and 2006.
The (WEEE Directive 2003) does not allow counting the reuse of complete devices
for the recovery and recycling rates, while the reuse of components is taken into
account. In the reuse of complete devices, the rates for luminaries are particularly
high. The reason behind could not be clarified, but (BMU 2011) discloses the same
trend in the preceding years.
Summing up, Germany exceeds the minimum requirements for collection, recovery
and recycling of e-waste. The more than 19 kg per year and inhabitant of EEE put on
the German market reveals a large potential for collection rates beyond the current
around eight kilogram per year and inhabitant.
60
4.1.3 Quality of Collection
The shared responsibility between the PuWaMA and the producers causes problems
on the interface between the PuWaMA and the producers’ takeback schemes and
influences the quality of collection.
Pickup Coordination
In the initial implementation phase of the ElektroG, the pickup of the containers from
the municipal collection points did not work very well. In January 2007, the PuWaMa
complained that around five percent 31 of pickups from the municipal collection points
were delayed. The long information chain from the PuWaMa via the clearing house
and the producers to the producers’ ESPs (see Figure 14 on page 51) took time to
run in. In February 2008, the complaints had decreased to 0.2 % only.
Damaged and Wrongly Sorted E-waste
In the initial ElektroG implementation phase, treatment operators complained about

containers containing e-waste of other collection groups, e.g. e-waste of collection
group 5 in collection group 3 containers. Part of the e-waste was damaged already
when it reached the treatment operators. Broken CRT TVs are difficult to treat. Of
particular concern are damaged LCD displays and cooling and freezing equipment,
as mercury, CFCs and HCFCs may be released into the environment. Figure 19
depicts the rear part of a flat panel display with broken backlights.
Treatment operators stated that with the implementation of the ElektroG, the rates of
broken or otherwise damaged equipment increased. Improper handling at the
municipal collection points was identified as one reason. E-waste such as old TVs
were dropped off or thrown instead of stacking them carefully into the containers.
While PuWaMA were responsible for the further treatment of e-waste prior to the
implementation of the ElektroG, their accountability now ends with the handover of
the containers to the producers. (Kramer 2011) PuWaMA are not paid for the
collection and proper storage of the e-waste, and often feel that they do this work for
the producers free of charge. The producers on their part have no contracts with the
PuWaMA and thus no leverage to force improvements. In any case, the quality
problems in collection hamper sound reuse and recycling of e-waste.
31
Presseinformation Nr. 19/2008, 3 Jahre ElektroG: http://www.umweltbundesamt.de/uba-
info-presse/2008/pdf/pd08-019.pdf; last accessed 16 June 2011, in German language
only
61
32
Figure 19: Rear part of a flat panel display with broken backlights
Meanwhile, after more than five years of e-waste management according to the
ElektroG, the situation seems to have improved due to intensive contacts and efforts
of ESPs and treatment operators with the PuWaMA. (Kramer 2011, Werth 2011) The
overall situation, however, seems to be inhomogeneous. Some ESPs consider the
problems with the PuWaMA as a marginal remaining problem (Werth 2011), while
others report persisting quality issues (Kramer 2011).
32
Dr. Jaco Huisman, United Nations University
62
4.1.4 Quality of Treatment
Control and Certification of Treatment Operators
The (ElektroG 2005) demands an annual certification of facilities, in which primary

treatment takes place. The certification shall ensure that the facility is technically
suitable to achieve the recovery and recycling targets and that all the data needed to
calculate and substantiate recovery rates are documented in a verifiable manner. The
certification also validates the treatment operators’ method to calculate the recovery
and recycling rates.
The audits must be conducted by independent experts sufficing the requirements

stipulated in the ElektroG. The maximum validity period of such certificates is 18
months. Facilities that are certified as “Entsorgungsfachbetrieb” (specialized waste
management companies) according to (EfbV 1996) are deemed certified if the
facility’s compliance with the provisions of the ElektroG has been verified and
documented in the certification. Such certification requires an annual audit as well.
Plants for the treatment of e-waste may cause emissions and noise. Establishing a
waste treatment plant hence requires governmental approval according to German
(Immission Control Act). This act sets strict limits for emissions, which are monitored
and controlled by the competent authorities.
Treatment operators thus are monitored and controlled in Germany according to the
(ElektroG 2005) and (EfbV 1996) as well as the (Immission Control Act) whether they
possess the technical and organizational capability and the knowledge for a state-of-
the-art environment-friendly treatment of e-waste.
Such controls and audits are valuable to assess operators’ principal abilities to
achieve certain treatment results. There is, however, no mean to control whether and
how far operators’ actually make use of their capabilities in day-to-day operations,
when no auditor is on site. As in the end, the producers are responsible for the sound
treatment of the e-waste, they should monitor their treatment operators as well.
Unannounced controls could improve the situation. (Kramer 2011) states that some
producers actually check their treatment operators regularly and carefully, while
others forego any further monitoring.
There are suspects that some treatment operators may not or not sufficiently comply
with the provisions of Annex II of the WEEE Directive such as the removal of
components containing hazardous substances and the specific treatment
requirements. It would be difficult to prove if a treatment operator shreds entire LCD
displays, for example, instead of removing the mercury containing backlights before.
Such incompliance would save cost for expensive manual disassembly of the LCD
displays, and the small amounts of mercury would evaporate and be diluted in the
waste stream.
63
Despite of all control and certification efforts, suspects remain that the strong
competition and producers having little focus on quality may cause some treatment
operators to not fully comply with the provisions of the WEEE Directive and the
ElektroG. As such incompliance is difficult to prove, unfair competition may drive a
downturn competition on quality.
Calculation of the Recovery and Recycling Rates
There is no commonly adopted and compulsory method for how to calculate the
recovery and recycling rates, neither in Germany nor across the EU. The calculations
may be based on flat rates. Most commonly used in Germany according to (Kramer
2011) is the document “Praxishilfe Erstbehandlung nach ElektroG“ (Practical
Assistance to Initial Treatment Operators According to ElektroG“) from (Gallenkemper
2008). A hard disk drive, for example, which was treated at a pre-processor and then
given into a recycling process, is accounted with 80 % recycling and 20 % of energy
recovery resulting in 100 % recovery. This would be independent from the actual
performance of the smelter. The data in (Gallenkemper 2008) are combined with
actual recovery and recycling performance data. This procedure helps bridging data
gaps and is a compromise between practicability and exactness in order to alleviate
some of the bureaucratic burden on the treatment operators. In the end, each
treatment operator may have his own calculation method. The calculation method is,
however, part of the treatment operators’ certification.
4.2 Producer Takeback Schemes Operating in Germany
As pointed out in section 3.1.2 on page 38, producers in Germany may set up
individual brand-selective (IBTS) or non-selective takeback schemes (INTS) as well
as collective takeback schemes (CTS). In practice, producers in Germany prefer
individual non-selective takeback systems.
4.2.1 Individual Non-selective Takeback Schemes
Individual non-selective takeback schemes are the normal case in Germany.

Producers appreciate the freedom of individually choosing their ESPs and treatment
64
operators and the competition keeping prices low. As producers contract EoL service
providers (ESPs) directly, they can define their own quality requirements and have
maximum freedom of individually contracting those ESPs that suffice these
requirements at best price. Producers can thus directly influence the EoL treatment.
As they do the tendering and contracting of ESPs themselves, producers gain deep
insight into the generation and composition of the total EoL cost, which maximizes
cost control and minimizes the abuse of financial resources. (Bellenberg 2011)
Disadvantageously, each producer working with an INTS has to establish

administrative capacity on its own to manage the e-waste he is responsible for. A
large German producer of household appliances, for example, established a
department with five employees for this task, while collective takeback schemes work
a whole country with just five to 25 employees. The German system in this point puts
at disadvantage small producers. For them the administrative burden is high
compared to the company size, and with the small amounts of EEE they put on the
market they cannot achieve economy of scale levels of e-waste enabling good prices
for the EoL of this e-waste. (Bellenberg 2011) As collective takeback systems are not
common in Germany, they cannot join such a system to reduce their cost.
Moreover, quality controls are complicated for producers working in an INTS. Most
treatment operators process e-waste from several producers due to the comparatively
small amounts of e-waste from single producers compared to a collective takeback
scheme. Checking compliance with the minimum recovery and recycling rates for a
single producer thus is a complex task. Producers in Germany do such checks
together with other producers of the same e-waste collection group. To protect ESPs
and treatment operators’ competitive information, the producers contract third party
auditors for such controls. (Bellenberg 2011)
INTS thus on the one hand enable producers keeping prices at competitive levels.
Producers taking their extended producer responsibilities serious can influence the
quality of treatment, and thoroughly monitor their ESPs. On the other hand, INTS are
difficult to operate for small enterprises, and put producers in a position to increase
cost pressure on ESPs compromising on quality.
As producers working with an INTS take back e-waste of all brands in their collection
group, INTS do not set financial incentives for ecodesign.
4.2.2 Collective and Individual Brand-Selective Takeback Schemes
The Federal Cartel Authority (FCA) limits the market shares of collective takeback
schemes (CTS) operating in Germany. (Bundeskartellamt 2005) The FCA ruling
excludes CTS in Germany covering all e-waste of a collection group, or even the
complete e-waste arising in Germany.
65
Currently, besides the many INTS, only one CTS is operating on the German market.
It takes back luminaries such as LED and compact fluorescent lamps (energy saving
lamps).33 Nine producers of luminaries are running this CTS. This does not contradict
the FCA’s rule because there are more producers in the German market who are not
members of this CTS. The FCA obviously does not consider this CTS as putting
competition at stake. (Bundeskartellamt 2005)
In most other EU member states, large scale collective takeback schemes (CTS) are
the normal case, with a single or few CTS only operating in the country. CTS are cost
efficient in the sense that they reduce the administrative burden on the single
producers, as explained in the previous section. CTS contract ESPs and treatment
operators for their members. Compared to INTS, they administrate large amounts of
e-waste. Thus, they achieve economy of scale enabling a strong position in
negotiations with ESPs or treatment operators. Competition, however, is incomplete,
as ESPs and treatment operators have just one or few potential business partners
resulting in monopsonies. Producers in such countries do not have much choice
either if they do not want to set up individual brand-selective takeback schemes.
For collective takeback schemes, controlling their contractors is less complicated than
in the case of the INTS. CTS achieve high volumes of e-waste from various
producers, for which compliance can then be declared collectively, not for each
individual producer. (Bellenberg 2011) ESPs and treatment operators, however,
prefer third party controls as well to maintain the confidentiality of their competitive
information.
No individual brand-selective takeback scheme (IBTS) is known to operate in

Germany or in any other EU member states. The producer would have to reimburse
the PuWaMA for sorting out waste devices of his brands from the general e-waste
stream and store it separately. Economy of scale is difficult to achieve resulting in
higher cost for treatment. The practicability of IBTS is limited as well. With around
10,000 producers registered in Germany, the PuWaMa cannot provide enough space
for the separate storage of containers for IBTS. Alternatively, producers may conduct
the collection from private households and distributors, which, however, again would
be a cost driver.
Like INTS, CTS do not set financial incentives for ecodesign, as such schemes take
back all producers’ e-waste in their collection group. IBTS would set such incentives.
High cost and practical constraints, however, make IBTS unattractive for producers.
33
lighcycle: http://www.lightcycle.de/; last accessed 30 May 2011
66
4.2.3 Cost of Logistics and Treatment
Figure 20 provides an overview on the end-of-life cost for the five collection groups of
e-waste in Germany.
34
Figure 20: End-of-life cost of e-waste in Germany (September 2010)
The prices comprise the logistics, storage and treatment of the e-waste starting from
the pickup of the containers at the municipal collection points and hence do not
include the PuWaMA’s cost for the collection of the e-waste. The prices include the
returns from sales of recycled materials and hence depend on the raw material
prices. None of the collection groups could be treated with economic profit in
September 2010. Prices of e-waste treatment in different EU member states were not
available.
34
Stiftung EAR, http://www.stiftung-
ear.de/e47/e129/e1222/e1223/regeln1243/Garantiedaten_ger.pdf, last accessed 15 June
2011;
67
4.3 Achievement of the German Transposition Priorities
The transposition of the (WEEE Directive 2003) into the German ElektroG and its
implementation targeted promoting competition, and preventing freeriders and cherry
picking. These objectives could mostly be achieved.
Promoting Competition
With around 10,000 producers registered and demanding EoL services and a
multitude of ESPs offering such services, the aspired complete competition on the
German market could be achieved. Unlike in most other EU member states operating
just one or few collective takeback systems, producers have freedom to individually
organize the takeback of e-waste. Whether and how far this reduces the prices could
not be investigated, as data on prices for the EoL of e-waste enabling reliable
comparisons are not available for the different EU member states.
Prevention of Freeriders
Around 10,000 producers35 putting EEE on the German market are registered at the
clearing house EAR. The Federal Environment Agency (UBA) stringently pursues
freeriders. These are producers that are not registered but nevertheless put EEE on
the German market. Freeriders thus escape their financial and other obligations
related to the EoL of their products. They may be fined with up to 50,000 Euro
(ElektroG 2005). Their numbers have clearly decreased since the UBA tightened the
controls after the initial implementation phase of the ElektroG. 36 The
“Bundesnetzagentur” (Federal Network Agency, FNA) supports the UBA in this task.
The FNA, among other tasks, monitors whether EEE put on the German market
complies with certain technical product-specific requirements.37 During these controls,
the FNA additionally checks whether the producers of EEE are clearly identifiable and
registered.
35
info-presse/2008/pdf/pd08-019.pdf
36
info-presse/2008/pdf/pd08-019.pdf
37
Marktaufsicht für elektrische/elektronische Produkte durch die Bundesnetzagentur;
http://www.bundesnetzagentur.de/SharedDocs/Downloads/DE/BNetzA/Sachgebiete/Telekom
munikation/TechnischeRegulierung/InverkehrbringenGeraeteEMVGFTEG/HinweiseElektronis
cheProdukteInternetID15065pdf.pdf?__blob=publicationFile; last accessed 6 June 2011 (in
German language only)
68
Besides the authorities, competitors can file a suit against freeriders for damages
from unfair competition, which might result in higher fines than the 50,000 Euro
foreseen in the ElektroG for non-registration.
Prevention of Cherry Picking
The clearing house EAR successfully prevents cherry picking, as each producer must
pick up containers from all over Germany, on the country side with high logistics cost
as well as in urban areas. The formula the EAR uses to allocate the containers to the
individual producers is published 38 and the assignment mechanism hence
transparent.
The ElektroG leaves the PuWaMA the option to take over the producers’
responsibility for an entire collection group (see “Handover of E-waste to the
Producers” on page 38). The PuWaMA make use of this possibility for collection
groups yielding an overall economic benefit depending on the raw material prices.
Producers hence consider this PuWaMA opting as cherry picking, the PuWaMA as an
at least partial compensation for their expenses related to the collection of the e-
waste. A more systematic financing of the collection, for example based on a fee paid
at the point of sale, could compensate the PuWaMA without opting, prevent cherry
picking and at the same time provide incentives for more and better collection. Details
on this proposal are presented in section 4.5.1 on page 70.
4.4 Transboundary Shipments of E-Waste out of the EU
As was shown in the previous chapters, a big share of e-waste, probably around
50 % of the e-waste arising, never enter the official e-waste management system.
There are no clear indications on the whereabouts of this equipment. Part of it is
exported to countries outside the EU. (Espejo 2011) describes the informal sector in
Germany consisting, among others, of informal collectors, informal collection points
and exporters. Often, persons originating from the countries of imports but living in
Germany organize the exports. (Espejo 2011) found that the equipment for export is
mainly sourced from corporate consumers. Another source is collection from the
streets. Private users put e-waste onto the street if the PuWaMA conduct household
collections. The informal collectors wander through the streets prior to the formal
38
Stiftung EAR: Calculation of market shares and container allocation; http://www.stiftung-
ear.de/e1767/e1044/e2235/051123Berechnungsweise_ger.pdf; last accessed 13 March 2011;
available in German language only
69
collectors and pick up the equipment. Informal collectors may also collect used EEE
directly from private users, sometimes even offering money for it. (Espejo 2011) No
clear evidence could be found that relevant amounts of e-waste leak out of the official
sector into the informal sector. Neither the corporate consumers nor the receiving
organizations, nor, of course, the informal collectors are obliged to inform the clearing
house EAR about the amounts, which explains at least parts of the data gap. A big
part of the e-waste arising in Germany thus never enters the formal, official e-waste
management system.
(Sander 2010) indicates around 155,000 tonnes of e-waste exports out of Germany
every year, ranging from 93,000 tonnes to 216,000 tonnes. The main types of
exported equipment were monitors, TVs, cooling and freezing equipment, computers
and small electronic devices such as toasters, mixers and shavers. The figures have,
however, high uncertainties. The main destinations of these exports are developing
countries like Nigeria, Ghana, China, India and Vietnam.
Transboundary movement of e-waste to developing countries and countries with

economies in transition is a phenomenon that can be observed in all developed
countries. The EU has implemented the Basel Convention in its legislation and hence
bans exports of e-waste to developing countries. The driver behind the exports is the
reuse value of such equipment in the receiving countries. In Germany, a mobile
phone has a material value of around one Euro, and for CRT TVs, sound treatment
costs more than the sales of the recycled materials can compensate. (Odeyingbo
2011) quantifies the price of untested mobile phones with five Euro at least in Nigeria,
that of TV sets with around 17 to 35 Euros. The equipment is shipped in containers,
or exported with used vehicles, which are loaded with used electrical and electronic
equipment. (Odeyingbo 2011) calculated that importers into Nigeria can make profits
of several thousand Euros per container. The situation is similar for other imports into
other developing countries.
(Espejo 2011) states that the controls at the ports are minimum. Additionally, the
exported equipment is labelled as EEE for reuse. While the export of e-waste is illegal
according to the Basel Convention, transboundary shipments of used EEE for reuse
are legal. Functional equipment is, however, difficult to differentiate from non-
functional e-waste in the ports. Even if the containers get controlled and non-
functional equipment is detected in a container, generally there is no prosecution of
the exporters. The exporter has to take back the container on his cost, and then may
try again later at the same or another port. (Espejo 2010)
While a big share of the exported equipment is actually reused, the serious
environmental and health impacts in developing countries start with the recycling and
dumping of e-waste when the equipment has no reuse value left. (Odeyingbo 2011,
StEP-Initiative)
70
4.5 Measures and Incentives for Improvements
The current e-waste management system in Germany and in the other EU member
states does not provide incentives for compliance and improvements. Higher
collection rates and better quality collection increase the cost for the PuWaMA as well
as for the producers, who must finance the transport and the treatment of the
separately collected e-waste.
Nevertheless, the current e-waste management system requires improvements.

Higher collection rates and better quality collection as well as more transparency in
the treatment of e-waste are, among others, urgent tasks.
4.5.1 Increased and Better Quality Collection
Increase of Collection Rates
Currently only around 50 % of e-waste arising is collected separately and treated in

the official e-waste management system. Treatment collected outside the official e-
waste management system is not likely to undergo a state-of-the-art treatment.
Additionally, most e-waste exported from Germany to developing countries never
enters the official e-waste management system. Achieving higher collection rates
hence is an important target, in particular important for e-waste, which may cause
pollution or resource losses. Examples are
 cooling and freezing equipment, where emissions of CFCs and HCFCs

contribute to global warming and depletion of the stratospheric ozone layer.
 all e-waste containing high amounts of precious metals, such as computers

and mobile phones.
All proposals for the recast WEEE Directive listed in the (Legislative Observatory)
target collection rates that for most EU member states would be higher than the
current four kilograms per inhabitant and year, as described in section 2.3.7 on page
33. Measures to achieve these targets could be:
 Increase proximity of collection facilities to consumers

Collect smaller e-waste, which consumers currently dispose of with household
waste, together with other waste directly from private households provided the
e-waste can be separated in a later stage for the further treatment.
Approaches like the “Wertstofftonne” and “Gelbe Tonne Plus” (see section
71
“Separation of Wastes in and at Private Households” on page 19) collecting

small e-waste together directly at the households may be viable approaches,
even though there are concerns about this concept as well. 39 (Bünemann
2011)
 Make takeback of e-waste obligatory for retailers and shops selling EEE.
 Require collectors to conduct periodical household collections of e-waste, e.g.

once a year. It must be taken into account, however, that such collections are
a main source for used electronic and electrical equipment exported to
developing countries. (Espejo 2011)
 Collectors, either PuWaMA or takeback schemes, could be required to offer a

“one stop service” for retailers to lower the bar for them to give e-waste to the
official system. The retailer just calls the collection service provider, who takes
care of everything else.
 The PuWaMA in Germany should put more emphasis on awareness rising of

consumers.
Financial Incentives
The (European Parliament 2010) proposed levying a charge at the point of sale to
improve collection. The levy shall be used for financing awareness raising campaigns
for consumers to increase the amounts of e-waste collected. Additionally, the funds
shall be used to remunerate the PuWaMA to incentivize higher quality collection. A
remuneration model as shown in Figure 21 could provide even stronger incentives.
The reimbursement of collectors could follow a progressive tariff. The tariff paid per
kilogram of e-waste collected increases with the total amount of e-waste collected
and handed over to the foreseen downstream operator (tariff A in Figure 21).
The progression of the tariff could also take into account the environmental priorities.
For e-waste containing hazardous materials or valuable resources, the progression
could start from a higher level, and it could additionally be steeper triggering more
collection efforts (tariff C in Figure 21).
The quality of the e-waste collection could be taken into consideration as well, in
particular for environmentally sensitive products. Damaged e-waste, in particular of e-
waste such as LCD flat panel displays, compact fluorescent lamps, fridges and
39
Bundesverband Sekundärrohstoffe und Entsorgung e. V.,
http://www.bvse.de/11/4609/Kein_Elektronikschrott_in_die_Wertstofftonne; last accessed 16
June 2011, in German language only
72
cooling equipment containing HCFCs and CFCs, could result in a reduction of

reimbursements (tariff B in Figure 21).
Figure 21: Reimbursement model providing collection incentives
After an evaluation of administrative costs and other drawbacks as well as of

environmental and other benefits of such a reimbursement model, the above
proposals may become part of standards for the collection of e-waste.
4.5.2 High Quality Treatment of E-waste
Quality Standards
Quality standards for the treatment of e-waste are considered as a mean to improve
the treatment quality and to create market transparency on quality. Such standards
aim at operationalizing legal requirements in order to make the operators’ compliance
checkable. Examples are mass balances of treatment plants. If the average content
of mercury in e-waste going into a treatment plant is assessed over a certain period, it
can be compared with the amounts of mercury the plant forwards to other operators
for further treatment. This should enable at least a plausibility check. Quality
standards are already available, such as (R2 2008) and (e-Stewards 2009). A further
standard particularly for Europe, (WEEELABEX 2011), has just been published. As
documentation of all activities is a key to compliance, the additional administrative
burden on operators is a clear disadvantage.
73
Comprehensive improvements require, however, standardizing the entire end-of-life

chain of EEE. Equipment, which is already broken when it arrives at pre-processing,
can no longer be treated adequately. (Deubzer 2010) The (European Parliament
2011) has demanded the Commission to initiate the development of such standards
for the EU.
Financial Incentives for Ecodesign

The e-waste management system in Germany exceeds the minimum collection as
well as the minimum recovery and recycling targets stipulated in the WEEE Directive
and the ElektroG. The original idea to establish extended producer responsibility as
an incentive for better ecodesign, however, could not be achieved, neither in
Germany nor in the other EU member states. The producers’ INTS and CTS
operating in Germany collect e-waste from all brands (Figure 9 on page 41).
Producers investing in ecodesign do not benefit more from these efforts than their
competitors in the same collection group do. Producers still prefer INTS and CTS
rather than bearing the higher cost of an IBTS, not to mention that with around 10,000
producers registered in Germany, IBTS cannot be implemented for all producers due
to space constraints in the infrastructure.
The (European Parliament 2010) demands EEE to be tested on appropriate design

for EoL, and well-designed EEE to receive a price reduction at end-of-life. This shall
apply even if the producer is organized in a CTS. This approach would interfere with
price setting in the producer takeback schemes. It is not clear whether the proposal
will be adopted in the recast WEEE Directive. It would need a thorough assessment
whether it is practical and effective to set incentives for ecodesign under the
implementation conditions in the different EU member states.
Harmonized Calculation of Recovery and Recycling Rates

As described in the section “Calculation of the Recovery and Recycling Rates” on
page 63, the calculation of the recovery and recycling rates in Germany, and in
between the EU member states is not harmonized. These treatment performance
rates hence do not necessarily reflect the actual performance. The WEEE Directive
obliges all EU member states to report their treatment performance data to the
Commission. The data are published in one document40, even though they are based
on different calculation methods. There is hence urgent need to harmonize the
calculation of the recovery and recycling rates across the EU. Comparable treatment
performances could stimulate competition for better treatment in between treatment
operators and in between member states.
40
Eurostat: WEEE – Key statistics and data:
http://epp.eurostat.ec.europa.eu/portal/page/portal/waste/data/wastestreams/weee;
74
5 Technical, Economical and Ecological Principles of

E-waste Treatment
The basic objectives of e-waste treatment are the prevention of pollution and the
recycling of resources.
5.1 Basic Objectives of E-waste Treatment
5.1.1 Pollution Prevention
E-waste may contain hazardous substances. The treatment of e-waste targets

preventing these substances from being released into the environment.
Some of the substances can be recycled along with the other materials from e-waste.
They remain within the technosphere for further use where they can be controlled and
are not released into the environment. Examples for such hazardous substances are
heavy metals like lead and cadmium. Other substances in e-waste, such as HCFCs
and CFCs in older cooling and freezing equipment and PCB contained in certain
capacitors, cannot be recycled. They must be removed from the e-waste material flow
and be incinerated in order to prevent pollution.
Hazardous components, preparations and substances can be removed
 in an initial treatment step, prior to further processing like shredding and

mechanical separation (initial removal), for instance by disassembly of the e-
waste device and manual removal,
or
 during or after subsequent processes (process-integrated removal).

75
The removal prior to any further treatment is indispensable if at least one of the
following conditions applies:
1. Hazardous substances or components cannot be controlled in subsequent

treatment processes and therefore may be released into the environment
during the treatment processes or from the resulting fractions or materials.
2. These substances or components otherwise disturb treatment processes of e-

waste, fractions or materials thereof in operations of the initial or downstream
operators thus seriously compromising the quality of the recycled materials.
3. These substances or components otherwise end up in incineration or on

landfill sites, which are not equipped to accept them.
4. These substances or components otherwise end up in incineration or on

landfill sites, even though recycling would be the environmentally better
option.
The initial removal of such substances and components from e-waste is dispensable
if
1. they can be controlled, isolated and removed safely and to a sufficient degree
during or after the recovery and recycling operations,
and
2. if these removed hazardous substances subsequently can be treated,

incinerated or disposed of in a way that allows treatment preventing pollution
to a degree comparable to the prior separation of these substances from e-
waste.
Annex II of the (WEEE Directive 2003) stipulates requirements for the removal of
certain hazardous components and substances from e-waste.
5.1.2 Recycling
The principle objective of all recycling activities is generating materials from waste
products in a quality, which is as close as possible to the status of primary materials.
Such secondary materials can be reused at a high reapplication level replacing
valuable primary raw materials and hence have a higher ecological value compared
to downcycled secondary materials. As products generally consist of more than one
substance or material, the separation of the materials and substances in products into
76
different fractions, from which they can be recycled, is a key step in all recycling
activities. For e-waste, this separation is a particularly difficult task due to its complex
composition.41
5.2 Treatment of E-waste
The following sections will give an overview on the treatment of e-waste in Germany.
Useful additional technical information can be found in (VDI 2343).
5.2.1 Overview on the Treatment
Figure 22 gives an overview on e-waste treatment in Europe comprising

preprocessing and material recycling.
Figure 22: Overview on e-waste treatment
41
StEP-Initiative: What is e-waste, http://www.step-initiative.org/initiative/what-is-e-waste.php;
77
The outline shows the principles, which treatment operators will adapt and modify
depending on the types of e-waste they treat, their process technology and their
knowhow. Figure 25 on page 82 shows an example of such a pre-treatment process.
Removal of Hazardous Components and Substances
Depending on the composition of the collected e-waste, preprocessing may start with
the manual sorting of the e-waste. Collection group 3, for example, comprises devices
of ICT and consumer electronics resulting in an inhomogeneous mix of e-waste. For
some of these devices, Annex II of the (WEEE Directive 2003) stipulates specific
treatment and the removal of hazardous substances. Examples in collection group 3
are CRT TVs and flat panel displays containing backlights with mercury, and
batteries. Such devices must be sorted out from collection group 3 e-waste prior to
further treatment steps. Otherwise the hazardous substances cannot be controlled
and may be released into the environment. Substances and components removed
from e-waste are forwarded to specific treatment, where they may be
 recycled, e.g. mercury and batteries
 incinerated, like the capacitors containing PCB,
 disposed of on special landfills, like phosphorous layers removed from CRT

TVs.
Next to hazardous components, bulky and strong parts may disturb the shredding and
mechanical separation process, or even damage the process equipment. Examples
are compressors from air conditions and from cooling and freezing equipment. The
cooling liquids are removed, and the compressors treated separately.
Separate Treatment of Valuable Parts
E-waste devices such as computers and mobile phones may contain printed wiring
boards and other components, which are rich in precious metals. Figure 23 shows an
example composition for a high grade printed wiring board in comparison to a low
grade one. Equipment with such high grade printed wiring boards may be sorted out
and disassembled. The printed wiring boards are then sent to separate treatment to
improve the recycling result (see chapter 5.2.3 on page 81).
78
Figure 23: Example of shares of different metals in a low grade (top) and a high grade printed
wiring board; percentages missing to 100 %: epoxy resin, glass fibres, plastics and other
metals (Deubzer 2007)
Big parts consisting of homogeneous materials like plastic casings of TVs may be
removed as well. The removal prevents downcycling. These removed parts can be
processed back to materials whose quality is close to or the same as primary
materials.
The removal of such parts may either be done manually directly from the e-waste, or
after a mechanical process that opens up the e-waste devices without breaking the
different components. Batteries, PWBs and big homogeneous material parts are then
easier to access.
79
Comminution and Mechanical Separation
The comminution of the e-waste is the introductory step for the subsequent
mechanical separation. Shredding is the most common comminution process. The
mechanical separation generates four fractions:
 aluminum fraction
 copper fraction
 iron fraction
 plastics fraction
The three metal fractions are treated further to prepare the recycling of the metals in
smelters, or go directly into the smelters. The most important fraction is the copper
fraction.
Pre-processing as well as in the recycling processes generate dusts mainly from the
flue gas filters. The dusts contain metals. Glass from products like washing machines,
scanners, copiers and small displays is pulverized during the comminution process.
Most of it ends up in the filters together with other dusts, or in the metal fractions.
(Kramer 2011) Depending on the metal prices and on the composition of the filter
dusts, the metals may be recycled from the dusts. Alternatively, the dusts are
disposed of on landfills.
5.2.2 Treatment of the Fractions from Pre-processing
Copper Fraction
The copper fraction is the target fraction for all metals besides iron and aluminum.
Copper smelters can recycle a wide range of different metals to a high percentage
and in good quality. Figure 24 shows the recycling performance of copper smelters.
The data go back to averages of five different European copper smelters including the
treatment of filter dusts and other fractions in other smelters, like for example in tin
smelters.
Figure 24 shows that copper and the precious metals (PMs) gold, silver, platinum and
palladium can be recycled very well from such copper fractions with recycling rates of
more than 95 %. For the other metals, the recycling rates decline.
80
Figure 24: Recycling rate of metals from e-waste copper fractions (Deubzer 2007)
Copper and PMs can be recycled to metals with the same purity and quality like
primary metals. Nickel is recycled as sulfuric acid, which may be used e.g. in
electroplating. Most of the other metals leave the copper smelter as alloys, like for
example tin-lead alloys, or as salts, from which the metals can be recycled in further
treatment steps at other plants.
The copper fraction contains certain amounts of plastics, iron and aluminum. These
metals cannot be recycled in copper smelters, but become slag. The plastics burn up
in the smelting processes.
Slag from copper and other smelters are used in road construction, or for backfilling
of mines.
81
Other Fractions
The plastics fraction contains a mix of different plastics, which in Germany is

incinerated for example in cement kilns, where it replaces fossil fuels. The plants
must be equipped with a state-of-the-art flue gas cleaning technology, as otherwise
dioxins and furans may be generated and emitted into the environment. The plastics
fraction contains a certain share of copper, which catalyzes the synthesis of dioxins
and furans from such plastics, in particular from those containing brominated flame
retardants like the PBDEs and PBBs banned in the (RoHS Directive 2003). Such
flame retardants were legally used in EEE put on the market before July 2006.
(Wäger 2010) Alternatively, advanced sorting technologies may be used to
differentiate the plastics and to improve their recyclability.42
The iron fraction and the aluminum fraction may undergo further preparatory
treatments before they are finally recycled. Different from the copper fraction,
contaminations with other metals such as lead, tin and copper cannot be removed
easily and the quality of the recycled materials may be lower than that of primary
metals.
Copper, PMs and the other metals in Figure 24 normally are not recycled from the
iron, aluminum and plastics fractions.
5.2.3 Performance of Pre-processing
Comminution is the preparatory step for the mechanical separation. The e-waste
devices are destroyed and disassembled into small pieces. Mechanical separation is
a combination of several processes, which separate the materials making use of their
Figure 25 shows an example for such a process.
Specific metals can only be recycled from certain fractions. The crucial performance
of the shredding and mechanical separation process hence is to direct each of the
metals into the fraction, from which it can be recycled, and to separate the plastics
from these metals into the plastics fraction. A high share of plastics in the metal
fractions may cause thermal problems in the smelters.
42
Markowski, Jens, BTU Cottbus, Germany: Rückgewinnung von Kunststoffen aus Elektronikschrott,
https://www-docs.tu-cottbus.de/aufbereitungstechnik/public/Poster/PosterKunststoffrecycling.pdf; last
82
Figure 25: Example of pre-processing with shredding and mechanical separation (EMPA,
Switzerland; modified)
(Chancerel 2009) assessed the performance of a state-of-the-art e-waste

preprocessing plant in Germany for gold, silver, palladium and copper. The plant
processed e-waste of collection group 3. Only 26 % of gold and palladium contained
in the processed e-waste was found in the copper fraction, and as little as 12 % of
silver. The rest was distributed over the other fractions and dusts, from which they are
not likely to be recycled. For copper and iron, the effectiveness of the process was
much higher. The process succeeded in directing 60 % of the copper to the copper
fraction, and around 96 % of iron to the iron fraction. This process and how it is used
yields good results for iron and acceptable ones for copper, but obviously is not
adequate to treat PM-rich components.
(Shöps 2010) assessed two commercially applied treatments of PCs at a German

and an Austrian pre-processor. PM-rich components such as the motherboards, plug-
in cards and connectors were removed mechanically or manually prior to the
83
comminution process (Figure 22 on page 76) and treated directly in the copper
smelter. The results in Table 6 illustrate that this treatment greatly improves the
recycling performance for the PMs.
Table 6: Recycling rates for gold, silver and palladium with removal and direct treatment of
PM-rich components in copper smelters (Schöps 2010)
Gold Silver Palladium
Recycling Rate in %
of total content in 70-80 49-75 41-66
treated e-waste
The studies of (Chancerel 2009) and (Schöps 2010) illustrate that pre-processing
requires knowledge to adapt the treatment to the treated e-waste. It is not sufficient to
install a shredding and mechanical separation process and simply treat all kinds of e-
waste with it in the same way. Good pre-processing requires a balanced application
of manual labor and state-of-the art mechanical processing for each type of e-waste.
5.2.4 Economical and Ecological Implications of Recycling
Basic Economical Considerations
In a competitive environment, operators will try to minimize their cost and operate
their treatment at an overall economic optimum. Beyond the legally stipulated
treatments such as the removal of hazardous components, the following
considerations are economical cornerstones for deciding about the appropriate
treatment:
 Labor cost is high in Germany. Depending on qualification and activity,

workers in a pre-processing plant may cost 12 – 22 Euro per hour (Kramer
2011). The entire treatment therefore is highly mechanized and treatment
operators reduce manual work as far as possible.
 A mechanical separation process can never achieve a 100 % separation of

metals and plastics into their target fractions. Each separation process hence
has a separation performance below 100 %. The exact performance is
84
different for each output material, and additionally depends on the type of
process as well as on the composition of the input.
 The direct treatment of PM-rich components in copper smelters avoids the

losses of PMs and thus increases the revenues. The components must,
however, be separated from the e-waste stream. This requires additional
processing and in particular manual labor causing additional cost.
 Iron and aluminum cannot be recycled in copper smelters. The revenues from
iron and aluminum decrease, if components are treated directly in copper
smelters.
The direct treatment of components in copper smelters hence is economically viable

only if the revenues from the avoided PM losses at least compensate the additional
labor cost and the losses of revenues from those metals, which cannot be recycled in
copper smelters.
The same economical considerations apply to any kind of separation of components

and parts such as bigger iron and aluminum parts. The higher revenues from the
sales of the removed components must at least compensate the additional cost for
the separation to make this operation economically viable.
In all other cases, treatment operators will choose mechanical processing of the
entire devices, unless legal compliance requires the removal of substances and
components, or if specific components in the e-waste disturb the comminution and
mechanical separation. As (Chancerel 2009) showed for iron and copper, a state-of-
the-art comminution and mechanical separation process produces good results for e-
waste with low contents of PMs.
Ecological Considerations
The economically driven decisions on the way of treatment affect the ecological
balance of the treatment as well. PMs are scarce metals, and they have huge
ecological backpacks. Mining and refining of PMs require moving huge volumes of
materials and consume immense amounts of energy compared to mass metals like
iron and lead, but also in comparison to copper and aluminum.
Separating parts of homogeneous materials like aluminum, iron and copper parts
from e-waste prior to comminution avoids material losses and the dilution of the
materials in the generated fractions. The higher material purity facilitates reapplying
the recycled materials at a higher level similar to that of primary materials.
85
Low Labor Cost as Enabling Factor
(Schöps 2010) showed that, compared to the results displayed in Table 6 on page 83,
a deeper manual dismantling of PM-rich components may further increase the
recycling yield for PMs. Beyond manually dismantling motherboards, plug-in cards
and connectors from PCs, additionally hard discs, disc drives and power supply units
were dismantled, and the printed circuit boards removed from these devices. The
results for the recycling of PMs increased to
 99 % for palladium,
 97 % for gold,
 92 % for silver.
Feng43 confirms these results for deep manual dismantling in the StEP Best of Two
Worlds project.44
With labor cost between 12 – 22 Euro per hour, deeper manual dismantling of e-
waste is economically not feasible in Germany. Lower labor cost in developing
countries and countries with market economies in transition may enable better
treatment. Manual labor can replace and complement mechanical treatment. In the
end, the effectiveness of each single process in the entire treatment is important for
the total overall effectiveness of recycling, and the process with the worst
performance decides on the overall recycling rate. In combination with modern
technologies for additional mechanical separation, in particular for complex materials
with high share of plastics, and with highly effective smelting and refining plants as
shown in Figure 24 on page 80, manual disassembly of e-waste may enable
economically and ecologically highly effective and efficient treatment of e-waste.
43
Wang, Feng, et al., United Nations University: StEP Best of two Worlds, not published
44
StEP Initiative: Best of Two Worlds, http://www.step-
initiative.org/projects/project.php?id=72; last accessed 19 June 2011
86
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92
Annex E-waste related Contacts
Auditing and certification of treatment operators
 Heinz Böni, Empa, St. Gallen, Switzerland

Phone +41 58 765 7858, [email protected]
Clearing houses and producer registration in Europe
 European WEEE Registers Network, http://www.ewrn.org/; last

ElektroG and WEEE Directive
 Kristine Koch, Umweltbundesamt, Dessau-Roßlau, Germany

Phone +49 340-2103-3020, e-mail [email protected]
 Dr. Heike Buschhorn, Niedersächsisches Ministerium für Umwelt- und

Klimaschutz, Hannover, Germany
Phone +49 511 120 3162, e-mail
[email protected]
E-waste treatment, takeback organization and recycling
 Kai Kramer, Elektrocycling GmbH, Goslar, Germany

Phone +49-5321 3367 24, e-mail [email protected]
 Dr. Christian Hagelüken, Umicore, Hanau, Germany

Phone +49-6181 594 294, e-mail [email protected]
End-of-Life Service Provider and Treatment Operators
 Industrie- und Handelskammer (IHK) Wiesbaden, Germany,

http://www.ihk-wiesbaden.de/index.php?id=entsorger#c2220; last
Expert database Germany
 Community of Experts, Industrie- und Handelskammer (IHK) Berlin,

Germany,
http://www.ihk-berlin.de/recht_und_fair_play/Sachverstaendigenwesen/,
last accessed 9 May 2011
93
Producer e-waste takeback systems in Europe
 Pascal Leroy, WEEE Forum, Brussels, Belgium

Phone +32 270 68 701, e-mail [email protected]
Recycling technologies
 Federal Ministry for the Environment, Nature Conservation and Nuclear

Safety: Export Initiative Recycling Technologies,
http://www.bmu.de/files/english/pdf/application/pdf/faltblatt_retech_en_bf
.pdf; http://www.retech-germany.de/english/dok/616.php; last accessed
26 June 2011
Scientific expertise and consulting on e-waste and RoHS
 United Nations University, Institute for Sustainability and Peace,

Operation Unit SCYCLE, Bonn, Germany
Contact: Ruediger Kuehr, phone +49 228 815 02 13, e-mail
[email protected]
 Step-Initiative, www.step-initiative.org
Contact: Ruediger Kuehr, phone +49 228 815 02 13, e-mail
[email protected]
Waste management, hazardous wastes, transboundary movement of wastes
 Dr. Joachim Wuttke, Umweltbundesamt Dessau-Roßlau, Germany

Phone +49 -340 2103-3459, e-mail [email protected]
WEEE Directive and recast of the WEEE Directive
 Thorsten Brunzema, DG Environment, European Commission, Brussels

Phone +32 2 296 73 10, e-mail [email protected]
 Karlheinz Florenz, European Parliament,

Phone +32 2 284 53 20, e-mail [email protected]
94

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E-waste Management in Germany

United Nations University

United Nations University (UNU) is an autonomous organ of the UN General

 Mr. Jan Bellenberg, Bosch-Siemens Hausgeräte GmbH, Germany

 Mrs. Heike Buschhorn and Mrs. Gabriele Markmann-Werner,

 Mrs. Perrine Chancerel, TU Berlin, Berlin, Germany

 Mr. Mathias Dammer, Stiftung Elektro-Altgeräteregister, Nürnberg, Germany

 Mrs. Silke Hossenfelder and Mr. Franz Heistermann, Bundeskartellamt, Bonn,

 Mrs. Kristine Koch and Mr. Joachim Wuttke, Umweltbundesamt, Dessau,

 Mr. Kai Kramer, Elektrocycling GmbH, Goslar, Germany

 Mr. Ruediger Kuehr, United Nations University, Bonn, Germany

 Mr. Pascal Leroy, WEEE Forum, Brussels, Belgium

 Mr. Sören Rüd, Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH,

 Mr. Christoph Werth-Kreienberg, NOEX AG, Germany

3 E-waste Management in Germany According to the ElektroG ......................... 35

4 The German E-waste Management System in Practice ................................... 52

4.4 Transboundary Shipments of E-Waste out of the EU ..................................................... 68

5 Technical, Economical and Ecological Principles of E-waste Treatment ........... 74

Figure 1: Outline of Germany’s administrative and political structure .......................16

Figure 3: E-waste management in Germany until 2006 ............................................27

Figure 7: Possibilities for producers to implement their extended producer

Figure 8: Individual brand-selective takeback scheme ..............................................40

Figure 9: Individual Non-selective Takeback Scheme ...............................................41

Figure 20: End-of-life cost of e-waste in Germany (September 2010) .......................66

Figure 21: Reimbursement model providing collection incentives .............................72

Figure 22: Overview on e-waste treatment ................................................................76

Figure 25: Example of pre-processing with shredding and mechanical separation

Table 2: E-waste collection groups in Germany (Espejo 2011, modified) ..................36

Table 4: Collection rate for e-waste from private households ....................................57

Category of electrical and electronic equipment (EEE)

End-of-life full service provider (ESP)

Extended producer responsibility (EPR)

E-waste from private households

 manufactures and places electrical and electronic equipment under an

Small e-waste appliance

B2B business to business

B2C business to consumer

CTS collective takeback scheme

EEE electrical and electronic equipment

EoL end of life

ESP end-of-life full service provider

EPR extended producer responsibility

FCA “Bundeskartellamt”, Federal Cartel Authority

FNA “Bundesnetzagentur”, Federal Network Agency

GDR German Democratic Republic

ICT information and communication technology

IBTS individual brand-selective takeback scheme

INTS individual non-selective takeback scheme

PBB Polybrominated biphenyls

PBDE Polybrominated diphenyl ethers

PCB polychlorinated biphenyls

PM precious metal (gold, silver)

PoM put on market

PuWaMA public waste management authorities

PWB printed wiring board

UBA “Umweltbundesamt”, Federal Environment Agency

2 Background on Waste Management in Germany

2.1 Political and Administrative Competences and

Figure 1 provides an overview on the administrative and political structure in