A study on the further development of product responsibility under the German ElektroG (Electrical and Electronic Equipment Act), published in September 2025, analyses how the collection, reuse, and recycling of waste electrical and electronic equipment (WEEE) in Germany can be sustainably improved. The study was prompted by the growing volume of new electrical and electronic equipment being placed on the market, while the separate collection of waste equipment has stagnated for years. As a result, the EU collection target of 65 per cent is being significantly missed: in 2022, the collection rate stood at just 31.7 per cent, and in 2023 it fell to below 30 per cent.
The study identifies the historically evolved system of shared product responsibility as the main cause. Responsibilities for collection, take-back, and recovery are divided among local authorities, producers, retailers, and other stakeholders, without any single party being directly accountable for achieving the collection targets. At the same time, complex reporting and documentation requirements, combined with a lack of incentives, result in valuable raw materials being lost and high-quality recycling processes being hindered. The authors therefore recommend a fundamental reform of the ElektroG towards Extended Producer Responsibility (EPR). Under this approach, producers or distributors would assume responsibility for meeting collection, reuse, and recycling targets. Clear targets, transparent monitoring, and penalties for non-compliance could significantly improve the system’s efficiency. At the same time, established structures such as municipal recycling centres and retailer take-back schemes should be retained.
The study also refers to the EU infringement proceedings against Germany, initiated in July 2024, and makes it clear that reform is necessary not only from a regulatory perspective. According to the model calculations, a comprehensive overhaul of the system by 2031 could result in an additional 1.26 million tonnes of waste electrical and electronic equipment being properly collected each year. This would keep raw materials worth up to 2.08 billion euros in the economic cycle, reduce annual CO₂ emissions by up to 1.92 million tonnes, and create up to 39,000 additional jobs.
The findings underscore that modernising product responsibility under the ElektroG could play a crucial role in strengthening the circular economy, securing valuable resources, and ensuring that European collection and recycling targets are reliably achieved in the future.
This study was commissioned or supported by a prominent, albeit not entirely uncontroversial, German environmental organisation, whose influence is clearly reflected in its findings. From VERE’s perspective, legal frameworks – particularly the Electrical and Electronic Equipment Act – should be regularly reviewed to identify opportunities for improvement. Viewed from this perspective, the study contributes to a debate that is both timely and necessary. Nevertheless, VERE takes a critical view of the proposal to hold retailers and producers directly responsible for achieving collection targets. The current system of shared product responsibility allocates responsibilities to those with the expertise required for the respective tasks. In VERE’s view, companies are already carrying the maximum burden through the financing and administration of their Extended Producer Responsibility obligations. Furthermore, VERE has argued for years that the current methodology for measuring collection rates is not an appropriate indicator of success and therefore presents a distorted picture. Before placing additional responsibilities on retailers, producers, and importers – particularly tasks that fall outside their core sphere of responsibility – greater attention should instead be given to improving the collection rate methodology, strengthening Germany’s recycling infrastructure, and addressing the grey and black export channels that prevent the proper documentation and tracking of waste electrical and electronic equipment.
VERE e.V. remains in close contact with the relevant stakeholders and will continue to keep its members informed of further developments via the “VERE Insider”.
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