On 15 October 2020, the VERE Association submitted its statement to the Federal Ministry for the Environment on the draft bill of a First Act to Amend the Electrical and Electronic Equipment Act (“ElektroG3 draft bill”).
VERE’s requests for amendment are quite manageable, since VERE considers the draft to be basically sensible and target-oriented; the bureaucratic effort is at least not much greater and there are opportunities to establish a qualitatively and quantitatively sophisticated collection and recycling/reuse system featuring increased market fairness.
VERE asked itself the following three central questions when examining and evaluating the planned amendments to the Electrical and Electronic Equipment Act:
- Are the amendments suitable to significantly increase the amount of waste electrical and electronic equipment collected and to improve the quality of use and recycling?
- Will the amendments lead to fair competition between properly registered manufacturers and free riders, who mostly import from third countries into Germany without being regulated at all?
- Will there be additional burdens on manufacturers and distributors in relation to possible positive effects on protecting the environment and resources?
The evaluation of the draft bill for the Electrical and Electronic Equipment Act under these three criteria can be found in the VERE statement, which is available for download here (in German language):
In summary, VERE wishes to make a positive comment on the fact that a number of proposals already submitted by VERE in its statement on the planned new version of the Electrical and Electronic Equipment Act of 25 June 2019 have been implemented in this draft. This confirms VERE’s opinion that continuous exchange concerning the effects of legislation in the marketplace certainly does lead to better laws.
VERE would therefore be all the more pleased if its proposed amendments were taken into account.