End of June 2019, the associations Bitkom (Bundesverband Informationswirtschaft, Telekommunikation und neue Medien e.V.) and ZVEI (Zentralverband Elektrotechnik- und Elektroindustrie e.V.) submitted an official statement to the BMU (Bundesministerium für Umwelt, Naturschutz und nukleare Sicherheit) regarding the upcoming amendment to the ElektroG.

Among others, the subject of collection quota was addressed, as Germany is likely not to reach the collection rate of 65 percent, which will apply from 2019 onwards: Bitkom and ZVEI share the findings from surveys which see gaps in consumer information. They appreciate and support the idea of a nationwide information campaign. A respective market research identifying and measuring public awareness of the subject is planned to be launched by Stiftung EAR this year, so that consequently a respective information campaign could be developed.

With regard to the correct recording of the returning quantities and the calculation of the collection rates, according to Bitkom and ZVEI, the following aspects have not been adequately considered so far:

time period between placing on the market and return of the EEE, i.e. for some product groups the volume placed on the market is much higher than the take-back quantities;

weight of electrical and electronic equipment;

changes in the product scope, as the “open scope” is now applicable

“Alternative” disposal routes, implicating recycling paths other than regularly planned, i.e. robbing of cables, or disposal of WEEE in containers for mixed waste in private households.