Information and communication technology (ICT) and electrical and electronic equipment

The use and lifespan of electrical and electronic equipment have declined in recent years, while repair rates remain consistently low. As a result, the quantity of electrical and electronic equipment placed on the market has steadily increased. In 2022, it reached 3.26 million tonnes, double the amount of a decade earlier (2013: 1.6 million tonnes). The annual collection rate for waste electrical and electronic equipment (WEEE) has remained well below the current statutory collection target of 65 percent in recent years. In 2021, the collection rate was only 38.6 percent. High collection losses mean that the total yield of secondary raw materials is much lower than potentially possible.

Among the obstacles to implementing the circular economy for electrical and electronic equipment, the prevailing market conditions and cost structures play a key role. Equipment prone to failure, software obsolescence, new technology trends and consumer demand for new products drive increasing consumption of electrical and electronic equipment. Repairs are often not carried out due to factors including design features that prevent repair, poor product quality and poor conditions for independent repair businesses. High repair costs compared to the purchase price of new, often cheaper products and the low residual value of the product to be repaired discourage consumers from choosing repair. Additionally, a lack of care during collection and take-back, as well as incomplete pre-treatment, separation and sorting of waste devices and their fractions, result in inadequate removal of pollutants and separation of recyclable materials. This limits the optimal recovery of materials and leads to sorting errors. The recovery of raw materials (some of which are critical and strategic) is not economically viable under current recycling methods, especially when these materials are present in low concentrations. 

The following regulations and initiatives are currently in preparation and provide important frameworks for the objectives of the NCES. 

EU Ecodesign for Sustainable Products Regulation (ESPR): This regulation replaces the Ecodesign Directive and expands its scope to cover most products, introducing requirements for material efficiency, durability, reusability, repairability, recycled content and information obligations, including a digital product passport (DPP). Negotiations on individual measures for product groups are expected to begin by late 2025. The ESPR also makes it possible to prohibit the destruction of unsold products (overstock and returns) and introduce a reporting obligation on these products. 

Electrical and Electronic Equipment Act (ElektroG): In line with the coalition agreement, a revision of ElektroG is planned for the current legislative period. The Federal Government presented a draft revision on 16 October 2024. The revision aims to increase collection rates for waste equipment, minimise fire risks associated with improper handling of battery-containing devices, improve the recovery of resource-relevant metals and plastics during the treatment of waste equipment and promote preparation for reuse. 

Extending the lifespan and use of electrical and electronic equipment is the most important lever in reducing environmental impact and raw material demand. 

Based on the vision of a comprehensive circular economy for 2045 presented in Section 1.3, and complementing the guiding principle and overarching goals formulated in Section 2, the following additional goals apply to this action area:

  • Design for circularity is the key principle for electrical and electronic equipment. Equipment is fundamentally designed to maximise technical longevity and lifespan, support reuse, enable repairs, and facilitate remanufacturing, repurposing and recycling in order to ensure materials remain in circulation for as long as possible.
  • Cycles should be as closed as possible while reducing negative social impacts across the supply chain.
  • Software and security updates are available for an adequate period of time, and software and hardware are upgradeable.
  • Electrical and electronic equipment is used and reused by consumers for a long time.

To achieve these goals, the following measures, among others, are required at national or EU level.

Promoting design for circularity

Design to enable a stronger focus on circular economy principles, including repairability, durability, easy access to repair information, avoidance of hazardous substances, easy access to and replacement of components, spare parts, batteries and parts containing pollutants, use of recyclable materials and recycled content, use of material combinations and forms of assembly which, where technically feasible, allow for easy disassembly and separation of individual parts. As part of the ESPR, support for overarching measures that facilitate the cross-manufacturer use and interchangeability of parts in ICT products, such as batteries, standardised ports and power adapters. This extends product lifespan, reduces the overall number of components that have to be offered, and facilitates the repairability and availability of spare parts .

Strengthening the reuse of ICT and electrical equipment

Public procurement has significant market influence and a role model function in many submarkets. In reviewing a potential revision of the federal procurement guidelines (AVV Klima und Umwelt – the General Administrative Regulation on the Procurement of Climate- and Environmentally Friendly Services), taking into account outcomes from the public procurement reform package, prioritising the procurement of used and remanufactured ICT and electronic products will also be considered (see Section ‎4.11).

It should also be examined whether public sector organisations could reintegrate their waste devices into circulation, (such as by participating in refurbishment platforms or donating devices to schools and non-profit organisations).

The market for refurbished electrical equipment is growing, but its share of the total market remains low. To strengthen this market and provide consumers interested in second-life devices with clear product identification, reliable quality seals are needed. 

Support for the introduction of a quality seal by suppliers of refurbished electrical equipment, helping consumers identify suitable reuse options. To ensure that these seals can also be used in public tenders, procurement regulations should also be taken into consideration.

Societal awareness of the importance of extending product lifespan and use of electrical and electronic equipment is increasing, contributing to higher collection and recovery rates. Numerous, mostly private initiatives play a key role in this shift and will be supported, for example mobile phone collection schemes (for example, at ALBA Berlin or in schools).

Consideration should be given to how existing quantity monitoring systems can be further developed as a basis for future regulatory measures. 

Strengthening circularity at end-of-life

Separate collection, sorting and recovery must be improved in order to ensure that valuable materials from ICT and electrical and electronic equipment are properly reintegrated into material cycles at the end of their technical lifespan or when no longer used due to consumer preferences.

Collecting more waste equipment separately, in a way that avoids as much damage and destruction as possible, first requires strengthening enforcement, which also falls under the responsibility of the Länder, of the ElektroG and the Commercial Waste Ordinance (GewAbfV). In addition to ensuring easily accessible collection infrastructure and raising consumer awareness, this includes reducing illegal exports of waste electrical and electronic equipment (WEEE) and facilitating intra-European shipments in preparation for reuse and recycling. This will help keep reusable or recyclable devices, components and materials in circulation in the internal market (see analogous measures in Sections ‎4.4 and ‎4.6).

Improving recovery of waste electrical and electronic equipment

In connection with the upcoming revision of the WEEE Directive, Germany should support the option of  more extensive requirements for the treatment of WEEE, particularly to promote high-quality recycling, are considered. This includes, for example, material-specific recycling targets and minimum recycled content targets. In this context, discussions should also explore whether and how eco-modulation within extended producer responsibility (EPR) could be introduced at European level to create incentives for circular ICT and electrical and electronic equipment. 

A key supporting measure is the promotion of R&D, particularly for open innovation models. Open‑source hardware increases transparency and accessibility, making it easier to maintain, repair, remanufacture and recycle ICT and electrical and electronic equipment. For its part, open-source software can enhance hardware longevity by supporting long-term compatibility with software. Consideration should be given to whether existing funding programmes could support the development and scaling of open innovations, or whether new funding measures should be introduced specifically for this purpose.