Metals

Germany relies heavily on imports to meet its demand for many metals. At the same time, the transition to a climate-neutral economy requires large quantities of metals. A functioning circular economy can make a significant contribution to securing the supply of raw materials with regard to metals, as high-quality recycling enables metals to be kept in circulation almost indefinitely. 

In addition, metal recycling has the potential to reduce environmental impacts compared to primary production; the extent of this potential depends on the specific metal, its application, and the waste stream in question. For instance, recycling copper from cables has a significantly lower carbon footprint than primary production. However, producing secondary copper from construction waste, for example, generates roughly three times as much CO₂ as production from cables, meaning it is not always environmentally advantageous compared to primary production. 

In this context, ship recycling may become increasingly important. The German merchant fleet comprises 2,500 vessels, 800 of which will be 25 years or older within the next 5 years, including 150 state-owned ships. The German inland shipping fleet consists of 2,400 vessels, with the average age in many segments exceeding 50 years. Establishing recycling capacity is a crucial step toward a maritime circular economy and is necessary to ensure the efficient use of scarce raw materials. The vast majority of a ship’s mass consists of steel, and its recyclability and CO2 reduction potential in relation to steel recycling and green steel is currently being widely discussed. However, due to the high weight of ships, other materials, although present in much smaller proportions, are also relevant. Strengthening shipbuilding based on the cradle-to-cradle principle, including ship recycling, is stipulated in the coalition agreement but remains in its early stages. 

Barriers to a circular metals economy:

  • Design for recycling and R-strategies such as reuse currently play only a minor role in the action area of metals.
  • Many metals, particularly critical or strategic metals, are used in low concentrations, making recovery difficult.
  • In most cases, there is no available information on which alloys are used in which components or products.
  • While well-functioning material cycles have long been established for some metals, the end-of-life recycling rate for others, particularly technology metals, is often below one percent.
  • The high number of different steel and aluminium alloys that mix during scrap collection complicates the reuse of recovered secondary raw materials in the production of high-quality wrought steel and aluminium alloys.
  • Although multi-stage analysis and sorting processes exist, they are not used across the board because more complex recycling processes are often not economically viable.
  • Greater separation, pre-disassembly and manual processing would improve scrap quality but also lead to higher costs.
  • Circularity considerations have so far played little role in shipbuilding, starting from the design phase. Current regulations, such as the EU Ship Recycling Regulation (EU) 1257/2013,[i] are not designed to promote or prescribe future recycling processes or recyclable and material-efficient ship designs. Instead, these regulations and standards aim to minimise risks and negative impacts associated with ship recycling, for example on the environment and working conditions.
  • Ship recycling in Germany is still in its early stages. The necessary regulatory frameworks and approval procedures for ship recycling facilities must still be established. Ship recycling is generally capital-intensive, and its profitability is difficult to predict, depending on several factors (for example, demand for recovered components and materials, contaminated waste disposal costs, labour costs, investment costs in recycling technologies, and the level of automation). 

[i] Under the EU regulation, each Member State designates a contact point responsible for providing information and advisory services on ship recycling. In Germany, the designated contact point is the Federal Maritime and Hydrographic Agency (BSH).

Various regulations and initiatives are already in preparation and provide important frameworks for the objectives of the NCES. These conditions will be taken into account when implementing the NCES:

  • Dialogue Platform on Recycled Raw Materials: The German Mineral Resources Agency (DERA) has developed options for increasing the share of recycled raw materials, including metals.
  • In mid-August 2023, the new Batteries Regulation (EU) 2023/1542 came into force. Among other provisions, it sets minimum recycling targets and mandatory recycled content targets for certain metals in batteries.
  • In November 2013, the EU Ship Recycling Regulation (EU) 1257/2013 was adopted. It establishes rules for the safe and environmentally sound recycling of ships and aims to make the associated activities safer and more environmentally friendly. The regulation stipulates that since 2018, merchant ships flying the flag of an EU Member State (with a gross tonnage over 500 GT) may only be recycled at certified shipyards (EU list).
  • The definition of climate-friendly steel from the BMWK concept Lead markets for climate‑friendly basic materials.

For the action area metals, the focus is primarily on a recycling-based strategy. The upstream elements of the R-strategies, which have a closer link to specific products, are assigned to the product-related action areas (such as vehicles, ICT and circular production). 

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:

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

  • Reducing the material footprint (raw material consumption, RMC) for metals.
  • Further developing and supporting recycled content targets at EU level in the medium to long term, in cooperation with industry. A potential example for metals would be EU-wide, material-specific targets for the use of recycled content in components containing technology metals.
  • In line with the European Critical Raw Materials Act (CRMA), which aims to cover at least 25 percent of annual demand for strategic raw materials through recycling and to significantly increase the recycling volumes of individual strategic raw materials in waste, the Federal Government aims to:
  • Reduce import dependency for aluminium processing, particularly by increasing recycling
  • Reduce import dependency for copper, particularly by increasing recycling
  • Meet part of the demand for lithium through recycling from lithium-ion batteries
  • Supporting the creation of appropriate frameworks for establishing a sufficient number of ship recycling facilities in Germany, with a particular focus on increasing the share of clean steel scrap used as green steel.

Establishing recycling processes and capacities, particularly for strategic metals

To achieve the goal of enabling functional recycling processes for critical and strategic metals, the following measures, among others, are required at the federal or EU level:

  • Supporting the EU-wide introduction of digital product passports (DPPs) for metal-containing products such as vehicles, ships, and electronic goods.
  • Expanding and further developing suitable funding programmes; integrating a funding focus on strategic metals within the DigiRess programme, which is to be consolidated and expanded.
  • Establishing a funding programme on the introduction of new technologies for the recovery of metals from slag and ash.
  • Supporting standardisation processes to improve recycled content quality for metals.
  • Reviewing the introduction of separation requirements for strategic metals (such as rare earth metals) from commercial waste.

Creating a dynamic materials register 

A dynamic materials register will be developed, based on work such as the mapping of the anthropogenic stock by the German Environment Agency (UBA). This register will provide information on material flows, alloy types and their chemical composition, including the presence of critical and technology metals in products and waste streams. 

Increasing the transport of steel scrap and recycled steel by rail and inland waterways

As transport modes particularly suited to bulk materials, rail and inland waterways play a key role in transporting waste and residues, which helps to minimise energy consumption and emissions. However, increasing their role in transport requires suitable facilities and terminals for transferring materials to rail and waterways. Steel scrap, for example, is becoming increasingly important in the steel industry, which aims to make German steel carbon neutral by 2045. Given this development, it is crucial to reduce greenhouse gas emissions in transport by switching to rail and waterways, and to increase transport capacities. To support the shift specifically to rail, the track access charge assistance could be extended. The expansion of infrastructure and the development of innovative freight transport concepts for recycled steel could be supported through state investments or funding programmes. Regarding inland waterways, businesses operating in a circular economy at ports face several barriers that make the approval processes for handling and storing recycling materials significantly more difficult. This is particularly an issue when handling or transporting not only steel scrap but also other recyclable materials such as construction materials for reprocessing. To address these challenges, measures from the National Ports Strategy, adopted by the Federal Cabinet on 20 March 2024, will be implemented. Key measures include: 

Measure 1.22: Strengthening existing port infrastructure and expansion potential, ensuring long-term sustainability against competing land uses. Priority should be given to future-oriented uses, where necessary with deep-sea access, such as for the energy transition, energy supply and circular economy.

Measure 1.7: Reviewing immission control and water regulations for goods handling in ports to reduce barriers for handling port-relevant goods without lowering environmental standards. In particular, this includes the classification of substances hazardous to water into water hazard classes (section 3 and appendix 1 of the Facilities for Handling Substances that are Hazardous to Water (Verordnung über Anlagen zum Umgang mit wassergefährdenden Stoffen, AwSV). 

Supporting innovative ship recycling technologies and fostering collaboration among relevant stakeholders

To advance innovations and technologies for sustainable ship recycling, the Federal Government has been supporting the ShipRec innovation network since 2023. The 13 project partners currently involved, including the Maritime Cluster Northern Germany (MCN), aim to identify innovative approaches and technological advancements in ship recycling. At the same time, the initiative seeks to foster dialogue between key stakeholders across the entire value chain and drive forward concrete projects for a more sustainable ship recycling industry. This includes both solutions to regulatory approval challenges and innovative technological concepts. The goal is to develop scalable and transferable processes for dismantling ships and large maritime structures, thereby promoting sustainable dismantling, supporting optimal use of existing resources and keeping valuable raw materials within the local economy. To achieve this, the approval regime for ship recycling companies must first be streamlined.