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UPDATE Germany: Product design issues strengthened through waste legislation proposal!

After France has already taken on the lead among the member states in connection with the EU’s “Circular Economy Action Plan” and its strategy for sustainable products (e.g. “Reparability Index” labeling required since January 1, 2021), the trend towards strengthening sustainable product design in the context of waste legislation is also progressing in Germany.

At the end of January 2021, the lead committee’s recommendation to the German Federal Assembly on the Draft Law amending the Waste Electrical and Electronic Equipment Act from September 16, 2020 and December 16, 2020 was published.

The committee’s recommendation now clarifies that in future consumer removability for batteries will be required. It is no longer sufficient that qualified personnel can remove incorporated batteries. This amendment to the existing requirement aims at extending the useful life of consumer products such as smartphones, tablets and notebooks. In the future, this will be coupled with measures to ensure the availability of spare parts, such as those requirements already implemented for household appliances based on the Eco-Design Directive (from March 2021).

At EU level, this topic is currently being addressed by the initiative “Designing mobile phones and tablets to be sustainable”. The aim of this proposal is, among other things, to ensure that cell phones and tablets can be repaired, upgraded and maintained by consumers. Possible regulatory action may be taken on aspects such as

  • Battery accessibility;
  • Durability;
  • Availability of spare parts; and
  • Ability for disassembly.

The public consultation on the initiative is scheduled for the first quarter of 2021.

If you would like to learn more about recent developments, the NovaLoop GLORIA module will keep you updated and provide you with regulatory updates relevant to your business in a timely and comprehensive manner!