Circular Economy Information Center

In order to make an active and controlled contribution to circular management as a waste generator, it is urgently necessary to have a minimum level of know-how about the disposal of production residues. It is important to understand the definitions of circular management, waste qualities, actors in operational waste management, and the cost structures of operational waste in the circular economy. This enables waste to be viewed like a product, provided with maximum quality, and then marketed to market participants with appropriate technologies.

Legal Regulations for Waste Generators

Another critical aspect in dealing with waste is the fact that it can cause harm to humans and the environment. Accordingly, legislators have heavily regulated this area.

Since presenting all regulations would exceed the scope of the study, the following are specifically addressed, focusing on regulations relevant to manufacturing industries and the production of technical textiles.

For more information on waste law and related guidelines, refer to the CycleTex BW study..

Classification of Waste
  • Determination of Waste Category
  • Formation of Waste Fraction
  • Assignment of Waste Key Number
     
The Waste Law

The waste law relevant to manufacturing companies is based on:

  • Regulations and directives of EU law
  • Regulations and technical instructions anchored in federal law, alongside the Circular Economy Act (KrWG)
  • Execution laws located in state law
  • The waste ordinance and fee schedule in municipal waste law
Circular Economy Act (KrWG)

The KrWG, which came into force on June 1, 2012, replacing the Circular Economy and Waste Act, transposed EU Waste Framework Directive 2008/98/EC into national law. The primary goal of this law is to increase resource efficiency in waste management by strengthening the waste hierarchy, particularly waste prevention, reuse, and recycling, to achieve sustainable environmental and climate protection. The KrWG distinguishes between products, by-products, and waste and defines the end of waste status after waste management treatment in a waste treatment facility. The KrWG also includes requirements for the separate collection of waste. In addition to the obligations of plant operators regarding permits, reporting obligations, registration obligations, obligations of the public-law waste disposal carriers, requirements for waste disposal companies and monitoring organizations are also outlined, as well as requirements for operational organization and waste officers.

One of the key regulations of the KrWG is the five-tier waste hierarchy. This establishes the ranking among waste management measures:

  1. Prevention
  2. Preparation for reuse
  3. Recycling
  4. Other recovery, particularly energy recovery and disposal
  5. Disposal

 

Regulation on Waste Officers (AbfBeauftrV)

The AbfBeauftrV specifies which companies are required to appoint a waste officer.

In broad terms:

  • Those who produce more than 100 tons of hazardous waste (e.g., machine oils, coating and finishing chemicals, dyes)

or

  • produce more than 2,000 tons of non-hazardous waste

must appoint a waste officer (see also §32 AbfBeauftrV). This individual can be appointed from within the company or hired as an external service provider.

Ordinance on Commercial Waste (GewAbfV)

The GewAbfV regulates the requirements for the recycling and pre-treatment of commercial municipal waste as well as certain construction and demolition waste. With the amendment of the Gewerbeabfallverordnung, which came into effect on August 1, 2017, the aim is to achieve the highest possible quality recycling of commercial waste.

Ordinance on Commercial Waste (GewAbfV)
The GewAbfV regulates the requirements for the recycling and pre-treatment of commercial municipal waste as well as certain construction and demolition waste. With the amendment of the Gewerbeabfallverordnung, which came into effect on August 1, 2017, the aim is to achieve the highest possible quality recycling of commercial waste.

The GewAbfV requires that the fractions of paper, cardboard, glass, organic waste, plastic, metal, wood, and textiles be kept separate and stored (§ 3 para. 1 GewAbfV). The annual documentation of the achieved separate collection quota is to be ensured by an expert (§ 3 para. 3). Furthermore, there is a comprehensive documentation requirement on the part of the producer to provide evidence of separate collection through site plans, weighbridge tickets, photographs, and disposal contracts. If the producer fails to fulfill or insufficiently fulfills these obligations, fines of up to 100,000 euros can be imposed. If separate collection is not reasonable for economic or technical reasons, the obligations to separate the recyclable materials are waived (§ 3 para. 2). However, the proof requirements for this are very demanding. If the evidence is deemed implausible, the producer is obligated to have the recyclable materials re-sorted at their own expense.

Ecodesign Directive

While the Ecodesign Directive does not fall under waste law, it is increasingly gaining influence on companies and their product development. Due to the relevance of the topic, it has been included in this context. The Ecodesign Framework Directive was created with the aim of improving the environmental compatibility of energy-related products throughout their entire life cycle by setting uniform European ecodesign requirements.

To avoid liability risks and meet the requirements, producers must ensure that they comply with the relevant regulations. So far, the Ecodesign Directive only applies to a small number of products such as washing machines, refrigerators, and TV sets. In a draft, the European Commission has published a "Sustainable Products Initiative" (SPI) and an EU strategy for sustainable textiles, which also includes textiles, furniture, steel, cement, and chemicals in ecodesign.

European Green Deal

To understand the desired political direction and future demands on businesses, it is worthwhile to focus on the European Union and the provisions and framework emerging from the Commission. Under the title "Green Deal," a vision of the European Community is understood, which aims to further strengthen the European Union's leading role in climate protection. By 2050, the 27 EU member states aim to become climate-neutral. At least 55% of greenhouse gas emissions are to be reduced by 2030. Measures include the reuse or recycling of all packaging put into circulation in the European Union and the introduction of a mandatory minimum proportion of recycled materials in product manufacturing (e.g., rPET in yarn production).

This consequently contributes significantly to the circular economy and is particularly relevant for all manufacturing companies. Just by doubling the use of recycled materials in all German productions, a further 60 million tons of CO2 equivalents can be saved annually. Manufacturing companies and waste generators must seize the Green Deal as an opportunity. The European Commission stipulates in its measures and objectives that producers should avoid waste, and if this is not possible, its economic value must be recovered. With a waste avoidance strategy and the circular management of waste, companies must prepare for the consequences of the Green Deal.

EU Strategy for Sustainable and Circular Textiles

To implement the European Green Deal, the European Commission has established the EU Strategy for Sustainable and Circular Textiles with the aim of making this sector more environmentally friendly and competitive. The specific goals include, among others, ensuring that by 2030, the majority of textile products on the EU market consist of recycled fibers and are free from hazardous substances. The EU Commission relies on requirements for design specifications and clear labeling of textiles, as well as expanding manufacturer responsibility and providing economic incentives for more sustainable product design. The EU strategy primarily focuses on used textiles but also presents an opportunity for manufacturers of technical textiles to serve as role models within the industry.

Would you like to learn more about the connections and definitions within the circular economy?
Check out the CycleTex BW study for more information »

Actors in the Circular Economy

Once waste leaves the company, it goes through various stages until the end of its waste status. Along the value chain within waste management, there are various activities and corresponding actors. The activities of all participants can contribute to the circular economy. In cooperation, the various actors along the value chain ensure compliant and sustainable waste management. An actor may take on multiple activities listed. For example, waste disposal service providers are often also collectors and transporters.

The actors in the circular economy can be divided into the following groups:

  • Suppliers
  • Waste generators
  • Collectors
  • Transporters
  • Waste disposal service providers
  • Waste sink

For more information and examples of each actor, refer to the CycleTex-BW study!

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