In Germany, the production of substitute construction materials and their use in technical structures are regulated by the Secondary Aggregate Directive. It distinguishes between a total of 16 materials and 27 material classes.
Key paper of the federal government
A regulation currently being planned by the German federal government to define when substitute constructions cease to be waste is now intended to close the gap that has arisen and create legal certainty. The problem with the paper presented by the Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV) lies in the limitation on few selected mineral materials and material classes that are granted product status. Industry representatives see this as a contradiction to the scientifically based concept of the Secondary Aggregate Directive – with considerable negative consequences for the circular economy.
Secondary aggregates are generally considered waste until they are installed. If manufacturers wish to declare them as products, they must provide evidence in accordance with the Circular Economy Act. The planned regulation on end of waste in Germany is intended to create legal clarity.
Survey commissioned by the associations
In order to be able to provide a more accurate impact assessment, eight German associations and interest groups joined forces at the end of 2023 and commissioned the economic research company Prognos AG to conduct a survey. The focus of the study was on how the sales and use of secondary aggregates would change under the planned new end of waste regulations.
Opportunities and risks
A total of 457 people took part in the online survey, and the results were clear: more than three-quarters of respondents expect an increase in landfill if the German government implemented its current key issues paper. With a focus on product status only for selected ‘best’ classes, the assessment is that demand for other material classes would decline. Yet the opportunities for more recycling would be enormous: in its analysis of the results, Prognos clearly found that 77 % of participants believe that product status for all secondary aggregates of all material classes would lead to an increase in application and recycling volumes.
Federal ministry must act
The detailed survey results were also officially handed over to the responsible ministry when the report was published. It remains to be seen whether the industry’s concerns, which are now backed up by reliable data, will be incorporated into a new draft.n.
Excerpt from the results of the online survey conducted by Prognos AG
The complete German PROGNOS study can be downloaded here
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