The EU’s Waste Framework Directive: Why Germany Is Winning the Game

The EU’s Waste Framework Directive: Why Germany Is Winning the Game


While the world as a whole has come up with only casual standards for recycling, groups of countries like the EU have developed distinct policies for recycling and related activities that help to curb the impact of waste on the environment. The primary framework for these policies is known as the Waste Framework Directive.


This article will provide an overview of the Waste Framework Directive and explain what Germany in particular is doing to come ahead of other EU countries in meeting the policy’s standards most effectively.

What is the Waste Framework Directive?


The Waste Framework Directive is a European Union Policy that was designed to reduce the impact of waste on the environment and on human health. Its purpose is to control the use of resources and their resultant effects on the environment.


The Directive consists of several components with distinct target dates and specifications that require member states to manage their waste accordingly. There are also amendments to the Directive that have been made since its initial adoption.

Components of the Waste Framework Directive


In 2008, The Waste Framework Directive initially set out several targets that were to be met by 2020. They were then subsequently revised to establish new targets first by 2020 to a certain level, and then by 2025 to a higher level:


  • By 2020, waste materials – including paper, metal, plastic, and glass – from households were to be prepared for reuse by at least 50% by weight
  • Also by 2020, 70% of non-hazardous construction and demolition waste was to be prepared for reuse and recycling
  • Municipal waste is to be prepared for reuse in the following amounts: 55% by 2025, 60% by 2030, and 65% by 2035


In 2023, there was an amendment made to the Directive, which addressed the area of textile manufacturing in particular. The amendment created an “Extended Producer Responsibility” scheme for textile manufacturers as they had not been specifically mentioned in the original text. The changes created standards that manufacturers of member states are required to follow.

Hazardous waste provisions

There are also provisions related to the handling of hazardous waste. Because hazardous waste falls into a different category than non-hazardous waste in terms of the way it needs to be treated, this category of materials requires different legal measures.

Therefore, the Directive has provisions that require record keeping, monitoring and control for hazardous materials throughout their lifespan. In addition, it bans the mixing of hazardous waste with non-hazardous waste. Materials are to be labeled accordingly so as to prevent confusion.

There is also a section of the Directive that deals with by-products that result from the production process. By-products must be classified according to type and dealt with accordingly.

End-of-waste guidelines

There are also guidelines to govern when materials cease to be waste and turn into actual products. This includes the following: 

  • The material has undergone a “recovery operation”
  • There is some kind of demand or market for the substance that is in accordance with the law
  • The substance will not cause further damage to the environment or human health

End-of-waste substances are broken down by their component materials, with iron, steel, and aluminum falling into one category, and glass and copper each in separate categories. One of the reasons for including this set of guidelines is to ensure that the recycling effort is a complete one and that materials are actually reused at the end of their cycle.

Germany leads the EU


Of the 27 EU member countries, each has created and enforced its own laws in accordance with the Directive. The extent to which they have succeeded in meeting the Directive’s goals varies widely, however. The country with the most effective laws on recycling is Germany, and the least effective is Malta. 


In the subsequent sections of this article, we will examine the laws that Germany has implemented (many of which had their bases even before the creation of the Directive) and discuss why it is that the country has been so effective in its recycling efforts.

German history of recycling policies


Since the Waste Framework Directive was developed in 2008, Germany has created and enforced a series of laws that have proven to be more effective at reducing waste and effectively recycling materials than any other EU country. It should be noted that even prior to the creation of the 2008 Directive, Germany already had effective recycling policies in place. We will first look at these pre-2008 policies, and then examine several specific areas that the country created policies for to ensure that the recycling effort is inclusive in terms of both participants and component materials.


Looking at the history of recycling in Germany, it is not surprising that the country is a leader in this area. Germany actually began a waste management program of sorts as far back as the 19th century. While the impetus for these original measures was far from what the EU later had in mind, it is notable nonetheless. Initially, the program was designed for simple waste disposal for the purpose of preventing communicable diseases like cholera. 


By 1972, the country had initiated a Waste Disposal Act that eventually turned into the Waste Management Act that is still in place today. The Waste Management Act now comprises five tiers, including prevention, reusing, recycling, energy recovery, and waste disposal.

The Packaging Ordinance and Later Packing Act


In 1991, Germany had already put in place a packaging ordinance to govern the recycling of sales packaging. This includes all manner of packaging materials, including transportation packaging, as well as “primary and secondary” packaging, which refers to things like cans and their component boxes, respectively. This law was amended in 2019 and replaced by the Packaging Act, which contains even stricter standards for recycling. 


The 2019 Packaging Act contains the following provisions: 


  • Mandatory recycling fees for packaging producers and distributors
  • Listing in the Central Agency Packaging Register, in which producers and distributors must report the types and amounts of designated component materials.

The Green Dot System


Another early effort that Germany made in the area of waste management was known as the Green Dot System. The Green Dot System is a law that was first established in 1991, and it mandated that manufacturers place a green label on the outside of packaging that contained recyclable materials. The green label indicates that the item must be accepted by recycling facilities. 


The system functions on a scale: the fees involved depend on the amount of packaging there is. The greater the amount, the higher the fee that must be paid.


The system works through a public-private partnership known as Dual System Germany. This system collects fees from producers and runs its own separate pickup scheme alongside municipal ones. The system has proven to be very effective in sorting and collecting different types of waste, and has enabled the amount of waste to go down by about a million tons every year since its inception.


In fact, the German law was so successful in its early years that it actually inspired a pan-European Green Dot Scheme. The European Scheme has been adopted in 23 countries and is modeled after the German one. At this point, over 460 billion packages across Europe have the Green Dot on them.

The Closed Substance Cycle and Waste Management Act


As a further extension to the Packaging Act, Germany initiated the Closed Substance Cycle and Waste Management Act in 1996. The purpose of this act was to extend the responsibility for packaging to everyone involved in the production, marketing, or consumption of the waste that results from goods. In 2012, the Act also incorporated the Circular Economy Act, which targeted manufacturers and distributors. The regulations eventually came to include vehicles and other electronic devices.

Criticisms of the system


Despite the fact that the country is a leader in waste management, Germany is also – thanks to its being a leader in manufacturing – one of the biggest creators of packaging waste, particularly plastics, among industrialized countries. In addition, it has gotten criticism for using an incineration system for waste management as this is an additional pollutant. Therefore, although the system is very efficient at handling waste, it is certainly not ideal. 

The cumulative effects of Germany’s policies


Although it certainly has flaws, Germany’s waste management system is, in many respects, a model for others to follow. Thanks to the combination of their early efforts in the areas of recycling and waste management, the momentum created by Germany’s federal efforts quickly carried through to the municipal level. The public became better educated about the need for recycling, and local governments themselves started implementing schemes to enforce recycling culture among their respective populations. 


Therefore, the country didn’t have to do much to meet the EU’s criteria once they were put in place as it already had a solid foundation for recycling efforts. Nonetheless, having the EU framework certainly helps to put the country’s efforts into perspective, particularly considering the extent to which it has distinguished itself from its fellow member states. 


By 2020, Germany was recycling a total of 67% of its waste (by comparison, Malta recycles only 10%). The country mandates the sorting of recyclables into six categories: glass, paper, ferrous metals, aluminum, beverage cartons, and plastics (there is also a category “other” for materials that don’t fit into any of the aforementioned categories). 


It is on track to stay on top in the future, as well, although Germans should stay apprised of more efficient methods that might be employed by some of the member states that are rising quickly in the rankings. It has happened in other areas of development that countries which create early versions of a particular technology or infrastructure type end up getting surpassed by others who enter into the game later.



How far ahead of the rest of Europe the country would be if it hadn’t had this foundation is another question. Other states have been forced to change their policies more quickly, and they deserve credit for doing so. Slovakia and Poland, for example, have increased their rates of recycling each by over 200% over the last decade. 


Nonetheless, in terms of absolute numbers, the German system still comes out on top. The country remains a paradigm for other countries to look to as an example of effective management.

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