According to Euwid, representatives of the ministry provided information on the status of current and upcoming projects at the Berlin Waste Law Conference.

The Federal Ministry for the Environment (BMUKN) is working on a broad package of reforms to waste legislation, focusing on commercial waste, batteries/electronic scrap, the circular economy and EU requirements. Some projects are stalling, while others are nearing implementation.
 
The amendment to the Commercial Waste Ordinance is stagnating due to blockages in the Federal Council, as ministry representative Jean Doumet explained. The issue is expected to return to the agenda in 2026. Carsten Träger (SPD), Parliamentary State Secretary at the Federal Environment Ministry, expects this to happen ‘perhaps in the spring’. The aim of the renewed revision of the Commercial Waste Ordinance is to strengthen enforcement and achieve higher recycling rates for mixed waste.
 
The ElektroG amendment, which primarily aims to reduce fire risks during disposal, provides for new take-back obligations for e-cigarettes, stricter requirements for sorting battery-containing devices and better labelling of take-back points. The Bundesrat approved the amendment to the ElektroG in mid-November and waived the right to refer the matter to the mediation committee. According to the BMUKN, the ban on disposable e-cigarettes repeatedly demanded by waste disposal and environmental associations will not be included in the ElektroG. However, the federal government has promised that the ban will be enshrined in law, although it is still unclear in which law. Health protection could serve as the legal basis. Doumet referred to France and Belgium as countries that have already implemented similar bans.
 
According to Doumet, the action programme for implementing the National Circular Economy Strategy (NKWS) adopted at the end of 2024 is a key project for the coming weeks. The NKWS is to be fleshed out in a package of measures, a draft of which was presented by the BMUKN in mid-October 2025. Although inter-ministerial coordination is proving difficult, particularly on the issue of public procurement, State Secretary Träger expects the programme to be approved by the cabinet as early as the beginning of December.
 
The implementation of EU requirements will also require further extensive work, for example with regard to the new Packaging Act and the amendment to the EU Industrial Emissions Directive, according to Doumet.
 
Sources:

• Euwid Recycling und Entsorgung 49/2025 (2.12.2025)
• Photo: © BMUKN / Florian Profitlich