German associations question proposed regulations

Four Germany-based trade associations have written a joint statement criticizing the draft LAGA (Länder Working Group on Waste) Communication 36 directed to “waste management companies.” The associations say they are mainly opposed to the notion of LAGA enforcement agencies “further tightening” their regulation of waste and recycling hauling firms.

The four associations that issued the statement are the BDE (Federal Association of German Disposal), the BDSV (Association of German Steel Recycling), and two organizations representing wastewater and specialized waste treatment companies.

In addition, the associations have proposed “clarifications” in the Communication 36 text they say would prevent non-uniform enforcement. “This makes it possible to eliminate the scope for interpretation which hinders uniform implementation throughout the nation,” says the associations. The clarifications concern certified activities pertaining to storage, treatment, processing and disposal as well as to confidential data in the monitoring report, say the groups.

A disposal ordinance that has been in force since June 1, 2017, means the numerous enforcement questions need to be clarified “in the interest of all parties involved in the task of [adhering to the ordinance] quickly and practically,” say the associations.

The LAGA has involved stakeholders in a hearing on the drafting of the enforcement text with a comment period that ends August 18, 2017.