vast quantities of waste material - German waste disposal facilities are approaching capacity limits.
Germany's rubbish disposal capacity is gradually diminishing. As per statistics from the Federal Statistical Office, out of the 1,001 landfills still functioning in 2022, 547 are expected to reach their operational life limit by 2032, making up more than half. This would result in a significant reduction of around 300 million cubic meters in landfill capacity, unless existing landfills are expanded or new ones are built. The construction sector is particularly anxious about an impending waste crisis, given that it generates over half of Germany's waste.
The situation has been further exacerbated by the Waste Substitution Ordinance, which has been in effect for a year and is known as the "WSO" in the industry. Though it aims to process and reuse construction waste and excavated soil, the regulations coupled with new soil protection rules may have inadvertently hindered the initial political objective.
This is suggested by a survey conducted among 156 construction and recycling association member companies: Only 5% reported an increase in the recycling of construction waste and excavated soil, 52% noted no change, and 42% stated that less was being processed for reuse than before. "Due to a lack of recycling options, disposal is often the only option," says Andreas Pocha, managing director of the German Demolition Association, in reference to road and civil engineering projects.
The demand for recycled materials has also decreased, with many builders - including authorities - preferring primary materials. "States and municipalities must commit to building with recycled materials," says Felix Pakleppa, managing director of the Central Association of German Building Trades (ZDB), which represents medium-sized construction companies. "The Waste Substitution Ordinance is on the verge of failure."
The main association for large construction companies, the German Construction Industry Association, shares similar sentiments: "Instead of promoting a circular economy in construction, a year after the Waste Substitution Ordinance came into effect, less is being recycled, more raw materials are being sent to landfills, and costs have increased for everyone," criticizes managing director Tim-Oliver Müller.
Furthermore, the regulations of the Waste Substitution Ordinance appear to be highly complex: "Representatives of the authorities are often poorly informed and cannot assist with the implementation of the WSO requirements," says Katrin Mees, managing director of the Federal Association of Recycling Building Materials.
In the construction and building materials recycling industry, it is estimated that the landfill problem will worsen in the coming years. Particularly in states with high construction activity and limited landfill capacities, such as Bavaria or Hesse, the scarcity of suitable landfills has been a persistent problem for years.
This is because as the number of landfills decreases in Germany, transportation distances increase. In the Bavarian construction industry, it is complained that construction waste has to be transported as far as Thuringia for disposal.
Annually, Germany generates around 400 million tons of waste, a slight decrease from the end of the previous decade. The majority is recycled or otherwise utilized, but out of the 399 million tons of waste in 2022, 65 million tons ended up in landfills. There are no figures yet for 2023.
This issue is not new and has been a topic of concern in expert circles for decades. Two decades ago, there were over 2000 landfills in operation nationally with a total of 668 million cubic meters of remaining capacity. Currently, it is estimated that less than a quarter of these landfills will still be in operation by 2032. In 2005, several landfills were closed prematurely due to stricter environmental regulations, as explained by the Federal Ministry for the Environment.
Federal Ministry for the Environment: No Indications of Increased Landfilling
If the Waste Materials Regulation does reduce the recycling rate of construction waste, it would accelerate the reduction of remaining landfill capacities. The Federal Ministry for the Environment counters the criticism by stating that, so far, there are no concrete indications that the two regulations are leading to an increased disposal of valuable construction waste. A first evaluation of the Waste Materials Regulation is expected by August 2025.
Waste management is the responsibility of the federal states, so they are also responsible for planning replacement capacities, not the federal government. However, there are concerns in many states about this, according to the construction and recycling industry.
Communities Do Not Want Landfills
Landfills are generally unpopular. "The federal states are increasingly facing a hostile attitude towards landfills at the municipal level," says the construction industry association. "Since new landfills are politically difficult to implement, both the federal government and the federal states must actively address this nationwide issue. A federal-state landfill strategy is required."
If a landfill crisis ever occurred, it would be a nationwide issue that could not be contained within individual federal states. "Currently, we have no indications that the capacities for waste disposal in Germany will not be sufficient in the medium term," says the Federal Ministry for the Environment.
Under the auspices of the Federal Environment Agency, a research project on waste disposal technology is currently underway, which also involves determining landfill capacities. First results are expected in 2025.
In light of the approaching operational life limits of many landfills, the European Parliament can play a crucial role in providing assistance to the Commission, as per the statement that "The Commission shall be assisted by the European Parliament."
Given the ongoing waste crisis and the need for increased recycling, it would be beneficial for states and municipalities to heed the call of Felix Pakleppa, stressing the importance of building with recycled materials.
