DA calls for swift revision of the EBV

What does the current industry association initiative mean for our sector?

The planned revision of the Ersatzbaustoffverordnung (EBV) is currently gaining momentum. For our companies, this is an important development, as it is about greater practical applicability, less bureaucracy, and improved framework conditions for the use of recycled construction materials. For this reason, the German Demolition Association has joined an industry-wide initiative which, in a joint letter to the Federal Minister for the Environment, Climate Action, Nature Conservation and Nuclear Safety, Carsten Schneider, calls for a swift revision of the EBV.

How the current industry initiative came about

The starting point was the Federal Environment Agency’s evaluation report on the first year of implementing the EBV. In a scenario-based exercise, feedback from practice, enforcement authorities and industry was analysed. This process identified so-called “low-hanging fruits” – adjustments that can be implemented in the short term without changing the level of protection for the environment and human health.

Against this backdrop, several associations along the mineral material value chains joined forces to initiate a prompt revision based on these findings. The aim is to implement broadly supported improvements quickly, rather than delaying the process through fundamental debates.

What the proposed adjustments are about

The focus is on practical simplifications, such as:

  • simplifications in analysis and testing procedures
  • clarifications regarding installation conditions
  • relief from documentation requirements
  • greater legal certainty in enforcement

These measures provide immediate support in day-to-day site operations and help make procedures more efficient and predictable.

Perspective of the construction industry: marketability in focus

For the German Demolition Association as well as the construction industry associations – the Central Association of the German Construction Trade and the Main Association of the German Construction Industry – the primary focus is on the marketability of recycled construction materials.

Because for our companies, one principle applies: only if materials can be used and specified in tenders with legal certainty can trust, investment security and stable markets develop.

Why the issue of “end-of-waste” remains central for us

A key factor for functioning circular systems is the question of the so-called end-of-waste status – in other words, when a recycled construction material is no longer legally considered waste, but a product. The DA continues to advocate for a regulation on this issue within the EBV.

The reason is simple: the existing structure of the EBV already provides a clear, quality-assured framework that creates legal certainty and can serve as a blueprint for other material streams.

Current status of the process

Based on discussions to date, the Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety plans to present a draft revision of the EBV by mid-year. This will then be followed by consultations with the federal states and associations.

During this phase, associations and companies will have the opportunity to submit statements and contribute practice-relevant input. The DA will, of course, participate actively and contribute the experience of its member companies. The Ministry’s goal is to proceed swiftly with the subsequent parliamentary process.

Joint steps, a clear course

The current industry initiative deliberately focuses on points where there is broad consensus. These improvements provide immediate benefits for practice and are therefore also supported by the DA.

Independently of this, the DA continues to actively pursue the issue of end-of-waste status. The objective remains a reliable legal framework that not only enables circular economy practices, but also makes them economically viable.

Conclusion for our companies

The planned revision of the EBV is an important step towards greater practical applicability and clarity in enforcement. Short-term improvements are in sight – and the fundamental questions surrounding the marketability of recycled construction materials remain firmly on the agenda.

Download PDF DA calls for swift revision of the EBV (in German)

Download