The skilled trades sector demands practical implementation of the substitute building materials regulation.

The German Confederation of Skilled Crafts praises the new substitute building materials regulation. However, it calls for improvements regarding bureaucracy reduction, legal certainty, and suitability for SMEs.

Every year, around 200 million tons of mineral waste are generated , primarily from construction and demolition work . This waste can be processed into mineral substitute building materials (MEB) and then reused in civil engineering projects, where it replaces primary building materials. The Substitute Building Materials Ordinance (ErsatzbaustoffV), introduced in 2023, established a uniform federal regulation for the use of mineral waste as substitute building materials. It is now slated for reform.

The Central Association of German Crafts (ZDH) generally supports the new version and praises the numerous improvements that the draft bill incorporates.

Planned relaxations

The planned amendment addresses many practical problems and aims to simplify the enforcement of the Substitute Building Materials Ordinance. According to the German Confederation of Skilled Crafts (ZDH), it removes existing obstacles to the use of mineral substitute building materials. The association particularly welcomes the standardization of testing procedures to the short column test. This adjustment enables comparable results and reduces contradictory analyses, duplicate testing, and unnecessary costs.

According to the association, other positive aspects include operational sampling by specialist personnel, clarifications regarding groundwater cover layers and regional background values, the fact that water protection area regulations no longer have priority, the shortened advance notification period, collective delivery notes and the introduction of a small quantity regulation.

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Critical points and demands of the skilled trades

The German Confederation of Skilled Crafts (ZDH) nevertheless sees room for improvement in certain areas . In particular, it calls for the amendment to be implemented more consistently where possible without lowering the level of protection. This concerns the notification requirements for material classes BG-3 and BG-F3, BM-3 and BM-F3, and RC-3, as well as the inclusion of quality-controlled RC-1 in the small quantity regulation.

The German Confederation of Skilled Crafts (ZDH) emphasized that it is crucial for the skilled trades that any promised relief measures are realistically documented and that new obligations are clearly and proportionately defined. Strengthening quality assurance measures is also essential. The amendment offers an opportunity to reduce bureaucracy and improve the marketability of mineral-based substitute building materials. According to the ZDH, the new regulations should promote not only the production but also the use, acceptance, and sale of these materials.

The association believes it is insufficient to postpone national regulations by citing ongoing European work. Germany should actively contribute concrete technical proposals.

These are the demands made by the trades.

• Implementation tailored to SMEs and practical, with uniform enforcement at the federal and state levels.
• Significant reduction in bureaucracy through nationwide standardized digital procedures
• clear rules of responsibility and liability
• Timely provision of all necessary location and material information for quotation and execution
• Ensure regional capacities for laboratories, testing and training, and monitor the consequences of the short column test.
• Legally compliant regulation regarding the end of waste status for quality-assured, harmlessly usable mineral substitute building materials
• Examination of all regulated material classes, waiving of blanket restrictions
• Strengthening demand from public sector clients, particularly through recycling-friendly public procurement
• Binding interpretive aids and the involvement of the skilled trades in practical checks, implementation aids, and in the future evaluation of the relief effects.

The advisors at the Chambers of Crafts will be happy to help you with any legal questions!

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