Germany Consults On Expanded Chemicals-Law Sanctions

Germany's environment ministry is consulting on a draft third amendment to the Chemicals Sanctions Ordinance, or ChemSanktionsV. The proposal would update criminal and administrative offences for breaches of EU chemicals law. The written hearing for German states and associations runs until 23 November 2026. Ministry notice, updated 26 October.

The ministry states that the draft has not yet been agreed between ministries. It is a proposal, not an adopted sanctions regime. Consultation status.

REACH Restrictions And Firefighting Foams

The draft updates offences linked to REACH Annex XVII restrictions. Named entries include polycyclic aromatic hydrocarbons, PFAS in firefighting foams and 2,4-dinitrotoluene. The sanctions refer to the conditions in the underlying EU restrictions. They do not create a new blanket ban on those substances. Draft Article 1, item 2.

For PFAS firefighting foams, the proposal also covers specified labelling and stock-labelling duties. Further provisions concern permitted uses, emissions and exposure reduction, separate collection and management plans. Draft Article 1, item 3.

Labelling And Chemicals Data

Other proposed changes cover revised EU classification, labelling and packaging requirements, F-gas labelling and data-submission duties under the common chemicals-data platform regulation. The draft also updates provisions relating to biocides and mercury reporting. Draft Article 1, items 4–8.

The explanatory memorandum describes the ordinance as a means of enforcing directly applicable EU duties through German criminal and administrative sanctions. It distinguishes those enforcement provisions from the underlying EU requirements. Memorandum, section A.I.

Proposed Commencement

Article 3 would bring the amendment into force the day after promulgation. The draft contains placeholders rather than an adopted calendar commencement date. The consultation deadline is therefore not the date on which the proposed sanctions would apply. Draft Article 3.