Germany

German Environment Agency Moves Diacrylate To Highest Water Hazard Class

Germany’s UBA reclassified the named diacrylate, identification number 10941, from WGK 2 to WGK 3. The water-hazard classification has applied since 7 October 2026; installation consequences depend on the applicable AwSV criteria.

Dr Steven Brennan

2 min readAI-drafted, expert reviewed

Industrial acrylate storage tanks with intact concrete secondary containment at a German manufacturing site

Germany Water Hazard Classification Rises To WGK 3

The German Environment Agency (Umweltbundesamt, UBA) has reclassified (octahydro-4,7-methano-1H-indendiyl)bis(methylene) diacrylate, UBA identification number 10941, from water hazard class (WGK) 2 to WGK 3. The order was published as BAnz AT 22.09.2026 B6 in the Federal Gazette and has applied since 7 October 2026, the fifteenth day after publication.

WGK 3 is the highest of Germany's three substance-specific water hazard classes. It denotes substances regarded as highly hazardous to water. The classification operates under the Ordinance on Installations Handling Substances Hazardous to Water, known as the AwSV. It is distinct from European Union harmonised classification under the Classification, Labelling and Packaging Regulation and does not itself create a new CLP label.

The order changes the official hazard input used for German installation regulation. It does not impose one identical technical measure on every operator. Consequences depend on the type of installation, the physical form, volume or mass handled, location and existing containment and inspection arrangements.

WGK 3 Can Raise An Installation's AwSV Hazard Level

Under section 39 of the AwSV, an installation's hazard level is determined from water hazard class and relevant volume for liquids or mass for solids and gases. For WGK 3 material, more than 0.22 cubic metres or 0.2 tonnes and up to one cubic metre or tonne produces hazard level B; more than one and up to ten produces level C; and more than ten produces level D. The corresponding WGK 2 levels are lower at several bands.

An increased installation level can affect advance notification under section 40, suitability assessment, documentation, operating instructions, specialist-contractor involvement and inspections under sections 41 to 47. Existing-installation and transitional provisions must be assessed case by case. Mixtures also require a separate AwSV derivation, so the neat substance's WGK 3 status does not mean every mixture containing it automatically has the same class.

Official source

Federal Gazette, BAnz AT 22.09.2026 B6

bundesanzeiger.de

Questions about this change

Does Germany's WGK 3 classification for the diacrylate create a new CLP hazard label?

No. Germany's WGK 3 classification concerns water hazards under the AwSV installation framework. It is separate from CLP hazard classification and labelling.

Does every mixture containing the diacrylate automatically become WGK 3 in Germany?

No. A mixture containing the diacrylate requires classification under the applicable AwSV calculation or test rules. The substance's WGK 3 classification is relevant, but does not automatically determine every mixture's class.

Dr Steven Brennan

CEO and co-founder of Foresight, and a co-opted member of ECHA's Committee for Socio-economic Analysis. He holds a PhD in chemical engineering.

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