Key takeaway
What This Development Means
Germany's Federal Gazette has published an Umweltbundesamt order reclassifying (octahydro-4,7-methano-1H-indendiyl)bis(methylene) diacrylate, CAS 42594-17-2, from water hazard class 2 to class 3 under the AwSV. The change takes effect 15 days after official publication and may raise relevant installation hazard levels, notification, inspection and specialist-contractor requirements.
Does WGK 3 create a new EU hazard label?
No. WGK is a German water-hazard classification used under the AwSV for installation controls. It is separate from CLP classification and labelling. Suppliers should update relevant German documentation, but should not invent a CLP hazard statement solely from the WGK change.
Will every mixture containing the diacrylate become WGK 3?
No. Mixtures are classified under AwSV calculation or test rules, including concentration and hazard-factor provisions. Operators need the composition and applicable derivation method. The substance's WGK 3 classification must be considered, but the finished mixture requires its own documented conclusion.
Source basis: Federal Gazette, BAnz AT 22.09.2026 B6
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, Chemical Abstracts Service number 42594-17-2, 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 takes effect 15 days after publication, on 7 October 2026.
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 or mass. 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.
Manufacturers, importers and distributors should update German safety and product-stewardship records and communicate the new WGK to customers. Site operators should locate the substance and relevant mixtures, confirm maximum inventory, recalculate installation hazard levels and review containment, notification and inspection status with the competent authority or an AwSV specialist where needed.
Foresight analysis: the sharpest operational effect may occur at installations near a section 39 volume or mass boundary. A classification change alone can move a facility from level A to B or from B to C, triggering controls even where throughput and equipment have not changed.
Complete substance and installation mapping before 7 October 2026, prioritising sites whose inventories cross the WGK 3 thresholds in section 39.
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