Germany’s Federal Ministry for the Environment has proposed a fifth amendment to the Chemicals Act (ChemG) to align national law with two key EU regulations: Regulation (EU) 2024/573 on fluorinated greenhouse gases (F-Gas Regulation) and Regulation (EU) 2024/590 on ozone-depleting substances (ODS Regulation). A public consultation is open until 20 August 2025, inviting comments from industry stakeholders, associations, and regional authorities.
Key Changes to Support EU Climate Goals
The proposed legislation will remove outdated national provisions now governed by EU law and grant regulatory authorities new powers to enforce the updated EU rules. These include the ability to issue production and use bans where violations are detected, particularly targeting the illegal trade or placement of equipment pre-filled with F-gases.
Additional updates will bolster Germany’s Chemicals Climate Protection Ordinance by clarifying the legal basis for expertise requirements and compliance procedures. Similar alignment is also underway for the Chemicals Climate Protection and Ozone Layer Regulations.
Compliance and Enforcement Implications Across Industry
Professionals across the chemicals, manufacturing, and environmental sectors must prepare for stricter enforcement and oversight of substances regulated under the F-Gas and ODS frameworks. This includes hydrofluorocarbons (HFCs), commonly used in refrigeration, air conditioning, and foam-blowing agents, which are being phased down under the F-Gas Regulation due to their high global warming potential.
The ODS Regulation focuses on substances like halons and CFCs, historically used in fire suppression and aerosols. While these are mostly phased out, enforcement remains vital to prevent illegal import or use.
The draft’s focus on preventing market circumvention and reinforcing EU bans sends a clear message: future compliance will require closer scrutiny, updated technical knowledge, and potentially revised supply chain practices.
Next Steps for Industry Stakeholders
All affected parties are encouraged to review the draft legislation and submit comments by the 20 August deadline. Early engagement will help shape how Germany transposes these EU rules, ensuring practical implementation for industries dealing with controlled substances.
