Germany has introduced new national regulations to supplement and enforce the EU's F-gas rules, directly affecting importers, distributors, and users of fluorinated greenhouse gases (F-gases) in the chemical supply chain. The updated framework, effective from April 2026, imposes stricter obligations on quota declarations, certification, and penalties for illegal trade, requiring immediate attention from overseas buyers and suppliers of refrigerants and related chemicals.
Key regulatory updates
On 17 April 2026, Germany replaced its existing Chemical Climate Protection Ordinance (ChemKlimaschutzV) with a new ordinance implementing EU Regulation 2024/573 on fluorinated greenhouse gases. This ordinance specifies chemical and waste management rules, as well as detailed requirements for expertise and certification under the EU framework. Enforcement is delegated to Germany's federal states, with a list of competent authorities available via the Bund/Länder-Arbeitsgemeinschaft Chemikaliensicherheit (BLAC).
Anti-illegal trade measures
The Third Act to Amend the Chemical Act, effective from 1 August 2021, targets illegal trade in fluorinated greenhouse gases. It imposes additional duties on suppliers of products and equipment under Article 11(1) and Annex III of EU Regulation 517/2014. Manufacturers, importers, and all downstream distributors of partially fluorinated hydrocarbons must submit a declaration confirming compliance with the EU quota obligations (Section 12j).
New penalties and temporary bans
The Fifth Act to Amend the Chemical Act, effective from 2 April 2026, introduces supplementary obligations aligned with Chapters III and IV of EU Regulation 2024/573. It also authorizes temporary bans for serious or repeated violations of the EU regulation. Non-compliance is further addressed by the Chemical Sanctions Ordinance (ChemSanktionsV), which outlines penalties for infringements.
What buyers should watch
Overseas importers and distributors of F-gases and related equipment should verify that their German partners or customers hold valid certifications and comply with the updated quota declaration requirements. The new temporary ban provisions mean that even a single serious violation could disrupt supply chains. Buyers should also monitor the list of recognized training and certification bodies published by German authorities to ensure their supply chain partners remain compliant.
Source: Read the original report | Published: April 17, 2026