With the entry into force of the revised German Chemicals Act on 24 November 2023, the handling of substances of very high concern (SVHC) will become more binding. Among other things, the establishment of a national Poisoning Register has been included in the Chemicals Act (ChemG). In addition, the tracking of missing or incorrect notifications of problematic substances in products, i.e. the entry in the SCIP database (substances of concern in products) of the European Chemicals Agency, has been adapted to EU law. More specifically, it is classified as an administrative offence for which a fine of up to 10,000 Euro may be imposed.

One of the core areas of the revision of the law is the new central Poisoning Register. It will be set up with the Federal Institute for Risk Assessment (BfR). From 1 January 2026, the data from all German poison information centers and the BfR will be compiled and evaluated. This data has been collected for a longer period of time, but a better basis is being established now for health risks associated with the use of hazardous products. The effects on the use of problematic substances and their marketing are foreseeable.

The obligation to register SCIPs, i.e. to report all problematic substances in products of all kinds, has been in place for three years. The legal basis for this was controversial for a long time. In practice, however, the system has already become established due to the demands made by commercial customers on their suppliers. Formally, the requirement is aimed at any company that, as a supplier of an article within the meaning of Article 3(33) of the REACH Regulation, is obligated to provide information in accordance with Article 33(1). If an article contains one or more substances of very high concern in significant concentrations, these substances must also be entered in the ECHA's SCIP database. Now a legal basis is established for the prosecution of companies that have not yet or not fully implemented this.