The Ministry of Energy, taking into account regulatory experience as well as public feedback, has adjusted the emission limits for several particularly toxic air pollutants in factories, raising them to stricter levels in line with German standards, which are more stringent than the EU regulations.
The modified regulation sets the strictest emission limits in the European Union for certain air pollutants, with a particular focus on carcinogenic, mutagenic, and reprotoxic (CMR) substances, as well as nickel, cobalt, and manganese (NCM) compounds, which are bound to airborne dust and pose particular health risks. Thanks to this modification, environmental authorities will be able to impose stricter, reduced emission limits - cut to half or even a fifth of previous levels - regardless of the type of activity when issuing permits.
The significantly stricter provisions will apply to new investments (i.e., those for which environmental permitting procedures have not yet started) from the date the legislation comes into force. For ongoing permits, the new rules will be applicable from 1 January 2027. For already operating factories, the new, much stricter emission limits must be applied from 1 January 2028. In all cases, companies must initiate the modification of the relevant permits.
By Lilla Majoros, Attorney at law, KCG Partners Law Firm
