PFAS regulation and enforcement accelerate in Germany

January 30, 2026

Read the full article by Preslava Dilkova, Françoise Labrousse, Dr. Holger Neumann, Elodie Simon, and Bijan Tavakoli (JD Surpa)

"The Background: Per- and polyfluoroalkyl substances ("PFAS") regulation in Germany is accelerating, with authorities increasingly relying on existing waste, water, and environmental criminal law, rather than waiting for new PFAS-specific statutes. Parallel EU measures are reinforcing this trend.

The Situation: A recent criminal conviction in Krefeld signals a tougher enforcement posture, exposing individuals to criminal liability and companies to administrative fines, profit confiscation, and remediation orders. At the same time, Germany is transposing EU drinking water rules into national law, introducing binding PFAS limits and tighter monitoring, while EU restrictions on firefighting foams and broader class-based controls advance.

Looking Ahead: Enforcement and criminal exposure will intensify further with Germany's planned transposition of the EU Environmental Crime Directive in 2026. Companies operating in Germany should treat PFAS as an immediate compliance and enforcement risk and take proactive steps to map uses, review permits and contracts, implement monitoring, and prepare for substitution and phase-outs."