Craftsmen demand practical guidelines for metal processing

The German Confederation of Skilled Crafts is calling for a practical and SME-friendly implementation of new regulations for metal processing. Additional burdens on small businesses must be avoided.

The German government intends to implement an EU regulation on metal processing and has submitted a draft administrative regulation to this effect . This also affects companies in the surface finishing and electroplating sectors, as well as metalworking businesses.

The "Conclusions on Best Available Techniques" (BAT Conclusions) primarily address hot rolling, cold rolling, wire drawing, continuous hot-dip coating, and batch galvanizing. Emission limits for air pollutants such as total dust, nitrogen oxides, sulfur oxides, and gaseous and particulate inorganic substances are established. Adjustments to monitoring, construction, and operational requirements are also planned. The goal is to achieve overall improved environmental protection.

Burdens on small and medium-sized enterprises

The Central Association of German Crafts (ZDH) is committed to high environmental protection and health standards and supports the European harmonization of environmental regulations.

From his perspective, however, it is crucial that the implementation of the BAT conclusions in national law remains technically and economically feasible and compatible with the needs of small and medium-sized enterprises (SMEs). According to the German Confederation of Skilled Crafts (ZDH), overburdening SMEs could lead to the relocation of production capacities abroad, which would jeopardize value creation and innovation in Germany and potentially worsen global environmental and climate balances.

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No requirements beyond EU standards

The association welcomes the efforts to implement the new regulations uniformly across Germany without additional requirements . Certain simplifications for smaller installations, such as lower measurement frequencies, are already included in the current draft.

At the same time, the expanded measurement, monitoring , and documentation requirements represent a considerable burden for craft businesses, according to the German Confederation of Skilled Crafts (ZDH ). Small and medium-sized enterprises (SMEs) in particular often lack sufficient personnel resources, which increases the need for external specialist services. Given the existing shortage of skilled workers, this problem is expected to worsen.

New costs hit small businesses especially hard.

In addition to ongoing costs for extra measurements, there will be a need for investments in technical upgrades as well as indirect costs due to operational adjustments. These investments will hit smaller businesses particularly hard due to limited financial resources. Furthermore, the German Confederation of Skilled Crafts (ZDH) doubts that the impact assessment presented in the draft fully reflects the actual costs and effects of the skilled worker shortage.

The German Confederation of Skilled Crafts emphasizes that implementing individual regulations is often only possible to a limited extent for existing facilities . Spatial and procedural constraints, in particular, complicate implementation. Furthermore, concrete approaches to digitizing and simplifying administrative and verification procedures are lacking . This creates the risk of differing enforcement practices across the states, which could lead to additional uncertainty for businesses.

In light of these challenges, the German Confederation of Skilled Crafts (ZDH) calls for greater consideration of the interests of the skilled trades in the further proceedings . Measurement and documentation obligations should be reviewed for their proportionality for small businesses, practical transition periods should be introduced, and procedures should be further simplified and digitized.

The advisors at the Chambers of Crafts will be happy to help you with any legal questions!

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