This commentary on the SchadRegProtAG is primarily intended as a legal working aid for practice and is aimed at the enforcement authorities and the operators of potentially reportable operating facilities. Although the obligations under international or European law behind the individual provisions of SchadProtRegAG form the background of this commentary, the user can use it without in-depth background knowledge. The commentary also addresses the provisions of the PRTR Protocol and the E-PRTR Regulation to the extent necessary for the practical application of SchadRegProtAG.
These standards concern two registries (the German PRTR and the European E-PRTR), are addressed to different addressees (European Commission, Member States, authorities and operators) and have different legal effects. The primacy of application of the European E-PRTR Regulation over German law is of particular practical significance. The interpretation of the German SchadRegProtAG is therefore also primarily based on the E-PRTR Regulation. German standards can, however, be used as an aid to interpretation if necessary. Since SchadRegProtAG merely supplements the E-PRTR Regulation and otherwise largely refers to it, the E-PRTR Regulation is printed in full in the Annex.