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Requirement · SBX-03

Carry full liability under Union and national law for any material harm caused to third parties by testing inside the sandbox.

Participants in net-zero regulatory sandboxes must comply, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 33(6), in the Net-Zero Industry Act. as of 2026-08-18
  • The act gives its timing as: Applies from 29 June 2024 (Art. 49(2)). as of 2026-08-18
  • It names 4 industries by name: Batteries and solar, Clean tech, Carbon capture and storage and Power. as of 2026-08-18
  • Compliance is checked by none, if it happens. as of 2026-08-18
Addressee Participants in net-zero regulatory sandboxesAct Regulation (EU) 2024/1735, consolidated 17.08.2025Article Art. 33(6)Class Businesses

The rule

New — no predecessor
Trigger

material harm inflicted on third parties as a result of sandbox testing

Obligation

Carry full liability under Union and national law for any material harm caused to third parties by testing inside the sandbox.

Who is affected

Addressee
Participants in net-zero regulatory sandboxes
Class
Businesses
Sectors
Names Batteries and solar, Wind, heat pumps, hydrogen, Carbon capture and fuels, Power and heat
Applies
Applies from 29 June 2024 (Art. 49(2))

Burden drivers

D6 — 1 of 7 marks fire on this provision.

Source text

Verbatim

Participants in the net-zero regulatory sandbox shall remain liable under applicable Union and Member States’ liability law for any material harm inflicted on third parties as a result of the testing taking place in the net-zero regulatory sandbox.

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