Peter Kugel

Peter Kugel is a specialist in Environmental, Health & Safety Risk Regulation and has a broad EU Regulatory & Litigation practice in environment, chemicals, food and drug law. He is a partner in the EU, Trade & Competition team.

T: +32 2 542 07 86
F: +32 2 534 58 88
T: +32 473 12 66 03


Peter has a particular interest in the role of science and expert opinion in the law and policy of hazard and risk regulation as well as the use of scientific evidence in regulatory decision-making procedures and in judicial review of science based measures by courts.

He focuses on law and policy of chemical control, downstream use of chemicals, free movement of goods and all kinds of market access conditions, occupational health and safety obligations and product safety requirements (marketing and use restrictions, substance classification, product authorization, EU-wide substance approval, packaging and labeling requirements, claims, CE-marking, ‘green marketing’, eco-labeling, sector specific requirements, etc.).

Peter further practices European and International Environmental law and concenrates on matters of sustainable development and product stewardship (air, soil and water quality, (hazardous) waste management, emission and resource efficiency, nature and biodiversity laws, marine and coastal protection, etc.).

In addition, he has experience in EU and International fisheries law (quota issues, partnership agreements, etc.).

Peter set up his own practice in 2009 (KUGEL LEGAL). Before that he worked in the Agrochemicals, Biocides & REACH group of Field Fisher Waterhouse LLP and prior to that in the Environment, Food & Chemicals practice of McKenna Long & Aldridge LLP.

He represents a wide range of companies and trade associations. Among his clients, he also counts governmental authorities (including the European Commission) and he regularly acts upon a referral from domestic and overseas law firms who seek independant support in their client matters (lawyers’ lawyer).

Peter regularly works with other specialists such as (eco)toxicologists, safety experts, research institutions, laboratories, scientific or governmental affairs consultancies.

Environment, Chemicals, Food & Drug law

Peter’s Environment, Chemicals, Food and Drug practice includes notably:

  • REACH and Classification, Labeling Packaging (CLP)
  • Biocides
  • Plant Protection Products (Agrochemicals)
  • Food Contact Materials
  • Food safety and hygiene rules, packaging and labeling claims, dietary supplements, vitamins, baby food, sports food, and other ‘Parnuts’, approval of novel foods etc.
  • Other highly regulated industry segments: new Approach Directives (notably Medical Devices), Electronics (RoHS/WEEE), Detergents, Fertilisers, Consumer products (Cosmetics, Toys, etc.), Packaging materials, Fuel additives, etc.
  • Veterinary medicines
  • Animal feed
  • Regulation of new technologies (nanotechnology, nano-materials, nano-substances etc.)
  • Environmental compliance: air emisions and ambient air quality, wastewater and ambient water quality, hazardous materials management, waste management, transport of (hazardous) waste, use of raw materials and natural resources, waste and by-products, birds and habitats preservation, pollution, marine and coastal protection, etc.
  • Occupational health and safety: IPPC, SEVESO and other rules on general facility design and operation, physical, chemical, biological, radiological hazards, personal protective equipment (PPE), special hazard environments, monitoring, etc.
  • Fisheries and maritime affairs

His activity also entails relevant international treaties such as the PIC-Convention, POP-Convention, Basel-Convention, MARPOL and other environment and nature protection conventions, International oceans law, fishery agreements, etc.

Data sharing & Task Force Formation (REACH, Biocides, Agrochemicals)

Peter has a sound expertise in regulatory scientific data protection and data sharing cases.

He provides strategic legal advice on data protection rights (exclusive use rights) and represents clients in data access negotiations, disagreements on fair, transparent and non-discriminatory conditions for Letters of Access, cost sharing disputes, forced data sharing procedures, protection of business secrets, ‘right to know’ and access to documents issues under the EU Aarhus-Regulation 1367/2006 and EU Regulation 1049/2001, etc.

Peter also acts as legal counsel to a number of task forces (consortiums) set up pursuant to REACH, EU Biocides legislation and EU Plant Protection legislation.

In addition to forming and advising task forces for the purpose of joint dossier preparation and dossier submission, Peter also advises clients on the commercial impact of new regulatory initiatives. He actively represents a number of ad hoc industry coalitions in various legislative or regulatory advocacy projects in EU Members states and EU-level.

EU Litigation

Peter often represents clients in national or European regulatory decision making procedures, governmental enforcement actions, administrative complaints or appeal proceedings. He has particular experience as a litigator before the domestic courts as well as the EU General Court and the Court of Justice of the European Union. He has been involved in various cases on REACH, pesticides, biocides and chemical hazard classifications.

Peter Kugel has registered (European) administrative and sanctions/enforcement law and economic regulatory law (free movement and market access conditions) as principal legal practices in the Netherlands Bar register (for which he is required to obtain ten training points per calendar year). Mr. Kugel does not have a Dutch ‘Stichting derdengelden’.





  • LLM, College of Europe Bruges (scholarship obtained from the Dutch government)
  • Erasmus, Institut Science Politiques de Paris
  • Summer School in Human Rights, Oxford University
  • JD, University of Leiden

Bar admissions

  • Member of the Breda bar (the Netherlands)
  • Associated member of the Brussels bar (EU-list)


  • English
  • Dutch
  • German
  • French

Professional activities

  • Member of the Advisory Board to the Dutch Knowledge Network on Biocides (KNB)
  • Member of the European Food Law Association (EFLA)
  • Member of the Dutch association for EU Law (NEVER)
  • Member of the Dutch association for environmental law (VMR)
  • Member of the Society for Risk Analysis (SRA)
  • Former member of the Editorial Board to the European Journal of Risk Regulation (EJRR)
  • Faculty member of the Summer Academy on Global Food Law and Policy (2010)
  • Teaching EU Judicial Protection at the European Institute for Public Administration until 2012