| WIESBADEN | That is to say, sulphur's not good in swelling spa town in Germany |
| SUNDISC | Sulphur not found, semi-invisible, in representation of Ra or Re? |
| INNOCENCE | Always using carbon for sulphur, not by any interpretation being clean? |
| SOFTEN | Assuage it with sulphur not infrequently (6) |
| HARROGATE | Spa town in North Yorkshire that is home to Betty's Tea Rooms |
| HOMBURG | Town in Germany after which a type of man's felt hat is named (7) |
| MEISSEN | Which town in Germany, near Dresden, is famous for porcelain? (7) |
| BERCHTESGADEN | Resort town in Germany in the Bavarian Alps associated with Adolf Hitler (13) |
| OWNING | Having a proprietary interest in a town in Germany (6) |
| CHELTENHAM | Town near Gloucester that became a fashionable spa town in the 19th century (10) |
| UNWILLINGNESS | Reluctance to turn over in swelling sun (13) |
| GOTHA | Which town in Germany is noted for its Almanach recording the royal and noble houses of Europe from |
| EMS | Town in Germany famous for the --- Telegram, which led to the outbreak of the Franco-Prussian War (3) |
| SOLARFLARE | Wind far, all wrapped up in swelling burst of energy (5,5) |
| QUINTESSENCE | Vital part of fruit production outside model town in Germany (12) |
| LANDAU | Horse-drawn enclosed carriage named after a town in Germany where it was first made (6) |
| AUGSBURG | Month's supply of food taken round town in Germany |
| DESSAU | Town in Germany at the confluence of the Elbe and Mulde rivers |
| HANSEATIC | The --- League was an association of towns in Germany from the 12c to the 17c (9) |
| ONPAPER | Mush fed to condemned man that's not good, in theory |