Managing industrial emissions is considered by EU authorities as the best way to improve environmental protection. The holistic approach adopted by the EU has guided the formulation of the Integrated Pollution and Prevention Control (IPPC) Directive and the new Industrial Emissions Directive (IED). Both Directives seek to regulate industrial operators within a global EU framework of permits where all emitters would have to comply with similar regulations. This avoids making low environmental performance a competitive advantage.
Just as Europe must be seen as whole, environment requires comprehensive protection throughout its territory. Compliance with environmental regulations should not cause unfair competition. To achieve comprehensive environmental protection, and provide both environmental and socio-economic benefits, the implementation of Industrial Emissions Directive must be experience- driven, cost- effective and allow some room for subsidiarity.
Cefic position on the Industrial Emissions Directive and its implementation
When implementing the now adopted directive, Cefic asks to avoid disproportionate changes for better environmental protection - so as to get the most suitable tools to detect threats to the environment. Manufacturing sites are currently regulated under the IPPC Directive. The chemical industry aims to improve sustainability by supporting innovation and competitiveness whilst reducing its impact on the environment. The industry strives for efficiency when designing manufacturing processes to minimise emissions and resource use. An integrated approach to protect the environment as a whole does not preclude a strong and innovative European chemical industry - provided the right balance between economic, environmental and social aspects is struck.
Cefic supports regulations that stimulate innovative developments to reduce emissions. The input of the chemical industry - which is known as “the industry of industries” because of its many downstream users - can add significant value to this debate. The challenge ahead in implementing the directive is to balance environmental, economic and societal concerns while achieving the goal of environmental protection in a sustainable way.
Different local conditions are acknowledged in the context of this debate. The IED, therefore, allows flexibility based on an environmental, technical as well as economic assessment. Local competent authorities are best placed to implement and use the IED provisions, in a transparent and public way, to take into account these local variations. This proportionate implementation of the emissions regulations is all the more important since the IED follows an integrated approach, taking into consideration all emissions, their origins and destinations.
Cefic contribution to the IED debate
Cefic is pleased to see that the expertise of the EU stakeholders (including relevant experts and authorities) will continue to be taken into account when adopting decisions based on Best Available Techniques (BAT), through an information exchange forum called the “Sevilla Process”. Such stakeholders need to be actively involved - in the spirit of the previous IPPC directive - in the legislative process of defining standards. Emission limit values must be set via an analysis of best available techniques by good performers. They should not, however, take into account single plants or technical examples lacking substantial feedback. In Cefic’s view, to maximise real environmental benefits and to minimise unnecessary costs, a risk- based approach to soil remediation at cessation of activities must be used.
Next steps
Elaborating the Best Available Techniques Reference (BREF) documents will be the next key step. The “Best Available Techniques”, the most eco-effective techniques to achieve environment protection, are at the heart of the Industrial Emissions Directive. It is important that the process of setting remains fair and transparent, benefitting from inputs of emissions managing specialists, operators and other stakeholders. The process of establishing these standards should also preserve future innovation and future technical developments against changing environmental needs. It is also essential to give potential investors legal and financial certainty. When investing in an existing site, operators must be able to understand what their financial liability would be in relation to the activities of previous operators and to their own activities.