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Evaluation of the Industrial Emissions Directive

Environment

The Industrial Emissions Directive aims to prevent or reduce pollution and waste generation from certain large industrial installations. The purpose of this evaluation is to assess how the Directive is working and whether it is delivering benefits for citizens and stakeholders.

Links

Public consultation

ID: 1913

Lobbying Activity

27 responses

Consultation response

BUSINESSEUROPE, 4 Dec 2018

See attached

Environmental Bureau Demands Radical Overhaul of Industrial Emissions Rules

European Environmental Bureau, 3 Dec 2018

The EEB demands fundamental changes to strengthen pollution standards, eliminate industry derogations, and redesign the regulatory framework as a binding EU Regulation. They seek mandatory stricter emission limits, complete overhaul of exemption procedures, and expanded scope to drive ecological transition of EU industry.
This would strengthen their ability to challenge weak permits and enforce higher standards.
Industrial operators lose flexibility and face significantly higher compliance costs and restrictions.

Consultation response

Association des Constructeurs Européens d'Automobiles, 4 Dec 2018

ACEA welcomes the activity of the European Commission to give a feedback to the roadmap on the IED REFIT. With regards to the roadmap ACEA has identified 3 key points that are relevant for its effective process. • The BREF review process appears to penalise proactive contributions. Where…

Chemical industry urges delay of industrial emissions review

European Chemical Industry Council, 4 Dec 2018

The industry urges postponing the evaluation until more companies have implemented current technical standards. They also suggest assessing whether the directive has significantly increased administrative burdens.
Delaying the review prevents additional regulatory costs before existing rules are fully active.

Consultation response

The European Steel Association, 4 Dec 2018

Overall, the European Steel Association (EUROFER) welcomes the commitment from the European Commission to ensure the efficiency of its Directives via thorough, transparent, and self-critical reviews. EUROFER is however surprised about the timing of this evaluation since it contradicts the…

Consultation response

FuelsEurope, 4 Dec 2018

FuelsEurope welcomes the Commission’s commitment to ensuring the efficacy of its directives through thorough, transparent, and self-critical reviews. It is only through these evaluations, rooted firmly in the best available data, that directives such as the Industrial Emissions Directive (IED) can…

Consultation response

Confederation of Danish Industry, 4 Dec 2018

In general, the IED is working well in Denmark. We have known the legal basis for many years. The permission scheme in Denmark was the idea behind the IPPC - the predecessor to IED. We think it will be difficult to do a full evaluation of the IE di-rective. According to the directive it can…

Consultation response

Wirtschaftskammer Österreich, 3 Dec 2018

WKO applause for achievements until now. The industrial emissions directive promotes the EU harmonisation of best available technologies for large industrial installations, which is to be applauded. A level playing field, cost-effectiveness as well as investment security for affected industrial…

Consultation response

Neste Oyj, 28 Nov 2018

The IE directive including BAT requirements is ambitious and its implementation is currently going on. Some industry sectors can expect to have full implementation in place by end of 2018. This is not the case with all important industry sectors. For example, the 4 years' legal implementation…

Consultation response

CEMBUREAU - The European Cement Association, 4 Dec 2018

CEMBUREAU, the European Cement Association, took note of the initiative by the European Commission to evaluate how the Industrial Emissions Directive (IED) is working. This Directive specifies how to control emissions from industrial sources other than CO2, through the application of Best…

Consultation response

European Ceramic Industry Association, 3 Dec 2018

The European Ceramics industry association (Cerame-Unie) welcomes the European Commission’s commitment to ensuring the efficacy of its directives through thorough, transparent, and self-critical reviews. It is our strong wish to actively contribute to this process and we believe that the…

Consultation response

Landbrug Fødevarer - Danish Agriculture and Food Council, 4 Dec 2018

Landbrug & Fødevarer repræsenterer mere end 1.500 husdyrbrug, som er omfattet af IE direktivet samt 100 virksomheder indenfor fødevareproduktion, kartoffelmel, slagterier, bryggerier, mælk, foder, garveri og biogas med produktion i Danmark. Mange af virksomhederne har hovedkontor i Danmark og…

Chemical Industry Federation of Finland seeks evaluation delay

Chemical Industry Federation of Finland (Kemianteollisuus ry), 3 Dec 2018

The federation claims it is too early to conclude the directive's impact. They suggest waiting for full implementation and a follow-up period. They also want flexibility for high-performing states.
Delaying the review prevents new regulatory burdens while current requirements are still being implemented.

Consultation response

Veolia Environnement, 4 Dec 2018

The Directive on industrial emissions is the main legal tool to tackle air pollution and mitigate industrial emissions in the EU. It should be noted that it has also inspired similar legislations outside of the continent. As a company dealing with environmental services, one of our main missions…

Consultation response

European Recycling Industries' Confederation, 30 Nov 2018

EuRIC, the European Recycling Industries’ Confederation, welcomes this Roadmap and the forthcoming review of the Industrial Emissions Directive. As the specific BREF for our industrial sector was recently reviewed (Waste Treatment BREF), we have detailed feedback to provide on the monitoring and…

Consultation response

European Federation of National Associations of Water Services, 3 Dec 2018

EurEau fully supports the goals and tools of the IED. We see, however, that pollutants from industrial sources are still released to the aquatic environment where they pose a threat to the quality of water resources (see the EEA report on Status of European Waters 2018). Water suppliers are obliged…

Waste-to-energy sector warns against premature industrial emissions evaluation

Confederation of European Waste-to-Energy Plants, 4 Dec 2018

CEWEP believes a proper evaluation needs a sufficient amount of data. They argue 2020 is too early to see impacts on installation performances.
The sector avoids the risk of policies being based on a distorted picture.
Public health and environment lose the benefit of faster pollution reduction efforts.

Consultation response

Valmet Oyj, 3 Dec 2018

Chapter IV of the Directive 2010/75/EU provides special provisions for waste incineration plants and waste co-incineration plants. Article 42(1) of the directive provides for the scope for when these special provisions are to be used. Unfortunately, the current wording of Article 42(1) makes a…

EURACOAL urges macro-level cost assessments for industrial emissions

European Association for Coal and Lignite, 4 Dec 2018

The association requests a more balanced cost-benefit analysis that includes the social impact of regulations. They argue that the current focus on health benefits ignores potential job losses and reduced economic activity. They also suggest revisiting compliance timelines to avoid excessive industry costs.
This would allow the industry to avoid expensive technology upgrades and prevent premature plant closures.
Public health may suffer if emission reductions are delayed to protect industrial profitability.

Hazardous Waste Europe demands reforms to industrial pollution rules

Hazardous Waste Europe, 4 Dec 2018

HWE supports maintaining mandatory permits while improving how key environmental issues are identified. They propose considering cross-media effects to prevent one pollution reduction from causing another. They also want clearer rules on indirect water discharges and measurement uncertainties.
These reforms would create a fairer market and reduce regulatory confusion.
Non-EU competitors lose their advantage of operating under weaker environmental regulations.

Consultation response

European Suppliers of Waste-to-Energy Technology, 4 Dec 2018

ESWET would like to welcome the Commission’s initiative to launch an evaluation of the Industrial Emissions Directive (IED) as a sign of its dedication to ensure that the IED remains an efficient piece of legislation. However, ESWET expresses reservations regarding the timeliness of such…

Consultation response

Intergraf European Federation for Print and Digital Communication, 4 Dec 2018

Intergraf, representing the European printing industry, welcomes the opportunity to comment on the evaluation roadmap of the Industrial Emissions Directive. The adoption of the Industrial Emissions Directive was of key relevance for the printing sector with the inclusion of the Solvent Directive.…

Consultation response

European Sustainable Phosphorus Platform, 4 Dec 2018

The IED is a key piece of EU legislation to ensure environmental quality in industry, in intensive agriculture and in food & beverage processing, in order to preserve the environment, to ensure a level playing field and to push forward environmental progress. The priority must be to continue…

Consultation response

European Expanded Clay Association, 4 Dec 2018

EXCA welcomes the opportunity to provide its feedback to the European Commission on the Evaluation of the Industrial Emissions Directive. The ceramic BREF, which covers expanded clay plants, was first published in August 2007, and has not yet been reviewed since. Therefore, the expanded clay…

Consultation response

Öljy- ja biopolttoaineala ry - Finnish Petroleum and Biofuels Association, 27 Nov 2018

The IE directive including BAT requirements is ambitious and its implementation is currently going on. Some industry sectors can expect to have full implementation in place by end on 2018. This is not the case with all important industry sectors. For example, the 4 years' legal implementation…

Consultation response

European Co-Processing Association, 4 Dec 2018

In the context of this first consultation, the following points seems important to EUCOPRO : 1. On the provisions of the Industrial Emissions Directive 2010/75 of 24 November 2010, and in particular its Chapter II, Eucopro considers that the existing provisions are adequate and sufficient to…

Consultation response

EUROPEAN COIL COATING ASSOCIATION, 3 Dec 2018

The European Coil Coating Association (ECCA) welcomes the EC commitment to make EU regulation more efficient and effective through thorough, transparent, and critical reviews. We, however, believe that launching an evaluation of the IED is premature, the main reason being that several…