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Revision of EU Ambient Air Quality legislation

Environment

Clean air is essential to human health and for sustaining the environment. As announced in the European Green Deal, the Commission will propose revision of air quality standards to align them more closely with World Health Organization recommendations. The proposal also aims to improve the EU clean air framework, building on the lessons learnt in 2019 by the fitness check of EU air quality legislation.

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Public consultation

ID: 12677

Lobbying Activity

70 responses

Transport and Environment urges EU to align air laws with WHO

Transport and Environment (European Federation for Transport and Environment), 13 Mar 2023

T&E demands aligning pollution limits with WHO guidelines and making air quality plans mandatory before violations occur. They also want penalties for non-compliance and explicit support for zero-emission zones.
Strict air quality targets would force faster implementation of zero-emission transport policies.
Public authorities would face higher costs and penalties for failing to meet standards.

Consultation response

Transport and Environment (European Federation for Transport and Environment), 14 Jan 2021

Transport & Environment, Europe's leading clean transport campaign group, welcomes the European Commission’s plan to review the Ambient Air Quality Directives (AAQD). While EU clean air laws have driven stepwise reductions in toxic air pollution, the Second Clean Air Outlook clearly shows that…

Environmental groups demand stricter EU air quality standards aligned with WHO

European Environmental Bureau, 14 Jan 2021

The EEB urges full alignment with forthcoming WHO air quality guidelines and binding limit values as the primary instrument. They want ambitious timelines, stronger monitoring requirements, and provisions on penalties and access to justice.
This would strengthen their ability to enforce air quality protections through legal action.
Polluting industries face higher compliance costs and stricter enforcement through new penalties.

ACEA Urges Delay of 2030 Ambient Air Quality Targets

Association des Constructeurs Européens d'Automobiles, 14 Mar 2023

The association suggests a slightly later date for greater compliance should be considered. All industrial sectors must contribute to help achieve future air quality limits. Policy makers should prioritize supporting the renewal of the old vehicle fleet.
A delay prevents the diversion of financial resources away from electric vehicle development.

German Industry Urges Delaying New EU Air Quality Limits

Bundesverband der Deutschen Industrie e.V., 14 Feb 2023

The organization requests postponing new air pollution limits until 2040 because the current 2030 goals are unrealistic. They also oppose new rules allowing citizens to sue for health damages caused by pollution.
This delay would protect businesses from high compliance costs and potential legal compensation claims.
Public health would suffer as people remain exposed to higher pollution levels for longer.

Consultation response

European Chemical Industry Council, 14 Jan 2021

Cefic, the European Chemical Industry Council, founded in 1972, is the voice of large, medium and small chemical companies across Europe, which provide 1.2 million jobs and account for about 17% of world chemicals production. Cefic welcomes the consultation of stakeholders concerning the roadmap…

ClientEarth urges EU to align air standards with WHO

ClientEarth AISBL, 10 Mar 2023

ClientEarth requests limit values fully aligned with WHO guidelines by 2030 and stricter enforcement of air quality plans. They also call for a robust sanctions regime and guaranteed access to justice for citizens.
These changes would empower the organization to hold public authorities legally accountable for pollution.
Public authorities would face stricter legal scrutiny and financial penalties for missing air quality targets.

Consultation response

ClientEarth AISBL, 13 Jan 2021

ClientEarth welcomes the opportunity to provide feedback on the start of this important initiative to revise and strengthen the Ambient Air Quality Directives. Please find attached our feedback.

Enel urges electrification to improve European air quality standards

ENEL SpA, 14 Mar 2023

Enel recommends accelerating the penetration of decarbonized electricity for transport and heating sectors. They also suggest reviewing monitoring station locations to reflect real population exposure more closely.
This shift would increase demand for Enel's renewable energy and charging infrastructure.
Manufacturers of internal combustion engines and fossil fuel boilers would see reduced demand.

Consultation response

ENEL SpA, 14 Jan 2021

Air quality in Europe is still far from complying with European or international standards. Especially in urban areas, air quality limits in Europe are widely exceeded for the three main pollutants (particulate matter or PM, ozone and nitrogen oxides or NOx). The European Energy Agency (EEA)…

German Chambers Urge Realistic Deadlines for EU Air Quality Rules

Deutsche Industrie- und Handelskammer, 23 Jan 2023

DIHK requests realistic timeframes that align limit values with industrial transformation and fleet modernization. They demand specific requirements ensuring air quality measurement results are representative across all regions.
This approach avoids high retrofitting costs and prevents delays for industrial investment projects.
Health-focused organizations lose as strict pollution limits are delayed beyond the next decade.

Austrian Business Chamber Urges Ten-Year Delay for Air Limits

Wirtschaftskammer Österreich, 13 Mar 2023

They want to postpone binding pollution limits until 2040 and allow more fuel-switching flexibility. Additionally, they call for removing the legal right for citizens to claim health damages.
This prevents production restrictions and shields companies from expensive environmental liability lawsuits.
Public health suffers as companies continue emitting higher levels of harmful pollutants.

Consultation response

Wirtschaftskammer Österreich, 13 Jan 2021

Austrian Federal Economic Chamber (WKO) feedback on IIA - revision of AAQDs – EC air quality roadmap: We encourage the Commission to avoid, prevent or reduce harmful effects of poor air quality on human health and the environment. To substantially improve enforcement of the AAQDs, we recommend a…

Eurometaux urges 2040 delay for new air quality standards

EUROMETAUX, 14 Mar 2023

The industry wants to delay new limit values until at least 2040. Metal standards should remain non-binding target values to account for natural background levels. They also oppose new health-related compensation schemes for legal reasons.
Delaying targets avoids disproportionate investment costs for technically difficult emission reductions.
Health and environmental groups lose as stricter pollution limits are postponed for decades.

Eurocities Backs Stricter Air Standards but Demands Shared Responsibility

Eurocities, 23 Feb 2023

Eurocities requests a joint responsibility clause ensuring national and EU support for local air quality planning. They also urge stricter source-specific regulations for transport and agriculture to meet new limits.
Shared accountability prevents cities from carrying the entire burden of meeting strict pollution targets.
The transport and agricultural sectors would face higher costs from mandatory emission reductions.

Consultation response

Eurocities, 14 Jan 2021

EU legislation has been working as a driving force for better air quality in Europe. However, and despite improvements, with many EU member states undergoing infringement procedures, the lack of enforcement and stringent standards are undermining local efforts taken by cities. We welcome that one…

Iberdrola advocates for stricter air standards to boost electrification

IBERDROLA, 28 Nov 2022

Iberdrola supports a 2050 zero-pollution objective and stricter 2030 standards. They advocate for electrifying transport and heating to solve air pollution. They also want penalties for countries exceeding limits.
Stricter air rules would increase demand for Iberdrola's renewable power and technologies.
Non-compliant governments and polluting industries would face lawsuits and financial penalties.

Consultation response

IBERDROLA, 13 Jan 2021

Air pollution is the biggest environmental risk to health in the European Unión According to the World Health Organization (WHO), air pollution is the biggest environmental risk to health in the EU. 96% of EU citizens living in urban areas were exposed to levels of air pollutants considered by…

German Energy Industry Urges Delay for New EU Air Standards

BDEW Bundesverband der Energie- und Wasserwirtschaft e. V., 14 Mar 2023

BDEW requests delaying the new air quality standards until 2035 and loosening proposed pollution limits for 2030. They also want more flexibility regarding legal liability and how exposure levels are calculated.
A delay would reduce technical retrofitting costs and simplify permitting for energy plants.
Public health suffers as citizens remain exposed to higher pollution levels longer.

Consultation response

Verband Deutscher Maschinen- und Anlagenbau e.V., 3 Mar 2023

VDMA expressly supports the efforts of the EU Commission to further improve air quality in the EU. Updating the EU air quality directives makes sense but must be carried out with the appropriate sense of proportion. Within the framework of this position paper, we have outlined various aspects and…

Deutsche Umwelthilfe Demands Strict WHO Air Standards by 2025

Deutsche Umwelthilfe e.V., 14 Mar 2023

DUH demands that air quality limits match WHO recommendations and become legally binding by 2025. They also call for stronger enforcement tools and mandatory penalties.
The group would achieve its health protection goals while reducing societal disease costs.
Negligent authorities and polluting industries would face mandatory financial penalties and legal action.

Consultation response

Zentralverband des Deutschen Handwerks e.V., 14 Jan 2021

Die Festsetzung von EU-weit gültigen Grenzwerten für Luftschadstoffe im Rahmen der Richtlinie 2008/50/EG ist aus Sicht der ZDH eine notwendige und sinnvolle Aufgabe der EU-Politik. Eine erfolgreiche Schadstoffsenkungspolitik erfordert über die Festlegung von Grenzwerten hinaus ein konsistentes und…

SUEZ Group urges inclusion of air treatment in EU law

SUEZ Group, 14 Mar 2023

SUEZ proposes integrating air treatment technologies and greenhouse gas capture into the directive. They also advocate for guidelines on innovative screening and public-private partnerships.
These policy changes would create new commercial opportunities for SUEZ’s proprietary environmental technologies.
Industrial firms would face increased compliance costs from new greenhouse gas capture requirements.

Consultation response

SUEZ Group, 14 Jan 2021

Suez welcomes the opportunity to provide feedback on the AAQ Directives revision roadmap. Please find our contribution attached.

German Chemical Industry Urges Delayed Implementation of Air Standards

Verband der Chemischen Industrie e.V., 7 Mar 2023

The association requests postponing compliance with new air quality values until 2040. They prefer flexible target values over strict limits and oppose expanded legal sanctions.
This delay protects the profitability of existing chemical plants during their long-term green transition.
Public health and environmental groups lose as stricter pollution limits are delayed for a decade.

Consultation response

Verband der Chemischen Industrie e.V., 13 Jan 2021

The VCI represents the politico-economic interests of around 1,700 German chemical companies and German subsidiaries of foreign businesses. In 2019 the German chemical industry realised sales of over 198 billion euros (equal to 1/3 of the Europe-an chemical industry) and employed around 464,000…

German steelmakers urge ten-year delay for air quality limits

Wirtschaftsvereinigung Stahl, 10 Mar 2023

WV Stahl requests suspending the consultation to allow for further impact assessments. They argue that new pollution limits should not apply until 2040 at the earliest.
Delaying new standards reduces compliance pressure on existing industrial production facilities.
Public health and legal rights of affected individuals would be undermined.

Consultation response

Wirtschaftsvereinigung Stahl, 13 Jan 2021

The Air Quality Directives set common methods for monitoring, assessing and informing about air quality in the European Union and set air quality targets to avoid, prevent or reduce harmful effects on human health and the environment as a whole. The steel industry supports a sustainable policy to…

Consultation response

Zero Waste Europe, 12 Jan 2021

ZWE welcomes the Commission proposal to review the Ambient Air Quality Directives. End of life treatment of waste such as waste incineration release pollutants to ambient air. These pollutants, at certain concentrations, lead to health and environmental issues, as the World Health Organization has…

European Cancer Organisation Urges Full Alignment With WHO Air Standards

European Cancer Organisation, 14 Mar 2023

ECO calls for full alignment with WHO guidelines rather than just closer targets. They urge the EU to exceed minimum requirements and study low-level pollution exposure.
Meeting these standards would reduce lung cancer cases and alleviate pressure on national healthcare systems.

Consultation response

European Sea Ports Organisation, 13 Jan 2021

The European Sea Ports Organisation (ESPO) and its members welcome Europe’s ambition to be the world’s first net zero emission area by 2050. Achieving the ambitions of the European Green Deal for 2030 and 2050 should be the driver of EU policy. This includes the goal of zero pollution by…

Consultation response

Veolia Environnement, 14 Jan 2021

Veolia welcomes the initiative of the European Commission to revise rules regarding air quality as announced in the European Green Deal and its zero pollution ambition for a toxic-free environment. We support the need to draw on the lessons learnt from the Fitness Check of the Ambient Air Quality…

European Public Health Alliance urges full WHO alignment on air standards

European Public Health Alliance, 14 Jan 2021

The organization requests that EU air quality standards be fully aligned with the latest WHO Air Quality Guidelines. They call for an ambitious action plan with concrete actions, binding timelines and goals to prevent pollution at its source. They emphasize that quick approval and immediate implementation is crucial to improve air quality and save lives.
This would reduce the 400,000 annual premature deaths from air pollution in the EU.
Polluting industries lose public financing and face stricter vehicle emission standards and zero emission requirements.

Copper Industry Urges Proportionality in New Air Quality Rules

International Copper Association Europe, 14 Mar 2023

The institute requests that the directive includes proportionality principles and target values. They argue further reductions should be avoided for activities where costs are disproportionately high. They insist the Industrial Emissions Directive remain the primary regulatory framework.
This would lower their long-term compliance costs and preserve their global market competitiveness.
Citizens and environmental groups lose if cost-benefit analyses are used to limit pollution reductions.

FIA calls for realistic air standards and longer review periods

Fédération Internationale de l'Automobile, 14 Mar 2023

The FIA requests longer review periods for legal certainty and objects to the term zero pollution objective. They argue that monitoring should focus on representative health burdens rather than isolated hotspots. Additionally, they believe current vehicle emission standards are already sufficient to reach target reductions.
This would reduce regulatory pressure on the transport sector and provide long-term planning stability.
Public health groups lose more frequent updates to air safety standards and stricter pollution targets.

Consultation response

Fédération Internationale de l'Automobile, 14 Jan 2021

The FIA European Bureau supports the endeavour of the European Commission to revise policies and legislation related to air quality from all sectors in the follow-up to the ambition set in the European Green Deal. Whilst the mobility sector is often singled out, there is a shared responsibility of…

Consultation response

Health & Environment Alliance, 13 Jan 2021

Air pollution is the number one environmental threat to health in the European region and globally, leading to 400,000 premature deaths and hundreds of billions of euros in health costs in Europe each year. There is a large body of evidence on how air pollution harms health. Poor air quality is a…

Aurubis urges EU to maintain current heavy metal air standards

Aurubis AG, 13 Mar 2023

Aurubis calls for maintaining current heavy metal targets. They request cost-benefit analyses for new standards. They seek time-related derogations for meeting air quality limits.
Avoiding stricter standards helps the company maintain its global market position.
Residents near industrial sites face prolonged exposure due to postponed deadlines.

Consultation response

Bellona Europa, 14 Jan 2021

Bellona sincerely welcomes the taking into account of the points expressed in the previous contribution, including the recognition that current air quality standards were largely missing the WHO recommendations. However, it’s important to aim at a full alignment with WHO recommendation, rather than…

ADAC Demands Socially Compatible Air Quality Standards

Allgemeiner Deutscher Automobil-Club e.V., 14 Mar 2023

The club demands air goals that protect personal mobility and economic viability. Driving bans must be a final resort after exhausting all other options.
This approach protects members from the high costs of immediate vehicle replacements.
Affected citizens lose the ability to seek legal redress for health damages from pollution.

Consultation response

Netherlands Organisation for Applied Scientific Research TNO, 17 Feb 2023

TNO fully supports the initiative of the European Commission to revise the air quality rules, as announced in the European Green Deal and its zero-pollution ambition for a toxic-free environment. We have aligned our suggestions with the document DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE…

Consultation response

AECC, 13 Jan 2021

The Association for Emissions Control by Catalyst (AECC) welcomes the opportunity to comment on the inception impact assessment on the revision of the Ambient Air Quality Directives. AECC fully supports the revision of the Ambient Air Quality Directives. Clean Internal Combustion Engines (ICEs)…

German metals industry urges moratorium on EU air quality rules

WirtschaftsVereinigung Metalle, 2 Mar 2023

The association demands a moratorium on the revision, arguing that new limit values should not apply before 2040. They also oppose new legal rights for damage compensation and NGO lawsuits.
This would avoid complicated approval processes and maintain legal certainty for industrial transformation projects.
Environmental groups and citizens lose new legal rights to seek compensation for pollution-related health damage.

Consultation response

Confederation of European Waste-to-Energy Plants, 13 Jan 2021

CEWEP, the Confederation of European Waste-to-Energy (WtE) Plants, welcomes the initiative of reviewing the EU Air Quality standards and aligning them more closely with the recommendations of the World Health Organization. Because of their dual nature, while offering an environmental and sanitary…

France Chimie highlights industry efforts in air quality revision

France Chimie, 14 Mar 2023

France Chimie highlights industry efforts and investments to reduce atmospheric emissions. They argue current European industrial regulations are already very demanding.
Emphasizing existing progress helps the industry avoid the cost of new requirements.

ESMO Urges Stricter Air Quality Limits to Prevent Lung Cancer

European Society for Medical Oncology (ESMO), 15 Feb 2023

ESMO recommends lowering the annual limit for fine particulate matter to 5 μg/m³ by 2030. This would align EU policy with current international health guidelines.
Stricter limits would reduce lung cancer rates and healthcare costs across the EU.

EURACOAL warns revised air quality rules threaten energy security

European Association for Coal and Lignite, 14 Mar 2023

EURACOAL argues that no revision is necessary because current laws already lead to improvements. They recommend focusing on better enforcement instead of setting stricter targets.
This would protect coal companies from costly upgrades and ensure their continued survival.
Citizens lose health benefits as air pollution causes hundreds of thousands of premature deaths.

EURACOAL Urges EU to Halt Air Quality Law Revision

European Association for Coal and Lignite, 14 Jan 2021

EURACOAL maintains that current air quality directives are adequate and do not require updating. They argue for better enforcement of existing laws and support for pollution control in neighboring countries.
The industry avoids high costs for coal plants approaching their end of life.
Vulnerable populations and citizens lose protections against health risks from poor air quality.

Consultation response

Partnership for Policy Integrity, 14 Jan 2021

Please see our attached comments and at http://www.pfpi.net/wp-content/uploads/2021/01/PFPI-Air-Quality-Consultation-comments-Jan-14-2021.pdf

EuroHealthNet urges full alignment with WHO air quality guidelines

EuroHealthNet, 9 Mar 2023

EuroHealthNet calls for full alignment with WHO guidelines and legally binding obligations. They advocate for targeted support for vulnerable groups and socioeconomically disadvantaged areas.
This would lower long-term health expenditures and reduce socio-economic health inequalities.
Member States lose the flexibility to set voluntary national air quality reduction targets.

Consultation response

Aggregates Europe - UEPG, 13 Mar 2023

Aggregates Europe - UEPG represents the aggregates industry companies that extract and supply quality construction raw materials in European countries, which are essential to meet demand. Aggregates Europe - UEPG supports the objectives to be achieved by the revision of this Directive, in…

Consultation response

Fédération Internationale des Véhicules Anciens, 9 Jan 2023

The average Historic Vehicle is taken out about 15 times a year, with historic cars travelling around 1,400km and historic motorcycles less than 900km per year. Considering this marginal use, their impact on air quality is negligible. Historic Vehicles are not for daily use and are thus not a part…

Consultation response

European Committee of Heating, Ventilation, Air Conditioning and Refrigeration Manufacturers, 14 Jan 2021

Eurovent holds that gap between the AAQ Directives and the WHO guidelines on PM2.5 must be closed, that air quality data must be disseminated to the public more effectively, and that ambient air quality legislation must be complemented with policies addressing indoor air pollution as well. More…

Consultation response

European Federation of Allergy and Airways Diseases Patients' Associations, 14 Jan 2021

The European Federation of Allergy and Airways Diseases Patients' Associations (EFA) welcomes the initiative of the Commission to revise the Ambient Air Quality Directives. Air pollution remains the single largest environmental health risk in Europe, and a major cause of mortality responsible for…

Consultation response

Tallano Technologie, 13 Jan 2021

We welcome the opportunity to share our views on the revision of EU rules on air quality and measures to address air pollution. Air pollution continues to be a major health and environmental problem in Europe. Despite improvements in air quality over recent decades, countries and cities across…

Consultation response

Bundesverband der Deutschen Sicherheits- und Verteidigungsindustrie e.V., 13 Jan 2021

Der BDSV hält eine Revision der europäischen Luftqualitätsrichtlinien für verfrüht: die entsprechenden Vorgaben wurden erst vor wenigen Jahren eingeführt und sind bereits in der aktuellen Fassung eine große Herausforderungen für die EU-Mitgliedstaaten und die Industrie. Eine Verschärfung wäre daher…

Consultation response

Bundesverband Bioenergie e.V., 14 Mar 2023

Am 26. Oktober 2022 hat die EU-Kommission ihren Vorschlag zur Überarbeitung der EU-Richtlinie (2008/50/EG) über die Luftqualität vorgelegt. Diese Richtlinie legt Methoden zur Überwachung und Beurteilung der Luftqualität sowie Grenzwerte und Ziele fest, um die Auswirkungen schlechter Luftqualität…

ÖAMTC urges realistic air targets and national litigation rules

Österreichischer Automobil-, Motorrad- und Touring Club, 13 Mar 2023

The club requests longer evaluation periods to ensure legal certainty for stakeholders. They argue that legal claims and compensation should remain under national regulation.
National control over lawsuits reduces the risk of uniform, strict enforcement.
Citizens and environmental groups lose standardized EU-wide paths to seek damages.

Consultation response

Ocelářská unie, 14 Mar 2023

We welcome the opportunity to express our views and comments on the draft revision of AAQD. Below please find some of our main points, while in the attachement further comments on individual Articles can be found. Alignment of the future EU AQ standards with technical and economic feasibility must…

Consultation response

CITTADINI PER L'ARIA, 14 Jan 2021

Citizens for Air welcomes the opportunity to provide a feed back on the AAQDs. Please find attached the feed back.

Consultation response

HKI Industrieverband Haus-, Heiz- und Küchentechnik e.V., 7 Mar 2023

In general, our industry supports the setting of air quality standards to prevent the build-up of excessive concentrations of pollutants. Clean air is important for human health and the environment. However, it should be noted that the WHO recommendations on which the revision of the Air Quality…

Consultation response

Wirtschaftsverband Stahl- und Metallverarbeitung e.V., 14 Jan 2021

Dear Sir or Madam, please find attached our feedback. Thank you for your considering our comments.

Consultation response

Provincie Utrecht, 14 Jan 2021

The Commission states that it is unlikely that an implementation plan is needed as the Ambient Air Quality Directive already is in force, and that the implementation structures are already in place within the Members States with the competent authorities appropriately designated. We would like to…

Consultation response

European Foundry Federation, 14 Jan 2021

According to the latest EEA's “Air quality in Europe - 2020 report”, a better air quality has led to a significant reduction of premature deaths over the past decade in Europe. EU, national and local policies and emission cuts in key sectors have improved air quality across Europe, the EEA report…

Consultation response

HKI Industrieverband Haus-, Heiz- und Küchentechnik e.V., 11 Jan 2021

The Industrial Association HKI sees the greatest potential for improving air quality in overcoming the blockade when replacing old appliances with more effective, combined biomass central and individual room heating. The announced Renovation Wave should, among other things, also target precisely…

Czech district heating group urges realistic air quality standards

Association for District Heating of the Czech Republic, 14 Mar 2023

The organization insists that air quality standards must be technically and economically feasible to avoid disrupting the energy transition. They also request that pollution reduction measures be distributed fairly among all contributors rather than just targeting industry.
This would prevent costly technical upgrades for heating plants already scheduled for phase-out.
Citizens seeking health damages lose easier legal pathways if the burden of proof remains unchanged.

Consultation response

Sveriges Kommuner och Regioner, 18 Jan 2023

SKR har följande att anföra: - SKR är positivt till att luftkvalitetsdirektivet uppdateras. Det är angeläget att ha en hög ambitionsnivå. Det är viktigt att nå WHO:s rekommendationer på lång sikt men det förutsätter att det går att uppfylla med rimliga åtgärder och i rimlig takt. - Det är angeläget…

Consultation response

Fundacja Instytut Spraw Obywatelskich, 14 Jan 2021

Instytut Spraw Obywatelskich z zadowoleniem przyjmuje inicjatywę Komisji dotyczącą przeglądu dyrektyw w sprawie jakości powietrza atmosferycznego, mając nadzieję na pozytywny wpływ regulacji na jakość powietrza, środowiska i zdrowie obywateli. Opinię przekazujemy w załączniku.

Consultation response

Luftförorenings- och klimatsekretariatet, 14 Jan 2021

Air pollution is the number one environmental health risk in the EU, causing both chronic and serious diseases such as asthma, cardiovascular problems and lung cancer. Air pollution is responsible for some 400 000 premature deaths every year in the EU and for damage to ecosystems and biodiversity…

Consultation response

Inter-Environnement Wallonie, 12 Jan 2021

La fédération Inter-Environnement Wallonie (IEW) soutien la Commission dans sa volonté de renforcer la législation de l'UE relative à la qualité de l'air. En particulier, IEW est favorable à l'alignement des valeurs limites européennes sur les lignes directrices de l'OMS. Un alignement sur les…