Industrial Emissions Directive

Ecolab welcomes the Commission’s proposal to revise the Industrial Emissions Directive and supports the high level of ambition in tackling emissions from large industrial installations as well as the stronger emphasis on energy and resource efficiency, including water.

Meeting the challenge of proper management of Hazardous Waste European Commission proposal amending the Industrial Emissions Directive (Directive 2010/75/EU) Eurits Comments June 2022 Eurits [the European Union for the Responsible Incineration & Treatment of Special waste] welcomes the Commission’s aims to update and modernise the Industrial Emissions Directive (IED) to deliver the objectives of the European Green…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

There is a significant risk that the revised directive will jeopardize an agile double twin transition of the industry to meet the challenges of climate change (carbon neutrality), limited access to resources (circularity), aging society (digitalization) and safe and sustainable chemicals (product innovation).

Dear Gentlemen, APQuímica — Associação Portuguesa da Química, Petrochemical e Refinação (Portuguese Association of Chemistry, Petrochemistry and Refination) welcomes this opportunity to express its views on the EC legislative proposal for amending/revising the Industrial Emissions Directive (IED), and to contribute to the ongoing process, following its participation in previous stakeholder consultations…

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EDF strongly supports the overall ambition of the EU Green Deal: to reach climate neutrality by 2050, as well as a 55% cut in GHG emissions by 2030. To implement this, the Group can build on an existing 90% decarbonized energy mix, thanks to the synergy between renewables and nuclear energy.

MGYOSZ (BusinessHungary) opinion on the revision of the Industrial Emission Directive for the open public consultation According to the evaluation of the Industrial Emissions Directive (IED) carried out by the Commission in 2019/2020, the IED was evaluated as largely efficient by broadly serving its purpose and showing tangible results (reduction in emissions regarding all key environmental pollutants).

The Fédération Nationale des Syndicats d’Exploitants Agricole (FNSEA), the leading French agricultural union, which brings together all the products of all the regions, makes the following observation: — Lowering the thresholds for pig and poultry installations (from 150 LU) would no longer force 7 % but exempt 70 % of French pig farms.

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Veolia welcomes the Commission’s proposal to revise the Industrial Emission Directive in an effort to support the EU Green Deal’s objectives and stands ready to support its implementation as the newly created champion of ecological transformation.

The EEB (real "environmental organisation") = "NGO", together with its active members ClientEarth, Carbon Market Watch and Ecos have provided its preliminary assessment on the proposal for revised IED + the Industrial Emissions Portal at this link https://eeb.org/library/ngo-preliminary-assessment-of-the-european-commissions-proposal-for-revised-ied-and-e-prtr/ Further briefings around the EEB's position and…

France Chimie welcomes the European Commission’s commitment to ensure that the Industrial Emissions Directive meets the Green Deal’s objectives of moving towards a zero-pollution environment and supporting climate, energy and circular economy policies.

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Revision of the Industrial Emissions Directive (IED): transformation of industry and security of power supply at stake  As part of the EU action plan "Zero Pollution Target for Air, Water and Soil", the EU Commission presented a proposal for the revision of the Industrial Emissions Directive (IED) on 5 April 2022.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, is fully committed to the objectives of the European Green Deal and the Circular Economy Action Plan as essential tools for providing the adequate stimuli to our economy while pushing forward EU Climate goals through the circular economy.

EURATEX, the European Apparel and Textile Confederation representing the interest of the European textiles and clothing industry, perceives the Industrial Emissions Directive proposal for review as greatly concerning.

Key messages: The existing solutions based on achieving emission limits falling within the ranges of BAT-AELs should be maintained, as they have enabled considerable and cost-effective success in the area of emission reductions adjusted to the technical specificity of installations.

Członek Europejskiej Rady Przemysłu Chemicznego CEFIC Warszawa, 23.06.2022 PIPC/176/2022 Stanowisko Polskiej Izby Przemysłu Chemicznego w ramach konsultacji Komisji Europejskiej ws. rewizji dyrektywy w sprawie emisji przemysłowych („IED”) Dyrektywa IED to jeden z najważniejszych unijnych aktów prawnych tworzących ramy dla funkcjonowania największych, europejskich instalacji przemysłowych.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Junho 2022 Posição da Federação Agrícola dos Açores relativa à Proposta de Atualização da Diretiva referente às Emissões Industriais Na sequência da adoção por parte da Comissão Europeia da proposta de atualização da Diretiva relativa às Emissões industriais - Diretiva 2010/75/UE do Parlamento Europeu e do Conselho, de 24 de novembro de 2010, relativa às emissões industriais (prevenção e controlo integrados da…

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EUROBAT, the Association of European Automotive and Industrial Battery Manufacturers, thanks the ‎Commission for the opportunity to comment on the proposal for a Directive revising Directive 2010/75/EU ‎‎(Industrial Emissions Directive).

The European Automobile Manufacturers’ Association (ACEA) is committed to reducing industrial emissions and therefore supports the planned revision of the IED. We as ACEA believe that the revision should be practical for companies as well as for authorities, and should start at the value-added processes where the greatest relevance for the reduction of industrial emissions can be achieved.

23 June 2022 Eurometaux’s Position on the new IED Proposal This paper provides an overview on the main critical issues for the Non-Ferrous Metals (NFM) sector and includes points to be considered in the review of the Industrial Emissions Directive (IED) and Industrial Emissions Portal (IEP).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Industrial Emission Directive Have your say consultation To : The Commission From: Svemin, Swedish Association of Mines, Mineral and Metal Producers Date : 2022.06.23 Summary The European Commission has proposed the inclusion of the (non-energy) mining sector into the scope of the Industrial Emissions Directive (IED) as part of a broader revision of the IED published on 5 April 2022 (see Commission´s proposal, Annex…

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Aurubis is a leading global supplier of non-ferrous metals and the world leader in copper recycling. We welcome the possibility to provide comments on the proposal for the revised Industrial Emissions Directive (IED). We believe the following cornerstones should be observed in the IED: - Approval procedures must be shortened and simplified, not lengthened. - Avoidance of bureaucratic regulations without added value.

The Finnish Forest Industries Federation (FIFF) supports the objectives of European Green Deal and ensures that the Finnish forest industry sector is willing to continuous environmental improvement and green transition. FIFF emphasises that the Industrial Emissions Directive (IED) has been an effective tool for reducing industrial emissions.

No revision of the IED in the current crisis In view of the war in Ukraine, Europe must now preserve the economic strength of companies and work on quickly effective, targeted and temporary measures to cushion the crisis. German industry sees the danger that companies will face existential difficulties due to energy prices or because of a Russian export ban on energy raw materials.

This contribution concerns only livestock. The integration of beef and methane and the 150 LSU threshold are welcome. In France the report of Cour des Comptes: L’encadrement et le contrôle … dans le domaine agricole points inefficiency, lack of means and obstruction, with high concern also for farms below the IED threshold.

Glass Alliance Europe is the European Alliance of Glass Industries. It has the unique feature of regrouping all the glass industries to work on common issues. It is composed of 14 national glass associations and of the 5 main sectors of the glass industries: container glass, flat glass, special glass, domestic glass and continuous filament glass fibres.

La Coopération Agricole is the single representative of French agricultural, agri-food, agro-industry and forestry cooperatives. We support the EU’s climate objectives and are committed to reducing the environmental impact of agricultural activities.

The IED (2010/75/EU) regulates large industrial emissions since the end of 2010. An evaluation in 2019 carried out by DG ENV showed that the IED is efficient, fit for purpose and has achieved its goals to a large degree as emissions have been reduced significantly across Europe. However there was also room for improvement which together with the targets of the EU Green Deal has triggered a review of the IED in 2021.

The Industrial Emissions Directive (IED) 2010/75/EU has been in force since the end of 2010, regulating large industrial installations and defining requirements for their permits. It also provides the basis for the "BREF process" in Seville, which resulted in a large number of binding conclusions corresponding to the best available techniques (BAT).

European Association of Mining Industries, Metal Ores & Industrial Minerals Revision of the Industrial Emissions Directive – Commission proposal to include mining sector - Feedback to “Have your Say” webpage Brussels, 23 June 2022 The European Commission has proposed the inclusion of the (non-energy) mining sector into the scope of the Industrial Emissions Directive (IED) as part of a broader revision of the IED…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

GENERAL COMMENTS: - In the view of the current international situation, in particular Russia's aggression against Ukraine and the resulting reduction in gas supplies to the EU, as well as the experience of the COVID-19 pandemic which generates the risk of a lack of sufficient generation capacity in the energy sector due to delays in investments, a system solution is needed to guarantee security of energy supply to…

The European Commission’s proposal for the revision of the Industrial Emissions Directive (IED) aims to contribute to achieving the objectives of the GREEN DEAL for a sustainable, climate-neutral EU-27 economy. The German textile industry, which is primarily a full-collar textile industry, is committed to sustainability and production-integrated environmental protection.

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Dans le cadre du Pacte Vert européen et l’objectif « Zéro pollution », la Commission européenne a présenté, le 5 avril 2022, un projet de réforme de la directive n°2010/75 relative au émissions industrielles (IED).

Carbon Market Watch welcomes the opportunity to provide feedback on the European Commission's proposal for the revision of the Industrial Emissions Directive. The revision of the Industrial Emissions Directive (IED) represents a huge opportunity to strengthen the directive to ensure it fulfills the objectives of the European Green Deal and effectively addresses the negative impact of industrial emissions on the…

FNADE’s Position Industrial emissions – EU rules updated June 2022 FNADE, the French association for waste management and environmental services welcomes the proposal of the European Commission for the Revision of Industrial Emissions Directive (IED) which has really helped to reduce for these last years the emissions of industrial activities in the air, water and soil.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Germany is one of the world’s leading countries in potash and salt mining, employing more than 11 000 people. German potash and salt mining is essential for Europe’s salt and fertiliser supply and makes Europe independent of Belarusian and Russian potash supplies.

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Dear Sir or Madam, please find enclosed the comments from the Bundesverband Sekundärrohstoffe und Entsorgung e.V. (bvse), the Bundesvereinigung Deutscher Stahl Recycling- und Entsorgungunternehmen e.V. (BDSV) and the Verband Deutscher Metallhändler und Recycler e.V. (VDM). Yours sincerely, [name removed]

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STATEMENT Ref. Ares(2022)4617009 - 23/06/2022 FoodDrinkEurope views on the European Commission Proposal for a Revision of the Industrial Emissions Directive There is an urgent need to reduce greenhouse gas emissions significantly, and rapidly, to prevent a rise in global temperatures with devastating impacts on people, biodiversity, the environment, and our food production.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

WKO, the Austrian Federal Economic Chamber, is still in the process of developing a compre-hensive position regarding the legislative proposal COM(2022) 156 final for amending the IED. As from our point of view the legislative proposal contains quite some problematic provisions, for now we would just like to provide feedback in form of a catalogue of questions – which we hope the European Commission can both answer…

VCI-Stellungnahme Entwurf der Industrieemissionsrichtlinie vom 6. April 2022 VORBEMERKUNG Die Richtlinie 2010/75/EU über Industrieemissionen (IED) ist seit Ende 2010 in Kraft. Die Industrieemissionsrichtlinie definiert den aktuellen Stand der Technik und enthält Anforderungen an Industrieanlagen und deren Genehmigung.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PROPOSTA DE REVISÃO DA DIRETIVA EMISSÕES INDUSTRIAIS [COM (2022) 156 FINAL] COMENTÁRIOS CIP - ASPETOS PREOCUPANTES COM IMPACTO NEGATIVO NA COMPETIRIVIDADE DAS EMPRESAS - ENQUADRAMENTO Da análise da proposta de revisão da Diretiva Emissões Industriais (IED), acolhemos com satisfação a manutenção da definição de BAT-Melhor Técnica Disponível (Art.3º), assim como a tentativa de harmonização das condições em que podem…

Filed in Portuguese · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Alliance to Save Energy (EU-ASE) welcomes the Commission’s proposal to revise the Industrial Emissions Directive and supports the high level of ambition in tackling emissions from large industrial installations as well as the stronger emphasis on energy and resources efficiency, including water.

As part of the European Green Pact and the Zero Pollution objective, on 5 April 2022 the European Commission presented a draft reform of Directive 2010/75 on industrial emissions (FDI). A3M would firstly point out that this proposal nevertheless comes at a time when European industry faces multiple challenges: high pressure on raw material and energy prices, the need to invest heavily in the energy transition and…

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As PFP (Primary Food Processors) member, Starch Europe fully supports the PFP position on the proposal for revision of the IED. With this proposal, the European Commission is striving for a toxic free environment and to support climate, energy and circular economy policies. Starch Europe however recalls that, to achieve those goals, EU industry must remain competitive.

LRF Dairy Sweden Statement On the EU Commission proposal for the revision of the Industrial Emissions Directive (IED) The overall EU framework to restrict unnecessary emissions is followed by the dairy sector since the start, and the EU leaders see the importance of the agri-food sector in providing food to the population. Current tendencies and realities only underline this importance.

Hungarian Chemical Industry Association (MAVESZ) opinion on the revision of the Industrial Emission Directive for the open public consultation According to the evaluation of the Industrial Emissions Directive (IED) carried out by the Commission in 2019/2020, the IED was evaluated as largely efficient by broadly serving its purpose and showing tangible results (reduction in emissions regarding all key environmental…

With its proposal for revision of the IED the European Commission is striving for toxic free environment and to support climate, energy and circular economy policies. Primary Food processors (PFP) however recalls that to achieve those goals EU industry must remain competitive.

APICER, the Portuguese Association of Ceramic Industries and Cristalaria, is grateful for your opportunity to participate in this public consultation and thus to present our comments on the document. We have thus prepared a document divided into several chapters: — Overall assessment of the document; — Positive aspects; — General aspects of concern to us; — Specific points of concern for the ceramics industry, in…

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The European Copper Institute (ECI) acknowledges the high ambition of the EU Green Deal, which materialised into the Zero Pollution Action Plan, the Chemical Strategy for Sustainability and the Circular Economy Action Plan. The three initiatives refer to the need to review the Industrial Emission Directive, which is pivotal in controlling and preventing environmental emissions.

In the context of the Public Consultation of the Industrial Emissions Directive (IED), the Portuguese associations representing the extractive and manufacturing sector — Cluster of Mineral Resources, ANIET, APICER and ASSIMAGRA — are therefore submitting their comments, as reflected in the attached joint and concerted participation document.

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A proposal against the objectives of the green deal for cattle farming! This revision of the rules on INDUSTRIAL emissions is not adapted to cattle farms and will have a negative and counterproductive effect on the environment. It is therefore appropriate, as is the case at present, to retain the exclusion of cattle farms from this legislation.

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Neste is the world’s leading producer of sustainable aviation fuel and renewable diesel, and renewable feedstock solutions for various polymers and chemicals industry uses. We are also developing chemical recycling to combat the plastic waste challenge. Our ambition is to make the Porvoo oil refinery in Finland the most sustainable refinery in Europe by 2030.

23.6.2022 VC Stellungnahme des Fachverbandes Steine-Keramik Review Industrieemissionen-Richtlinie Der Fachverband Steine-Keramik als gesetzliche Interessenvertretung der österreichischen Baustoffindustrie vertritt 313 Mitgliedsfirmen mit einem Gesamtjahresumsatz von € 3,23 Milliarden und knapp 14.000 Beschäftigten.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Spanish magnesia association (MAGES) firmly supports the EU Green Deal’s objectives and stand ready to support its implementation. The high energy prices, the disrupted supply chains and high inflation pose existential difficulties to companies who have already been under pressure in the last years due to the COVID crisis.

The Federation of Norwegian Industries represents a wide range of industry branches. We represent over 3.000 companies with approx. 130.000 employees. Our main input to the revision of Directive 2010/75/EU can be found below.

Stellungnahme 22. Juni 2022 Vorschlag für eine Richtlinie des Europäischen Parlaments und des Rates zur Änderung der Richtlinie 2010/75/EU des Europäischen Parlaments und des Rates vom 24. November 2010 über Industrieemissionen (integrierte Vermeidung und Verminderung der Umweltverschmutzung) und der Richtlinie 1999/31/EG des Rates vom 26. April 1999 über Abfalldeponien (IE-Richtlinie) Der Fachverband Biogas e.V.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Spanish Cement Association, OFICEMEN, firmly supports the EU Green Deal’s objectives and stand ready to support its implementation. The high energy prices, the disrupted supply chains and high inflation pose existential difficulties to companies who have already been under pressure in the last years due to the COVID crisis.

Bioenergy Europe welcomes the revision of the Industrial Emissions Directive (IED) and higher ambition that the Commission is showing in this context. However, the continued exclusion of construction and demolition waste in the revised definition of “Biomass” (Art. 3 (31)) risks leading to the non-recognition of wood waste as biomass.

An ambitious proposal for amendments to the current Directive, in particular as regards the extension of the scope of the legislation to include other activities, in particular those related to intensive livestock farming, comes in line with the Green Deal ambition, but for the agricultural sector at a completely inappropriate time (including in view of the sharp rise in food prices, there would be a risk of further…

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European Commission DG ENV Unit C4 Brussels, 23 June 2022 EPF feedback on the Proposal for a Directive Amending Directive on Industrial Emissions and Directive on Landfill of Waste The European Panel Federation (EPF) welcomes the possibility to provide feedback on the Proposal for a Directive Amending Directive 2010/75/Eu on Industrial Emissions (Integrated Pollution Prevention and Control) and Directive 1999/31/EC…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Federation of European Producers of Abrasives (FEPA) represents the European abrasive industry since its inception in 1955, encompassing four product segments, bonded and coated abrasives, superabrasives and (conventional) grains. It represents over 19000 European jobs and more than 250 companies from 23 countries and 7 national associations. FEPA has been part of the Art. 13 forum since 2019.

Good afternoon, We attach a document containing the position of ANIET — National Association of Extractive and Transformative Industry, representing the metal, non-metallic, ornamental and aggregates sectors. ANIET stands by EUROMINES, a European association of which it is an associate member. I would like to thank you, Francelina Pinto Director General

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RECHARGE, the leading industry association for advanced rechargeable and lithium batteries in Europe, fully supports the EU Green Deal objectives and welcomes the revision of the Industrial Emissions Directive (IED) to truly guide large European industry to meeting the zero-pollution ambition by 2050.

CEFS, the European Association of Sugar Manufacturers, recognises the urgent need to quickly and significantly reduce Greenhouse Gas (GHG) emissions to counter the rise in global temperatures, which risks huge impacts on people, biodiversity, the environment, and food production.

UNESID, the Spanish Steel Association, understands the revision of the Industrial Emissions Directive (IED) and the effort that shall be made by the European Union to ensure its alignment with the EU Green Deal’s objectives. Taking the opportunity to give feedback, we should start by saying that this revision comes amid very difficult economic panorama.

The Industrial Emissions Directive is one of the most important directives governing the operation of chemical installations. The Directive covers more than 80 chemical installations in Finland. The proposal for a new Industrial Emissions Directive (COM(022) 156 final) is in line with the objectives of the EU Green Deal and aims to accelerate the transition of companies towards a greener future.

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EURACOAL is pleased to submit its attached response to the European Commission's proposal to revise the IED. The proposal would result in the further de industrialisation of Europe as it puts a disproportionate burden on European industry and the energy sector.

PRISE DE POSITION D’INTERBEV SUR LES DIRECTIVES IED INTERBEV est l’Association Nationale Interprofessionnelle du Bétail et des Viandes, fondée en 1979 à l’initiative des organisations représentatives de la filière bétail et viandes (de ruminants).

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Paris, le 23 juin 2022 Position du MEDEF vis-à-vis de la proposition de la Commission Européenne révisant la directive sur les émissions industrielles Alors que l’évaluation faite de la directive IED avait montré la pertinence de cette dernière pour réduire de façon conséquente les émissions industrielles, la Commission Européenne a fait le choix de réviser cette directive pour renforcer sa mise en œuvre dans les…

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The overall EU framework to restrict unnecessary emissions is followed by the dairy sector since the start, and the EU leaders see the importance of the agri-food sector in providing food to the population. Current tendencies and realities only underline the importance. We are willing to further work on our raw material uses and critical emissions and wish to continue improving as much as possible.

Comments and observations on the revision of the Industrial Emissions Directive BAT-AEL Setting emission limit values complying with the lower limit of the emissions range associated with the best available techniques (BAT-AEL), according to art.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Federal Association of the German Glass Industry (BV Glas) is a central point of contact for everything glass related. One of its most important functions is to provide key information about the German glass industry and about glass as a material not only to industrial users and decision-makers, but also the craft and retail trades, opinion leaders in the fields of science, research, politics and media, as well…

Climate Action Network (CAN) Europe is Europe's leading NGO coalition fighting dangerous climate change. With over 185 member organisations from 38 European countries, representing over 1.700 NGOs and more than 47 million citizens, CAN Europe promotes sustainable climate, energy and development policies throughout Europe.

The revised IED has huge potential to become one of the legislative flagships translating the European Green Deal’s objectives into tangible legal obligations. Main issues of today’s IED have been described in our submission 2021 (https://www.clientearth.org/latest/documents/revision-of-the-industrial-emissions-directive/).

European Industrial Insulation Foundation (EiiF) strongly supports the initiative to update EU rules on industrial emissions. We encourage this initiative in its aim to ensure industry uses techniques that create a more sustainable EU economy, and a cleaner environment that improves public health.

Opinion of the Association of German abrasives VDS on the proposal for a Directive of the European Parliament and of the Council amending Directive 2010/75/EU of 24 November 2010 on industrial emissions, document COM(2022)156; In the attached opinion we refer to the amended definition of installations for the manufacture of ceramic products by firing in Annex I, point 3.5.

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We support the proposal since it supports water carriers an circular economy investments. However, we have had separate points of attention. First of all, in Article 3 (b). 12, Suez advocates for the BAT conclusions to restore as performance level and not to be binding. To avoid cross effects, proposals on emissions and performance should be documented in a technical way.

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The Industrial Emission Directive (IED) is a cornerstone of the EU legislation, aiming at achieving a high level of protection of the environment as a whole. The EU Commission’s proposal for a revision of the IED provides valuable and key provisions to prevent and control pollution arising from industrial activities and issue environmental permits.

The Confederation of the European Paper Industries (Cepi) highlights that the Industrial Emissions Directive (IED) proved, also via its fitness check, that the Directive is fit for purpose. The IED and the sector-specific BAT conclusions have delivered a considerable reduction in industrial emissions and achieved the goals they were set up to fulfill.

The IED (2010/75/EU) has regulated large facility industrial emissions since the end of 2010. An evaluation undertaken in 2019 by DG ENV concluded that the IED is efficient, fit for purpose and has achieved its goals to a large degree as emissions have reduced significantly across Europe.

The professional association of wood energy (FVH) in the Federal Bioenergy Association welcomes the objectives of the Green Deal to increase the share of renewable energy and reduce greenhouse gas emissions. The FVH sees the revision of the IED as an opportunity to support and remove barriers to the expansion of renewable energies.

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The proposal to revise the IED provides for the extension of the scope, the tightening of limit values and numerous additional information requirements. This would lead to high additional costs for retrofitting and bureaucracy. Authorisation procedures for large industrial installations would be even more lengthy.

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Komentář Hospodářské komory České republiky k návrhu revize směrnice 2010/75/EU o průmyslových emisích Evropská komise představila dne 5. dubna 2022 návrh „Proposal for a Revision of the Industrial Emissions Directive“ (dále jen IED revize). Hospodářská komora ČR (dále jen HK ČR) má k návrhu IED revize následující připomínky. Obecná připomínka: 1.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The IED (2010/75/EU) has regulated large facility industrial emissions since the end of 2010. An evaluation undertaken in 2019 by DG ENV concluded that the IED is efficient, fit for purpose and has achieved its goals to a large degree as emissions have reduced significantly across Europe.

The new Industrial Emissions Directive (IED) risks slowing the green transition, innovation and complicating permit processes The IED has been an effective tool for reducing industrial emissions and has delivered new legislation year after year via Seville process and BAT-conclusion, sector by sector. All 30 BREF are not yet revised under this cycle.

ROCKWOOL supports the need to strengthen and improve the Industrial Emissions Directive (IED) and appreciates the Commission’s proposal particularly regarding energy efficiency and circular economy aspects. ROCKWOOL welcomes the proposal to make energy efficiency requirements mandatory by strengthening the already existing horizontal BREF for energy efficiency and making it mandatory for all sectors.

EURIMA Position Paper on the revision of the Industrial Emissions Directive (IED) Key recommendations  Further clarify the BREF process to guarantee ambitious, yet achievable Emission Limit Values and ensure proportionality in the setting of those linked to Environmental Quality Standards; consider a transitional period as part of transformation plans.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eurogypsum, the European federation representing the gypsum extractive and processing sector, as well as the producers of gypsum solutions, such as plaster and plasterboard, supports the European Green Deal’s objectives and is committed to supplying materials and products which enable Europe’s transition to a climate neutral, pollution free and circular economy, particularly with solutions for building renovation…

CIELFFA is representing the interests of the European cold rolling industry, an independent sector of the steel manufacturing industry with mostly small and medium-sized companies. We strongly oppose the inclusion of cold rolling mills in the scope of the IED for the following main reasons: - No significant adverse environmental impacts arise from this industry.

CIELFFA is representing the interests of the European cold rolling industry, an independent sector of the steel manufacturing industry with mostly small and medium-sized companies. We strongly oppose the inclusion of cold rolling mills in the scope of the IED for the following main reasons: - No significant adverse environmental impacts arise from this industry.

The European Commission has put forward a regulatory proposal with its draft new Industrial Emissions Directive on Integrated Pollution Prevention and Control (IED). It provides for an extension of the scope, as well as extensive new and unnecessarily disruptive requirements for operators of industrial installations. It provides, inter alia, for the inclusion of cold rolling mills in Annex I.

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Against the background of the goal of greenhouse gas neutrality, the steel industry in Germany is determined to successfully lead the transformation towards climate-neutral and sustainable steel production and to become the technology leader for innovative and climate-friendly production processes.

Chemours is a different kind of chemistry company driven by a purpose to create together with our employees, customers and communities a more colorful, capable, and cleaner world through the power of chemistry. Built upon a 200-year-old legacy and a world-class product portfolio, Chemours has major research, development, and production facilities in every region of the world, with a special focus in Europe.

We urge lawmakers to adopt strong and enforceable provisions that reflect the severity of the negative impact animal farming has on our environment. While we welcome the proposed increase in the number of animal farms falling under the scope of the Industrial Emissions Directive, the weaker and inadequate rules under the IED tailored for animal farming are very troubling and could threaten the protection of our…

In the document attached, you will find OFICEMEN's amendments suggestions to the Proposal for a Directive Amending Directive 2010/75/Eu on Industrial Emissions (Integrated Pollution Prevention and Control) and Directive 1999/31/EC on Landfill of Waste. Best regards

Central Europe Energy Partner (CEEP) would like to present its comments to the Inception Impact assessment for the revision of the Industrial Emissions Directive (IED). We believe that achieving climate neutrality should be made in a gradual and coherent manner without overlapping policies and tools but also should set a clear pathway for industry in the regulatory framework. Please find attached our feedback.

The Shift Project (TSP) is a think-tank advocating the shift to a post-carbon economy. As a non-profit organization committed to serving the general interest through scientific objectivity, we are dedicated to informing and influencing the debate on energy transition in Europe.

April 21st, 2020 COMMENTS FROM SPAIN CONCERNING THE DOCUMENT “INCEPTION IMPACT ASSESSMENT”- IED REVISION PROCEDURE INCEPTION IMPACT ASSESSMENT Inception Impact Assessments aim to inform citizens and stakeholders about the Commission's plans in order to allow them to provide feedback on the intended initiative and to participate effectively in future consultation activities.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

They are Pierpaolo Albertario, the IED environmental inspector, the council to read some of my publications produced some years ago. Effective sustainable development strategies and self-sustainable management methodologies can be found in these strategies. Circular economy and finance, and system self-sustainability.

Filed in Italian · English published by the European Commission

Green Dictionary welcomes the findings of the European Commission that a review of the IED is necessary to improve delivery and effectiveness of its goals. The current goal is to achieve a high level of environmental protection from industrial activities, with priority to pollution prevention over control.

The EU Directive 2010/75 EU pursues the goal of enforcing the same level of environmental protection at a similar technological level throughout Europe. In accordance with this Directive, the EU Commission adopted Commission Implementing Decision (EU) 2017/302 of 15 February 2017 establishing BAT conclusions of the BREF documents as binding guidelines for livestock installations in the field of pig and poultry…

The EU Directive 2010/75 EU pursues the goal of enforcing the same level of environmental protection at a similar technological level throughout Europe. In accordance with this Directive, the EU Commission adopted Commission Implementing Decision (EU) 2017/302 of 15 February 2017 establishing BAT conclusions of the BREF documents as binding guidelines for livestock installations in the field of pig and poultry…

We connect Polish Business and Science with the EU Ref. Ares(2020)2163466 - 21/04/2020 #BSP_Paper April 2020 Industrial Emissions Directive (IED) Revision 1. Introduction Business & Science Poland (BSP) is grateful for the opportunity to provide comments to the Inception Impact Assessment (IIA) on the revision of the Industrial Emissions Directive (IED).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Following the Commission’s assessment impact on the Industrial Emissions Directive, the Belgian Confederation of Belgian Enterprises (FEB) would like to further focus on the following issues: The FBO considers that it would not be appropriate to take into account the impact of the circular economy or the reduction of greenhouse gas emissions through the Industrial Emissions Directive.

Filed in Dutch · English published by the European Commission

From the point of view of the DIHK, the IED as a whole proves to be an effective legal instrument to reduce industrial emissions. In general, a large number of companies expect the economic benefits of the IED by creating a uniform level of requirements across the EU and avoiding distortions of competition. However, individual companies report contrary experiences in other EU Member States.

Filed in German · English published by the European Commission

The IED is well-drafted and provides a structured framework for a techno-economic process for the preparation of BAT conclusions. However, the “Seville process” appears to be in need of improvement. Based on our experience with updating the LCP BREF, the process was biased towards political considerations rather than the technical and economic factors specified in the IED.

Summary of recommendations - The Industrial Emissions Directive (IED) is the main EU regulatory instrument dedicated to emissions from industrial installations and related processes. The assessment of coherence with circular economy and climate neutrality set out in the EU Green Deal should not compromise the IED's key objective.

Sycom shares the Commission’s finding on the effectiveness of the Industrial Emissions Directive (IED), and stands ready to take part in the reflections on its possible revision in the light of the decarbonisation objectives. Are affected by the IED and GHG issuers: Burial and burning. 1. The IED will be ineffective without actions to reduce the presence of fossil materials in incinerated waste.

Filed in French · English published by the European Commission

Członek Europejskiej Rady Przemysłu Chemicznego CEFIC Warszawa, 21.04.2020 PIPC/113/2020 European Commission DG ENV Unit C4 Industrial Emissions & Safety Rewizja dyrektywy w sprawie emisji przemysłowych W związku z trwającymi konsultacjami społecznymi Komisji Europejskiej odnośnie rewizji dyrektywy w sprawie emisji przemysłowych (Dyrektywy IED), Polska Izba Przemysłu Chemicznego zwraca uwagę na poniższe kwestie.

Filed in Polish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Detailed comments are in the document attached. Summary Climate Action Network Europe welcomes the European Commission found the review of the IED necessary and the need to improve its implementation, delivery and effectiveness on its objectives.

2020 Industrial Affairs Ref. Ares(2020)2171462 - 22/04/2020 21 April 2020 Federación Empresarial de la Industria Química Española – www.feique.org Hermosilla, 31 - 28001 Madrid – Tfno: 91 431 79 64 – Fax: [phone removed] –[email removed] FEIQUE’s comments on the European Commission’s Inception Impact Assessment regarding a revision of the Industrial Emissions Directive (IED) GENERAL COMMENTS As a general comment, we…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ESWET acknowledges the Commission’s plan to revise the Industrial Emissions Directive, in particular its ambition to contribute to circularity and the decarbonisation of industry. In that respect, ESWET expresses its support to the Commission’s efforts towards a green transition and seizes the opportunity to share its perspective.

Dear, I attach comments from the Swedish Government on the Inception Imact Assessment for EU rules on industrial emissions - revision. Best regards [name removed] [name removed] Coordinator SWEDISH Environmental Protection Agency EU Unit OFFICE: Virkesvägen 2, Stockholm MAIL: 106 48 Stockholm TELEPHONE: [phone removed] INTERNET: swedishepa.se

Tervehdys, Thank you for this opportunity to give our comments to Commission’s plan in its early stage. FinnMin has reservations with the Commission suggestion that, as part of the planned revision of the IED, it might be advantageous to include mining sector in the IED. We do not share the view that IED framework and processes related would make any additional value if extractive industries would be included.

EurEau represents both drinking water and waste water service national associations from 29 countries in Europe. Protection of drinking water resources is one of our key concerns and the Industrial Emission Directive should be a key contributor to it.

ClientEarth supports the EEB's position on this inception impact assessment, as well as its submissions to the IED fitness check roadmap and targeted consultation. We made our own submissions on issues of access to information, public participation and access to justice as part of the fitness check (https://www.documents.clientearth.org/library/download-info/ied-fitness-check-response-aarhus-issues/).

Recent assessment of IED has shown both environmental benefits and also the need of some improvements. FNADE, representing the french recycling and waste management sector, would like to give some comments on the different options the commission has explored for modernizing IED: ● First of all, FNADE wants to underline IED is an adequate tool to reduce water and air emissions and to tackle the environment and health…

Meeting the challenge of Proper Management of Hazardous Waste Industrial Emissions Directive: Inception Impact Assessment Eurits comments, April 2020 Eurits welcomes the Inception Impact Assessment (IIA) on the potential revision of the Industrial Emissions Directive (IED) (Directive 2010/75/EU).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Comentários CIP na Consulta CE da Avaliação de Impacto Inicial sobre a revisão da Diretiva das Emissões Industriais (DEI) A indústria nacional considera que a Diretiva das Emissões Industriais tem sido eficaz na prevenção e controlo da poluição, mas não poderá por si só responder a todas as questões de ambiente e clima. Deverá ser sempre avaliada em conjugação com os restantes diplomas e regulamentos da EU.

Filed in Portuguese · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The PGE Capital Group is the biggest Polish energy utility with a total 56,03 TWh of electricity and 50,33 PJ of heat generated in 2019, which guarantees a safe and reliable power supply to ca. 5.27 million of electricity consumers. Nearly all of our units need to hold a relevant permit within the meaning of the Article 4 of the Industrial Emissions Directive (“IED”).

Eni’s views on the European Commission Inception Impact Assessment - Revision of the Industrial Emissions Directive Eni fully supports the European Commission’s objective to provide industry with a coherent framework for a cleaner and more environmentally sustainable Europe, in line with the Green Deal and to which the revision of the IED could contribute.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in buildings and in industrial facilities.

Bioenergy Europe would welcome the revision of the Industrial Emissions Directive (ITD). The transition towards carbon neutral economy requires an appropriate legal framework providing a legal certainty for all participants of the market.

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental NGO in Finland. We have been quite happy with the IPPC/IED, but we largely agree with the analysis by the European Commission. Now it is high time to take the next step forward and make a review of the IED. There are our three main messages for further work.

Legal-Informational Centre fro NGOs (PIC) from Slovenia supports the findings of the European Commission that a review of the IED is necessary in order to achieve a high level of environmental protection from industrial activities, with priority to pollution prevention over control.

Veolia is the global leader in optimised resource management. With over 170,000 employees worldwide, the Group designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries.

EUCOPRO ASBL Rue Vilain XIIII, 53-55 B-1000 Brussels Phone: [phone removed] Fax : [phone removed] EUCOPRO Interest Representative Identification number: 75111426376-95 Brussels, 20 April 2020 Inception Impact Assessment : Revision of the Industrial Emissions Directive Eucopro comments Eucopro – the European Association for Co-processing is composed of waste pre-treatment companies that prepare alternative fuels and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In the context of the European Green Deal, EDA shares and fully supports the EU’s ambition to take coherent and forceful leadership at European and global level. The dairy industry is committed to play its role within this new set of policy tools to further strengthen our full engagement and support to the efforts made at all levels of the supply chain.

Brussels, 20.04.2020 PKEE position on the IIA to the Industrial Emissions Directive revision 1. Polish Electricity Association (PKEE) acknowledges Commission’s attempt to review IED which is setting emissions caps for industrial activities.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The TÜV-Association welcomes the Commission’s initiative to consider a revision of the IED. While the use of Best Available Techniques (BAT) has proven successful in defining binding emissions values within the EU, it is equally important to ensure its effective implementation within the member states.

CEWEP, the Confederation of European Waste-to-Energy Plants, believes that IED provisions and the BREF process are a fundamental step forward for the reduction and elimination of pollutants arising from industrial activities.

FuelsEurope welcomes the possibility to provide its feedback on the Inception Impact Assessment (IIA) on the revision of the Industrial Emissions Directive. FuelsEurope considers the IED an essential regulatory policy instrument since it ensures a very high level of protection of the environment as a whole through the setting of permit conditions based on the Best Available Technologies (BAT) and its Associated…

The European Recycling Industries’ Confederation – EuRIC - welcomes the publication of an Inception Impact Assessment (IIA) within the framework of the revision of the Industrial Emission Directive. Looking at the different objectives and policy options detailed in it, EuRIC wishes to make the following comments. - BREF Process EuRIC agrees that options to improve the BREF elaboration process have to be explored.

MEDEF, Comments on the Inception Impact Assessment on IED directive While many industrial sectors are currently mobilized in the management of the COVID-19 crisis, it is extremely difficult to carry out this consultation which requires the answer of all the sectors concerned.

Bellona Europa fully supports the comprehensive feedback to the Inception Impact Assessment on the Industrial Emissions Directive revision by the European Environmental Bureau and Carbon Market Watch. As the Inception Impact Assessment states, the revision of the Industrial Emissions Directive (IED) should improve its effectiveness and facilitate increased ambition in line with the policies of the Green Deal.

Carbon Market Watch fully supports the comprehensive feedback provided by the European Environmental Bureau to the inception impact assessment and welcomes the opportunity to give specific views on how the Industrial Emissions Directive (IED) should be revised to support industrial decarbonisation in a complementary manner to the EU Emission Trading System.

• Orano thanks the European Commission for giving it an opportunity to give its opinion on this roadmap and notes that the IED is rather efficient. If improvements can be made, a recast of these provisions is not urgent. On the other hand, it seems a priority to harmonise the implementation of this directive in the Member States.

Filed in French · English published by the European Commission

FEAD does not call for a revision of the IED (Industrial Emissions Directive), and is convinced that climate ambitions, as well as circular economy benefits, should be addressed elsewhere. IED’s philosophy relies on site specific permitting. It is not suited for an overarching approach.

Europe’s non-ferrous-metals industry welcomes the opportunity to provide feedback on the Inception Impact Assessment planning for the Industrial Emissions Directive and would like to share several recommendations on the way forward. Attached you find our considerations regarding the scoping, coherence with other policies as Circular Economy, decarbonisation and water legislation.

Eurogypsum’s initial remarks on the review of the Industrial Emissions Directive: A balanced appraisal of benefits, costs and implications is required In light of the impact of today’s Covid-19 crisis on our members’ operations, availability and priorities, as well as the short consultation time available on the inception impact assessment, Eurogypsum is only able to make a few remarks at this stage on the plans for…

COMMENTS of the Association UKRMETALURGPROM (Ukraine) concerning the Revision of the Industrial Emissions Directive Association Ukrmetalurgprom represents the whole Ukrainian mining & steel industry and herewith would like to share its views as regards inception impact assessment re review of industrial emission rules in the EU.

Bayer would like to express its full support of the Commission Zero Pollution ambition and objective to protect Europe natural capital and people health. By initiating a European Green Deal, Europe has taken a decisive step to address the most pressing challenges of our generation. Our feedback on the Industrial Emissions Directive roadmap can be found in the attached document.

Regarding the proposed roadmap, Bioenergia ry - the Bioenergy Association of Finland would like to highlight some key issues which need to be taken into consideration by the European Commission. As for the Inception Impact Assessment, making legislation consistent and interfaces more fluent between various regulations is welcomed, but overlapping legislation must be avoided.

Regarding the public consultation opened by the European Commission on Inception Impact Assessment for the Revision of the Industrial Emissions Directive, ANFAC (Spanish Automobile Manufacturers' Association) expounds its comments bellow. In the first place, we remain doubtful of the appropriateness of the timing for this revision, given that several BREFs have yet to be adopted.

AFEP, the French Association of Large Companies, welcomes the consultation of the European Commission on an Inception Impact Assessment in view of a possible revision of the Industrial Emissions Directive, following a public consultation in the summer of 2019 to which AFEP responded.

The IED and the consequential requirements of the Directive in the form of BAT conclusions BREFs are of general importance in order to increase the level of environmental protection in the EU in the field of industrial emissions and to harmonise these requirements.

Filed in Swedish · English published by the European Commission

Revision of the Industrial Emissions Directive – Inception Impact Assessment A Eurelectric comments paper April 2020 Eurelectric represents the interests of the electricity industry in Europe. Our work covers all major issues affecting our sector. Our members represent the electricity industry in over 30 European countries.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Technology Industries of Finland’s contribution to the Inception Impact Assessment of the revision of Industrial Emissions Directive (IED) Technology Industries of Finland thanks for of the possibility to comment Commission’s plan, revision of Industrial Emissions Directive, in its early stage as Inception Impact Assessment is.

The energy sector has been subject to a drastic strengthening of environmental requirements (LCP, IED, BAT) which will lead to further significant emission reductions. It is very challenging from the technical and economical point of view and has also a significant impact on the Member States, especially on the early stage of energy transition as the Poland is.

Warsaw, 21st April 2020 PGNiG POSITION ON INCEPTION IMPACT ASSESSMENT CONCERNING REVISION OF THE INDUSTRIAL EMISSIONS DIRECTIVE PGNiG welcomes the opportunity to comment on the inception impact assessment concerning revision of Industrial Emissions Directive 2010/75/EU (IED).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

• We agree to the conclusion that there are significant EU added value and we believe that the Seville process is an important tool in this regard and should continue. A review of the Seville process instead of an opening of the Directive could accommodate most of the issues identified by the IED evaluation eg climate, energy and circular economy.

As it currently stands the art. 42 (1) of IE-Directive is ambiguous and needs to be clarified. The paragraph 2 reads “This Chapter shall not apply to gasification or pyrolysis plants, if the gases resulting from this thermal treatment of waste are purified to such an extent that they are no longer a waste prior to their incineration and they can cause emissions no higher than those resulting from the burning of…

CO2 Value Europe (CVE) is the European association dedicated to Carbon Capture and Utilisation (CCU) and is representing over 65 members along the CCU value chain, primarily industrial actors from different sectors. CVE welcomes the Commission’s initiative to revise the Industrial Emissions Directive (IED) and the opportunity to provide feedback on the roadmap.

As a part of European chemical industry, Finnish chemical industry is strongly committed to contribute its proposals to support the review of the IED-Sevilla process. To date, the European chemical manufacturers are directly or indirectly impacted by some 20 BREFs. Therefore, the drafting of reference documents describing Best Available Techniques (a.k.a.

Re: Potential inclusion of additional sectors Stockholm, 21 April 2020 Svemin is the national industry association for mines and for mineral and metal producers in Sweden, representing around 40 companies which employ 13,000 people in production, exploration and technology. Our member companies are active throughout the country, with the mines being mainly located in northern Sweden and Bergslagen.

21.04.2020 AK-406 European Commission DG ENV Unit C4 Industrial Emissions & Safety Bruxelles/Brussel BELGIQUE/BELGIE COMMENTS of the Association UKRMETALURGPROM (Ukraine) concerning the Revision of the Industrial Emissions Directive Association Ukrmetalurgprom represents the whole Ukrainian mining & steel industry and herewith would like to share its views as regards inception impact assessment re review of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We agree that the Directive has significant EU added value and the Seville process is an important tool and should continue. For IED to interact with decarbonization and contribute to circular economy a review of the Seville process could be sufficient. Many BREFs are neither reviewed nor implemented yet, so we don’t know the Directives full performance.

Entrepreneurship and business environment Heidi Lettojärvi 21.4.2020 1 (3) CONFEDERATION OF FINNISH INDUSTRIES (EK) contribution to the Inception Impact Assessment of the Revision of the Industrial Emission Directive Confederation of Finnish Industries (EK) is the leading business organization in Finland. Our main task is to make Finland an internationally attractive and competitive business environment.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Cefic, the voice of the European chemical industry is strongly committed to contribute its proposals to support the review of the IED-Sevilla process. Cefic already supported the evaluation of the IED in 2018/19 and endorsed its members to provide broad response to the public consultation (PC) and the Targeted Stakeholder Survey (TS).

The key policy objectives when opening a reflection on the Industrial Emission Directive 2010/75/EU should be: creating conducive conditions among Member States in support of the competitiveness of the industrial sectors in the EU, with a view to improving the citizen’s quality of life, including by maintaining and enhancing the EU environmental protection levels.

Danish Aquaculture strongly recommends that the revised Industrial Emissions Directive (IED) does not include aquaculture. The Organization Danish Aquaculture fully supports the objectives and means of the European Green Deal.

Input to Inception Impact Assessment for the revision of the Industrial Emissions Directive (IED) 1. Summary Bankwatch Romania welcomes the findings of the European Commission that a review of the IED is necessary to improve delivery and effectiveness of its goals. The current goal is to achieve a high level of environmental protection from industrial activities, with priority to pollution prevention over control.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

IFA Aquaculture fully supports the objectives and means of the European Green Deal. Specifically by taking on and fostering the new growth strategies built in both the Farm to Fork Strategy and the Circular Economy Action Plan that aim to transform the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy where there are no net emissions of greenhouse gases in 2050 and…

ACEA welcomes the opportunity to provide comments to the Inception Impact Assessment for the revision of the Industrial Emission Directive (IED). As general comment ACEA would like to underline that, while the European Commission intends to modify the Directive, the IED has been just implemented and a lot of BREFs are not yet updated and did not entered into force yet.

CEOE COMMENTS: INCEPTION IMPACT ASSESSMENT ON THE “REVISION OF THE INDUSTRIAL EMISSIONS DIRECTIVE” 21 April 2020 Departamento de Industria, Energía, Medio Ambiente y Clima CEOE comments: revision of the industrial emissions directive (IED) 21 April 2020 CEOE comments: Inception impact assessment on the “revision of the industrial emissions directive” BACKGROUND The European Commission has opened a public…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Green Deal requires the Commission to review measures at the EU's disposal to reduce and control pollution generated by large industrial installations. One such tool is the Directive of the European Parliament and Council 2010/75/EU of 24 November 2010 (IED), which regulates the basic sectors of industry in terms of emissions from industrial installations.

The Industrial Minerals Association Europe (IMA-Europe) welcomes the opportunity to provide its feedback to the European Commission on the inception impact assessment, Directive 2010/75/EU. It is only through these assessments that directives such as the Industrial Emissions Directive (IED) can be designed fit-for-purpose.

Friends of the Earth Finland welcomes the findings of the European Commission that a review of the IED is necessary to improve delivery and effectiveness of its goals. The current goal is to achieve a high level of environmental protection from industrial activities, with priority to pollution prevention over control.

Changes of IED and BREF should always be assessed in terms of feasibility, cost effectiveness and manageability. The IED cannot and must not solve all issues raised during the IED Evaluation in 2019. Commission Implementing Decision (EU) 2017/302 (BAT) conclusions, under Directive 2010/75/EU of the European Parliament and of the Council, for the intensive rearing of poultry or pigs was published in February 2017 and…

RWE, Onyx and Vattenfall are electricity production companies with several locations in different European countries We welcome the opportunity to provide feedback to the European Commission’s publication of an inception impact assessment on the revision of the Industrial Emissions Directive (IED). On behalf of Vattenfall, ONYX and RWE NL, you will find the joint input in the attachment .

Dear Sir/Madam, we couldn't upload our comments as an attachment. There was constantly an information that "the attach a file filed is invalid". Therefore, as our comments exceed 4000 characters, we are sending the remarks as a link to our google disc. Should you have any difficulties opening it, please do not hesitate to contact us.

European Alliance to Save Energy on the Inception Impact Assessment on the Revision of the Industrial Emissions Directive European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the European Commission’s publication of an inception impact assessment on the revision of the Industrial Emissions Directive (IED).

Answer to the inception impact assessment (roadmap) on the Industrial Emissions Directive. The European Lime Association (EuLA) welcomes the opportunity to provide its feedback to the European Commission on the inception impact assessment, Directive 2010/75/EU. It is only through these assessments that directives such as the Industrial Emissions Directive (IED) can be designed fit-for-purpose.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ThyssenKrupp Steel Europe AG is a subsidiary of thyssenkrupp AG and one of the world’s leading suppliers of carbon steel flat products. With around 27.000 employees we supply high-quality steel products for innovative and demanding applications. With an annual production volume of approximately 12 million metric tons of crude steel, we are Germany’s largest flat steel producer.

Filed in German · English published by the European Commission

The IED’s main purpose is to set environmental protection standards for the industry and provide a framework for industrial operations to meet the identified best available techniques. Euroheat & Power (EHP), representing the District Heating and Cooling (DHC) sector in Europe and beyond, support the ambition to achieve a high level of environmental protection.

Overall, the roadmap addresses the most important overall issues like circular economy, better BREF process and implementation issues. Below we have listed elements that we think needs to be taken into consideration in the assessment. BREF process In the work on the BREF process we would like to have more focus in innovation. The current approach is too focused on end-of-pipe solutions.

EUTurbines, the European Association of Gas and Steam Turbine Manufacturers, acknowledges and supports the important role of the Industrial Emission Directive (IED) to reduce pollution from industrial activities. Its application has strengthened the development and deployment of improved techniques to prevent and control environmental impacts from industrial installations.

The Federation of European Aquaculture Producers (FEAP) fully supports the objectives and means of the European Green Deal. Specifically by taking on and fostering the new growth strategies built in both the Farm to Fork Strategy and the Circular Economy Action Plan that aim to transform the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy where there are no net…

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on inception impact assessment (IIA) of the Revision of the Industrial Emissions Directive (IED). AHD CR has actively participated in the elaboration process of the Large Combustion Plants BREF, the Waste Treatment BREF and the Waste Incineration BREF within the framework of the IED.

KGHM Polska Miedź S.A. welcomes the opportunity to provide its initial comments on the Industrial Emissions Directive Inception Impact Assessment (IIA). Please find our position in the attached document. We will continue to provide further input at the later stage of consultation process.

Gas Networks Ireland (GNI) and its parent company Ervia, welcomes the opportunity to respond to the European Commission’s (EC) proposal for a directive on Industrial Emissions-EU rules updated. GNI acknowledges that this initiative would update rules on industrial emissions to ensure industry keeps improving the EU’s environment and it aims to ensure industry uses techniques that create a more sustainable EU…

ESPP supports the suggested widening of the IED scope to cover intensive cattle farms and aquaculture, in coherence with the inclusion today of large pig and poultry farms. ESPP supports that the IED process should better take into account EU Circular Economy objectives.

The Hungarian Aquaculture and Fisheries Inter-branch Organization welcomes the European Green Deal and fully supports its goals. However the organization would like to draw the attention several facts regarding the revision of the Industrial Emissions Directive. The Hungarian aquaculture production based on pond farming; it covers a decisive part (81%) of the total production.

Feedback 1 (2) 20 April 2020 Finnish forest industry feedback - Public consultation on the Inception Impact Assessment for the Industrial Emissions Directive The Industrial Emissions Directive (IED) and sector-specific BAT conclusions have resulted in a considerable reduction of industrial emissions. Emissions have been reduced greatly even before the directive was adopted.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Considering the goals of the Green Deal, it's a shame that IED doesn't address the climate crisis directly. The regulation of GHG emissions is left to the ETS Directive, but at the same time more than 90% of industrial greenhouse gas emissions are covered by free ETS emissions allowances, so that Directive provides almost no incentive to energy-intensive industries to decarbonize.

In 2019 Commission President von der Leyen announced the European Green Deal to transform the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy where there are no net emissions of greenhouse gases in 2050 and where economic growth is decoupled from resource use.

Summary: The EEB welcomes the findings of the European Commission that a review of the IED is necessary to improve delivery and effectiveness with respect to its goals. The current goal is to achieve a high general level of environmental protection from industrial activities, with priority to pollution prevention over control.

The Spanish Association of Fish Farmers (APROMAR) fully supports the objectives and means of the European Green Deal. Specifically by taking on and fostering the new growth strategies built in both the Farm to Fork Strategy and the Circular Economy Action Plan that aim to transform the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy where there are no net emissions of…

European Aluminium, the trade association representing the full aluminium supply chain, welcomes the opportunity to comment on the Inception Impact Assessment of the Industrial Emissions Directive. Please find enclosed our preliminary response gathering the views from the aluminium industry.

Cepi would like to share the following feedback on the IED inception impact assessment: IED was able to deliver on its main objectives (emissions reduction); European pulp and paper sector has reduced considerably its emissions to the environment in the last decades.

The EiiF strongly supports the initiative to update EU rules on industrial emissions. We encourage this initiative in its aim to ensure industry uses techniques that create a more sustainable EU economy, and a cleaner environment that improves public health.

Feedback to the Inception Impact Assessment (IIA) of the Revision of the IED published by DG ENV on 26 March 2020 The IIA refers to an evaluation of IED according to which in the following areas the operation of the legislative framework might be improved: 1) There may be sectors outside the IED scope that cause high pollution and for which the IED could be an appropriate policy instrument 2) Comparability of Member…

FEEDBACK Inception impact assessment - Ares(2020)1738021 Revision of the Industrial Emissions Directive WSM Wirtschaftsverband Stahl- und Metallverarbeitung e.V. (German Steel and Metal Processing Industry Association), representing the German steel and metal processing industry towards politics and economy, would like to take this opportunity to express serious concerns regarding the ongoing activities of the EU…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Industrial Emission Directive 2010/75 has demonstrated efficiency to provide an EU framework to “reduce emissions into air, water and land and to prevent the generation of waste, in order to achieve a high level of protection of the environment taken as a whole”. As an active partner since the beginning in the valuable Sevilla process - including IED article 13 Forum, HWE is familiar with the IED directive.

BACKGROUND UEPG, the European Aggregates Association represents the largest non-energy extractive industry in Europe with members in 23 countries. Aggregates are sand, gravel, crushed rock, marine aggregates as well as secondary raw materials, such as recycled and manufactured aggregates. They are used to build Europe’s essential infrastructure including homes, roads, railways, schools, hospitals or dams.

Glass Alliance Europe (GAE) welcomes this opportunity to comment the inception impact assessment on the Industrial Emission Directive (IED) review and would like to highlight two elements that should be taken into account at the time of the impact assessment.

Industrial Emissions Directive (IED) inception impact assessment – EUROFER response (box) Due to the COVID-19 pandemic, many steel operators cannot effectively contribute to Commission activities or are simply not available. Therefore, this contribution cannot comprehensively reflect the full view of the sector.

API (Associazione Piscicoltori Italiani - Italian Fish Farmers Association) fully supports the objectives and means of the European Green Deal. Specifically by taking on and fostering the new growth strategies built in both the Farm to Fork Strategy and the Circular Economy Action Plan that aim to transform the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy where…

The European Foundry Industry Association CAEF highly welcomes the opportunity to comment the Inception Impact Assessment on the Industrial Emission Directive (IED) review. Regrettably, the feedback period doesn’t consider at all the current situation given by the Covid-19 pandemic. Thus, any assessment of legislative proposals is only possible to a very limited extend.

We agree to the conclusion that the Directive has significant EU added value and the Seville process is an important tool and should continue. For IED to interact with decarbonization and contribute to circular economy a review of the Seville process could be sufficient. Many BREFs are neither reviewed nor implemented yet, so we don’t know the Directives full performance.

Brussels, 17 April 2020 Revision of the Industrial Emissions Directive Cerame-Unie’s feedback to the inception impact assessment Cerame-Unie, the European Ceramic Industry Association, welcomes the start of the Impact Assessment on the revision of the Directive 2010/75/EU on Industrial Emissions (IED), with an inception impact assessment.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PTBA Contribution The Polish Trout Breeders Association (PTBA) fully supports the objectives and means of the European Green Deal. Specifically by taking on and fostering the new growth strategies built in both the Farm to Fork Strategy and the Circular Economy Action Plan that aim to transform the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy where there are no net…

20.04.2020 CEMBUREAU’s feedback to the Industrial Emissions EU rules update CEMBUREAU, the European Cement Association (www.cembureau.eu), takes note of the Inception Impact Assessment and the opportunity to provide feedback to the industrial emissions rules update.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Sir/Madam, there are more than 1 500 plants operating in Bavaria, which are listed in Annex 1 to the IED. These are monitored on a risk-based basis in accordance with the provisions of the IED. The outcome of the review will be published on the internet at the level of the 105 competent surveillance authorities close to the citizen.

Filed in German · English published by the European Commission

Initial comments consultation on on the the European Roadmap Commission “Revision of the public Industrial Emissions Directive” (Inception impact assessment). April 20, 2020 THE BREF (Seville) PROCESS: It is a robust procedure that allows the participation of stakeholders to establish the Best Available Techniques.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Federal Association of the German Glass Industry (Bundesverband Glasindustrie, BV Glas) welcomes this opportunity to comment the inception impact assessment on the Industrial Emission Directive (IED) review. In our view, the consultation comes at an inappropriate time: Firstly, the COVID-19-pandemic is currently the dominant topic and consultations should therefore be postponed.

MAGES believes that the IED and the BREFs are delivering environmental performance across Europe because their approach is flexible, focuses on continuous improvements and addresses local environmental issues holistically. MAGES has identified several aspects to be considered in the IED revision process:  The Seville process must be limited to the control of the relevant industrial emissions.

The iron and steel industry in Germany supports the efforts of the Commission to achieve a higher level of air quality and reduce negative impacts on, and risks to human health and the environment. With this intention the iron and steel industry in Germany promotes the Industrial Emission Directive (IED) which provides ambitious and notably explicit rules on permitting, operating and decommissioning of industrial…

The Industrial Emissions Directive represents one of the most relevant pieces of legislation for the industrial sector, regulating the core of its activity, the permit setting process, best available techniques and binding associated emission levels.

•There is a significant EU added value elaborating sector BREF in the Seville process. An improved Seville process will be able to both contribute to circular economy and to interact with decarbonization of industry and major changes in IED may not be necessary.

EUROMOT welcomes the Commission’s initiative to consult stakeholders on the IED revision process. We have been active in past LCP BREF 2017 and IED consultation processes. In the paragraphs below we provide our response to some specific sections of the Commission’s inception impact assessment on the IED review. 1. Section A Quote “The European Green Deal commits the Commission to review ...

Input to Inception Impact Assessment for the revision of the Industrial Emissions Directive (IED) 1. Summary Frank Bold Society, z.s., welcomes the findings of the European Commission that a review of the IED is necessary to improve delivery and effectiveness of its goals.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Polish Steel Association(HIPH) shares the joint position of the European steel sector. Due to the COVID-19 pandemic, many steel operators cannot effectively contribute to Commission activities or are simply not available. Therefore, this contribution cannot comprehensively reflect the full view of the sector.

As the recognized representative of the European mineral raw materials industry covering more than 42 different metals and minerals and employing 350.000 directly and about four times as many indirectly, Euromines welcomes a European Green Deal to put Europe on the right track to a sustainable future and is prepared to take the necessary measures to make it the world's first climate neutral continent.

The European Insulation Manufacturers Association (Eurima) welcomes the Commission’s intention to improve the design and implementation of the Industrial Emissions Directive (IED) in order to prevent, reduce and eliminate as far as possible pollution arising from industrial activities.

The IED and within the BREF process is a commonly accepted and effective instrument to reduce the emissions from major industrial installations. Changes of this system should always be assessed in terms of feasibility, cost effectiveness and manageability. The IED cannot and must not solve all issues raised during the IED Evaluation Workshop in May 2019.

ZWE recommends revising the IED to ensure that waste incineration and co-incineration plants respect the same total emissions levels. Current legislation sets higher emissions ceilings for cement plants co-incinerating waste than those for dedicated waste incinerators.

The successive policies applied in the EU to prevent pollutants emissions from the production of energy in large combustion plants have demonstrated to be significantly successful. According to the EEA data, the EU Public electricity and heat production reduced SO2 emissions by 65% over the period 2000-2010, mostly due to the IPPC directive.

BDI position paper Review of IED In the view of the BDI, there is currently no need to amend the EU directive on industrial emissions. The objectives of the directive - improving environmental quality and creating a level playing field - are being achieved.

Contribution to the EU-Commission's consultation of the Inception Impact Assessment of the Industrial Emmission Directive From Confederation of Danish Industry, we find that the directive works well i the context it was agreed upon by the European Parliament and the Council. Since 2010 the discussion on environmental regulation in Europe has changed it focus.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eesti Põllumajandus-Kaubanduskoda, Pärnu mnt 141 Tallinn 11314, tel 600 9349, [email removed] Arvamuse avaldamine tööstusheitmete direktiivi (IED) ülevaatamise teekaardi kohta Eesti Põllumajandus-Kaubanduskoda (EPKK) tervitab Euroopa Komisjoni algatust viia läbi Euroopa Parlamendi ja nõukogu direktiivi 2010/75/EL, tööstusheitemete kohta (IED) mõjuanalüüs.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

• Estonia finds that the lessons learned from the Covid-19 crisis should be considered when impact assessment is carried out. After the crisis, we have to rebuild our economy and doing so, we have to keep in mind our climate and environmental goals. • In general Estonia considers that the IED largely serves its purpose and we do not wish to have significant changes into the directive at this moment.

Nádech z.s. welcomes the findings of the European Commission that a review of the IED is necessary to improve delivery and effectiveness of its goals. The current goal is to achieve a high level of environmental protection from industrial activities, with priority to pollution prevention over control.

FoodDrinkEurope feedback to European Commission Inception Impact Assessment on the Revision of the Industrial Emissions Directive FoodDrinkEurope has cooperated with the European Commission in the 2019 Evaluation of the IED.

The proposed objectives and policy options (section B) can be clearly divided into two main areas: (a) Fixing issues that have been identified with the current process e.g. improvement to the BREF process, addressing areas of weakness, coherence with other EU legislation. (b) Broadening the scope of the IED e.g. new sectors, circular economy, decarbonisation.

CEWEP feedback to inception impact assessment on 2030 Climate Target Plan CEWEP welcomes the willingness of the EU to become climate neutral by 2050, having in mind that such an ambitious target would require for legislators to make evidence-based decisions, in all sectors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EUROPEAN COMMISSION PUBLIC CONSULTATION PROPOSAL FOR A DIRECTIVE – INDUSTRIAL EMISSIONS FEEDBACK PERIOD: 24 MARCH 2020 – 21 APRIL 2020 HSE GROUP’S VIEW DATE: 15 APRIL 2020 HSE Group participated in the first public consultation regarding the necessity to revise the Directive 2010/75/EU on industrial emissions (IED Directive) in 2019.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)