CAN Europe’s position on the Commission’s Industrial Emissions Directive revision proposal

Around 50 000 large-scale industrial installations are covered by the Industrial Emissions Directive (IED), at the core of which lies an obligation for Member States’ authorities to prepare an environmental permit for a given industrial site, based on the sector’s best available techniques and upholding a holistic approach to pollution prevention. Industrial installations falling under the current IED scope account for 20% of the EU’s air emissions, 20% of emissions to water and 40% of the greenhouse gases emissions . The recent evaluation of the Directive showed that there was room for beefing up the requirements needed to bring forward the industrial transformation of those heavily polluting industries, underpinned by a more effective application of the “polluter pays” principle. A need for a more ambitious and solid framework driving down the emissions to air and addressing circularity and resource use was identified. The Industrial Emissions Directive has the potential to drive improvements in production processes, playing a central piece in the industrial transformation puzzle. To do so, it must be framed as one of the small number of industrial transformation pieces of legislation in a toolbox addressing: products (ecodesign of sustainable products regulation with knock on effects on other product-specific regulations, as well as the corporate sustainability legislations), processes (IED) and market mechanisms (EU ETS, CBAM, GPP). The IED revision comes in a timely manner to address resource overconsumption and restore regenerative patterns, when the global consumption of materials such as biomass, fossil fuels, metals and minerals is expected to double in the next 40 years and waste generation is expected to increase by 70% by 2050 . CAN Europe welcomes the awaited revision proposal and recognizes the effort to include much needed new aspects in the revised text, especially regarding circular economy and resource use. We however emphasize the lack of clarity on key elements that will truly deliver on the holistic value chain transformation of industry, rooting in resource preservation, health protection, inclusivity and regenerative patterns. We singled out four elements of the proposed revision that will enable a transformation of industry within the planetary boundaries, provided that the European Parliament and the Council step up the level of ambition from the Commission’s proposal. Those key elements are revolving around:

The inclusion of mandatory environmental performance levels in permits, ramping up the industry’s contribution to circular practices and lowering resource use (raw materials, energy, water) in production processes.
The existence of a precise and binding transformation pathway at plant level with interim milestones, end-goal and indicators compatible with EU overarching climate, zero pollution and circular economy targets.
The implementation of the polluter pays principle, achieved through emissions limit values at installation level for relevant pollutants.
An enhanced framework allowing civil society to better access information regarding industry environmental pollutions, with harmonized reporting throughout Member States, allowing comparison between sites.

Read full position paper here.