Invited by the EU Commission, CAEF participated in the so-called Targeted Stakeholder Survey (TSS) — a detailed consultation on the further development of the Industrial Emissions Directive (IED).
The IED is the backbone for the authorisation of industrial installations in the EU. In order to ensure the highest possible level of environmental protection in all Member States, industrial installations with significant environmentally relevant impacts must meet very demanding requirements. For foundries, as a predominantly SME sector, the requirements of the IED are already a challenge in most cases. Acting as a responsible and sustainable industry, we care about an intact environment. For this reason, many foundries are highly engaged in reducing their impacts on air, water and soil.
Although the IED has proven to fulfil its purpose of immission protection excellently, the EU Commission has decided to revise its rules and to add further requirements. These are to include, for example, the political requirements of the Green Deal — on decarbonisation and the circular economy, among others. While the latter could indeed be integrated into the IED, it makes little sense to include GHG Emissions. This is because IED aims to protect both human health and the environment around a facility, while GHG emissions are a global problem. Moreover, there is a very effective trading system existing for GHG allowances. We therefore explicitly oppose mixing-up a market-based instrument with regulatory rules.
Therefore, see the Joint statement with regard to the climate change related policy options considered in context of the Targeted Stakeholders Survey on the revision of the Industrial Emissions Directive: IED joint industry statement.pdf (722 downloads )