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 (66 downloads) 


General Secretariat
CAEF - The European Foundry Association

Hansaallee 203
40549 Düsseldorf

tel: +49 (0)211 6871 217
fax: +49 (0)211 6871 40217