With the call for the re-activ­a­tion of the Tech­nical Work­ing Group (TWG) in July 2018, the revi­sion of the BREF (Best Avail­able Tech­niques Ref­er­ence Doc­u­ment) for the Smither­ies and Foundries was launched. The TWG is the cru­cial panel in the BREF review pro­cess. In order to rep­res­ent the interests of the European foundries in this revi­sion adequately, the European Foundry Asso­ci­ation (CAEF) par­ti­cip­ates in the TWG with 17 mem­bers. Fur­ther­more, the TWG con­sists of del­eg­a­tions from the European Mem­ber States, the Industry, the EU Com­mis­sion as well as European Envir­on­mental Asso­ci­ations.

Against the back­ground of the long-last­ing pro­cesses dur­ing the past, the European Com­mis­sion has drawn up new guidelines to speed up the BREF review this time. Before the offi­cial Kick-off Meet­ing, cer­tain work is car­ried out within a so-called front-load­ing pro­ced­ure. Unlike the “Wish List” used in the past, in which the mem­bers of the TWG could for­mu­late their revi­sion requests related to the BREF con­tents, now “Ini­tial Pos­i­tions” are developed by the BREF authors and sub­mit­ted to the TWG for com­ment. These “Ini­tial Pos­i­tions” include pro­pos­als and requests for poten­tial adjust­ments to an exist­ing BREF; for example regard­ing the scope and struc­ture of the doc­u­ment, rel­ev­ant Key Envir­on­mental Issues (KEI) and organ­iz­a­tion of data col­lec­tion as well as poten­tial BAT can­did­ates.

From CAEF´s point of view, the SME struc­ture of the foundry industry has to be taken into account dur­ing the whole BREF revi­sion activ­it­ies. Thus, the European Foundry Asso­ci­ation wel­comes the more focused approach as required by the EU Com­mis­sion. Only pro­cesses and para­met­ers being def­in­itely of envir­on­mental rel­ev­ance should be object of the review. In par­tic­u­lar, some of the pro­posed KEI have been seen very crit­ical by the Foundry Industry.

So, CAEF does not con­sider require­ments for energy or mater­ial effi­ciency as being reas­on­able. Due to the huge vari­ety of applied mater­i­als, tech­no­lo­gies, pro­cesses and man­u­fac­tured products, the set­ting of cer­tain limit val­ues can never sat­isfy the indi­vidual con­di­tions of our com­pan­ies.

In March, the assessed items of the Ini­tial Pos­i­tions had to be sub­mit­ted to the Seville Bur­eau. They form the basis for the Kick-off Meet­ing sched­uled for Septem­ber 2019.

CAEF Con­tact:

Elke Radtke
phone: +49 211 68 71 — 290
elke.radtke@caef.eu

General Secretariat
CAEF - The European Foundry Association

Hansaallee 203
40549 Düsseldorf
Germany

tel: +49 (0)211 6871 217
fax: +49 (0)211 6871 40217
e-mail: info@caef.eu