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.
We see a great opportunity in the enforcement of EU rules on industrial emissions, and we recommend the following suggestions for the IED’s revision:
1. The horizontal Energy Efficiency BREF must become mandatory (including SMEs). If not, industry will continue to consider it irrelevant and the EU goals will not be met.
2. The Energy Efficiency BREF must be updated and improved. Mandatory minimum requirements for insulation defined by maximum heat loss rates similar to the existing building insulation standards must be introduced and the structure and formatting must be corrected.
3. The duration of the general process for developing and reviewing BREFs is too long and too complex. We propose to change the BREF process to enable a duration of not more than one year, and a revision every 4 years.
We strongly encourage DG Environment on the revision of the Industrial Emissions Directive and we offer any support we can give to ensure industry uses the insulation BAT in its best way to create a more sustainable EU economy, and a cleaner environment that improves public health.
Furthermore, EiiF being part of the IED Article 13 Forum will take part in a planned workshop on the next BREF review cycle on 12 June and is currently preparing its feedback to a survey sent to all stakeholders of the Forum.