The revised Industrial Emissions Directive (IED) published on April 5, 2022 rightly aims to regulate pollutant emissions from industrial installations. All the installations covered by the directive have a requirement to comply with a permit helping to achieve the highest level of protection of human health and the environment.
Challenges remain, as the IED environmental permit licensing process can take a significant amount of time, and in the worst case slows down investment decisions. As we are preparing for a rapid green transition in line with the European Green Deal, IED permit process should be efficient and predictable. This would greatly facilitate environmental- and climate-friendly investments.
The directive focuses on industrial process at the manufacturing stage, and not on products. As has been stated by Commissions experts, the IED is not the ideal instrument to deliver circular economy objectives.
Circular economy approach should continue to be incentivised, such as reducing the quantities of waste sent for disposal from production and facilitating process residues use or process residues recycling. However, it should not become mandatory requirements under the IED permitting process.
Concerning the emission limits related to the protection of air and water, it is certainly important. We must ensure this will not lead to ineffective investments – investing in expensive technology and having a small impact on the state of the environment.
In general, overlaps and double regulation should be avoided following the Commission’s own Better Regulatory principle.