Brussels, 20 March 2023 • Ref. 23PFP006
The Primary Food Processors (PFP) association welcomes the general approach adopted by the Council regarding the revision of the Industrial Emissions Directive (2010/75/EU), reached during the Environmental Council meeting on 16 March 2023.
PFP considers the compromise agreement relatively balanced and particularly welcomes the Council’s decision not to support the European Commission proposal requiring the strictest possible Emission Limit Values across all installations. According to the organisation, such an approach would be impractical due to the diversity of industrial processes, operational conditions and circumstances across Member States.
The organisation nevertheless highlights two areas where concerns remain. These relate to the treatment of confidential business information under Article 13 and the proposed implementation of Environmental Performance Limit Values under Article 15.
PFP notes that confidential and commercially sensitive information often plays an important role in defining Best Available Techniques (BAT) and establishing BAT Associated Emission Levels. The organisation believes that such information should only be disclosed to the European Commission and competent national authorities that are legally bound by professional secrecy obligations.
According to PFP, commercially sensitive information should undergo aggregation and anonymisation procedures before being shared with third parties in order to minimise commercial risks and protect confidential business interests.
The association regrets that the Council did not reject the Commission proposal that would grant external actors broader access to information than industry representatives participating in Technical Working Groups involved in the Sevilla process.
PFP also expresses concerns regarding Environmental Performance Limit Values related to resource efficiency, water consumption, energy consumption and waste generation. The organisation argues that these indicators should not become legally binding obligations at EU level.
According to PFP, the European Union already has several regulatory frameworks addressing these environmental areas, creating a risk of overlap, duplication and inconsistent implementation requirements. The organisation therefore believes that decisions regarding Environmental Performance Limit Values should remain under the discretion of Member States and industrial operators.
To preserve the competitiveness of Europe’s primary food processing industries, PFP calls for concrete improvements to Articles 13 and 15 during the next stages of the legislative process. The organisation advocates stronger protection of confidential business information, greater safeguards for commercially sensitive data, and a more flexible approach to environmental performance indicators.
PFP remains committed to supporting environmental objectives while ensuring that industrial competitiveness, operational flexibility and regulatory coherence are maintained throughout the implementation of future environmental legislation.
PFP members process approximately 220 million tonnes of raw materials, including cereals, sugar beet, rapeseeds, soybeans, sunflower seeds, crude vegetable oils, cocoa products and starch potatoes, and employ more than 120,000 people across the European Union.
