Brussels, 20 March 2023
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. In particular, the organisation welcomes the Council’s decision not to support the European Commission’s proposal requiring the strictest possible Emission Limit Values, recognising that industrial processes and operational conditions vary significantly across sectors and Member States.
At the same time, PFP highlights two important areas where concerns remain. These relate to Article 13 on the handling of confidential business information within the Sevilla process and Article 15 on the implementation of environmental performance limit values.
According to the organisation, confidential and commercially sensitive information often plays an important role in defining Best Available Techniques (BAT) and establishing BAT Associated Emission Levels (AELs). PFP believes that such information should only be shared with the European Commission and national competent authorities that are legally bound by professional confidentiality obligations.
The association further argues that any information shared with external parties should first be aggregated and anonymised in order to reduce commercial sensitivity and protect confidential business data.
PFP regrets that the Council did not reject provisions that would grant external actors broader access to information than industry representatives participating in Technical Working Groups involved in the Sevilla process.
The organisation also expresses concerns regarding environmental performance limit values linked to resource efficiency, water consumption, energy consumption and waste generation. PFP believes these indicators should not become legally binding requirements.
According to the association, the European Union already has multiple legislative instruments addressing these environmental areas, creating a risk of overlapping obligations and regulatory inconsistencies. PFP therefore considers that decisions regarding such limits should remain under the discretion of Member States and operators.
To preserve the competitiveness of Europe’s primary food processing industries, PFP calls for further improvements to Articles 13 and 15 during the next stages of the legislative process.
The organisation remains committed to constructive engagement with European institutions and supports an Industrial Emissions Directive that achieves environmental objectives while maintaining industrial competitiveness and regulatory certainty.
PFP brings together the European Committee of Sugar Manufacturers (CEFS), the European Cocoa Association (ECA), the European Flour Milling Association (European Flour Millers), the European Starch Industry Association (Starch Europe), the European Vegetable Protein Association (EUVEPRO), and the European Vegetable Oil and Proteinmeal Industry (FEDIOL).
PFP members process approximately 220 million tonnes of raw materials, including cereals, sugar beet, rapeseeds, soybeans, sunflower seeds, crude vegetable oil, cocoa products and starch potatoes, employing more than 120,000 people across the European Union.
Official website: www.pfp-eu.org
