Brussels, 12 April 2024
Primary Food Processors (PFP) welcome the formal adoption of the revised Industrial Emissions Directive (IED) legislative text by the Economic and Financial Affairs Council while highlighting several important considerations regarding implementation and operational feasibility across the sector.
The organisation welcomes the compromise text revising Directive 2010/75/EU and particularly supports the commitment to ensuring equal access to data for all stakeholders participating in future revisions of Best Available Techniques Reference Documents (BREFs).
According to PFP, equal access to technical and operational information will contribute to greater transparency and more balanced participation throughout the development of future industrial emissions policies and technical standards.
At the same time, the organisation expresses concerns regarding the obligation for competent authorities to apply the strictest achievable emission limit values based on Best Available Techniques (BAT). PFP notes that primary food processing installations operate under highly diverse production conditions and that a one size fits all approach may not reflect operational realities across the sector.
PFP stresses that some installations could face significant challenges in achieving the most demanding emission levels and therefore emphasises the importance of considering the full BAT Associated Emission Level (BAT AEL) range during implementation.
The organisation also raises concerns regarding the introduction of binding Environmental Performance Limit Values (EPLVs) for water management. While environmental performance indicators relating to waste and other resources remain indicative, water related EPLVs will become binding requirements under the revised framework.
PFP argues that this approach creates an imbalance between environmental performance indicators and may introduce additional implementation challenges for operators across the sector.
The association calls for a balanced implementation of the revised Industrial Emissions Directive that supports both environmental objectives and industrial competitiveness. According to PFP, implementation should recognise operational diversity, allow realistic compliance pathways, encourage continuous dialogue between authorities and industry stakeholders, and ensure that environmental requirements remain technically achievable.
PFP confirms its commitment to continued engagement with policymakers, regulators and stakeholders throughout the implementation phase of the revised Directive.
PFP brings together the European Association of Sugar Manufacturers (CEFS), the European Cocoa Association (ECA), the European Flour Milling Association (European Flour Millers), the European Vegetable Protein Association (EUVEPRO), the European Vegetable Oil and Proteinmeal Industry (FEDIOL), and the European Starch Industry Association (Starch Europe).
