EuLA (2020) Position paper on IED – Roadmap

Answer to the inception impact assessment (roadmap) on the Industrial Emissions Directive.

The European Lime Association (EuLA) welcomes the opportunity to provide its feedback to the European Commission on the inception impact assessment, Directive 2010/75/EU. It is only through these assessments that directives such as the Industrial Emissions Directive (IED) can be designed fit-for-purpose. Therefore, it is a priority for the lime sector to engage in a constructive dialogue with policy makers to ensure its successful implementation and review.


Acknowledge and implement ‘Better regulation’ principles by avoiding overlap and duplication of regulation i.e. regulating GHG emissions through IED vs ETS.
A proposal to set ELVs for CO₂ could risk double-regulation and overlapping of policies between the ETS and the IED (ETS is a market-based instrument to tackle GHG emissions and IED as control and command to tackle other emissions). The current environmental objectives are addressed via the existing arsenal of regulatory measures (e.g. IED, WFD, AAQD, etc.) and the EU ETS Directive already covers the concept of performance benchmark. IED Art. 9.1 should be left intact.

The BREFs (and the IED process) must take cross-media effects into account, and consider cross-policy or wider (societal, economic, etc.) impacts.                                                                                                            Industrial emissions have reduced dramatically over the years and, whilst the lime sector will continue to work hard to minimise its environmental impact, the focus needs to incorporate other sectors, both in considering the direct impact of each sector and the combined effects of sector policies. Possible new thresholds set by the IED should be technically an economically feasible, not to impair the competitiveness of the European lime sector.

A systematic harmonized approach to derive the BAT‐AEL as a result of the BREF review process.
A robust and transparent approach will secure consistency for stakeholders throughout the BREF review process, as well as for regulators and operators at permitting level. It should be based on collected data for each technique and sector, and not through a simplistic statistical assessment, including contextual information, where only environmental performances are measured, omitting the technical and economic feasibility.