The aim of the revision is to describe bindingly applied technologies, taking into account the cost-benefit ratio, with which a generally high level of environmental protection can currently be achieved most effectively and which can be verified by the competent authorities. The BREF STM defines the future limit values for emissions to air and wastewater for both the German and the European surface treatment industry.
As early as 2021, national expert groups ((E)NEG) - in Germany under the leadership of the Federal Environment Agency (UBA) and with the active participation of the VOA - and the Technical Working Group at European level formulated the "Initial Positions" and a questionnaire for the numerous, differently positioned EU companies. The survey completed in 2023 forms the basis for the development of the BREF-STM, which consists of two parts - the fact sheet and the Best Available Technique Conclusion (BAT Conclusion), which contains the relevant requirements.
Green Deal as a catalyst
The EU's European Green Deal is bringing the BREF process more into the focus of plant-related environmental protection. In future, the data collected from VOA member companies will be used to derive emission values that are binding throughout Europe.
The VOA is involved in the ENEG, has sent a representative to the Technical Working Group and maintains contact with important political decision-makers, including at European level. In recent months, the aim has been to collect realistic and comprehensible plant data from VOA member companies on the basis of the complex questionnaire and enter it into the data pool. It became apparent that not only German companies, but also the individual EU countries have different procedures and in some cases different measured values are collected.
In addition, some companies simply do not have the technical equipment required to collect the data. In Germany, data on the heavy metal load in wastewater in kg/h is also unusual and is not measured; the same applies to odor emissions. In addition, to calculate the removal efficiency required for each air pollutant, the pollutant concentrations would also have to be recorded in the raw gas. However, measurements are only taken in the clean gas, as this is where the limit values to be complied with apply.
Based on the data collected from plants across Europe, the EIPPC office now needs to establish sound data that can be implemented by plant operators and verified by the approval authorities. The publication of the new BREF STM scheduled for fall 2026 is likely to be delayed by a few months, according to the VOA.
How does the update process work and who is involved?
In the run-up to a BREF revision, which is due every ten years, the industry experts at the Federal Environment Agency (UBA) set up the (Extended) National Expert Groups ((E)NEG) and the so-called "Seville Process" begins. The NEG, the national committee for the revision, is made up of representatives from the authorities, while the ENEG also involves experts from industry, science and associations. The group meets at regular intervals and discusses the current status, upcoming work and possible positions on the individual steps in the process.
The requirements contained in the BAT reference documents are binding in all EU member states. They apply to new installations immediately after publication and to existing installations after four years at the latest.
Sandra Leuthold, responsible for the STM BREF at the UBA, says of the revision: "The industry associations such as the VOA play an important role in supporting the 'Seville process' at national level, as they form the interface with the companies that provide their data for the derivation of future emission values by completing the extremely complex questionnaire. The associations also coordinate the comments on the individual papers. I am very pleased about the active participation, as this is the only way we can develop good positions."
Further information can be found at www.umweltbundesamt.de.