The ZVO has already reported several times on the new version of the Industrial Emissions Directive (IED). Its implementation, the BREF documents, are directly affected, which affects surface technology first. This is because the STM BREF (Surface Treatment of Metals and Plastics) is currently being revised. This means that the earlier specifications for the development overlap with the new requirements of the IED, particularly in Article 15. The significance of the data developed and, above all, its interpretation in the BAT (Best Available Techniques) conclusions will have a much greater impact.
Reliable statements require sufficient data
As the ZVO is well informed about the status via the CETS, doubts have arisen as to whether the progress of the revision to date is suitable for generating sufficient data to be able to draw reliable conclusions. This primarily concerns the comparability of systems and installations with regard to emissions and consumption values or environmental performance indicators.
Possible consequences and improvements were discussed in talks with CDU/CSU and SPD MPs. Above all, it was recognized that a process whose basis has been changed should not simply be continued. A moratorium would be desirable.
Both representatives promised further support. Germany should take a clear position and insist on a robust, meaningful process for the creation of future BREFs.