Position Paper on the Revision of the Industrial Emissions Directive & Industrial Emissions Portal Regulation (IED & IEP)

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Maintain the core principles of the Industrial Emissions Directive

  • The current Industrial Emissions Directive (IED) framework is fit to enable the environmental transformation of European industries.
  • Eurelectric welcomes the preservation of its core principles and definitions. For instance, its integrated approach, the definitions of Best Available Techniques (BAT) and the Sevilla process.

Streamline the permit process and keep flexibility under current BAT-AELs ranges for site-specific reasons

  • The revision of the directive should consider setting a fixed processing time to ensure that competent authorities deliver a revised permit within a given timeframe, as lengthy permitting processes can be detrimental to investment decisions.
  • Setting all permit conditions at the lowest end of the BAT-Associated Emission Levels (BAT-AEL) range is technically and economically unattainable for most industrial installations. Thus, imposing a disproportionate administrative burden on plant operators. The current approach allowing the full range of BAT-AEL and the possibility to derogate from them, if properly justified, should be maintained. For instance, existing thermal installations close to the end of their lifecycle currently operated solely to balance the intermittent generation of variable renewable energy sources and decrease the load factor.

Respect the scope of EU law and avoid overburdening the IED

  • Eurelectric is concerned that empowering the Commission to adopt delegated acts to further extend the sectoral scope of the Directive may affect the functioning of the Sevilla process and undermine plant operators’ legal certainty. Any adjustment to the scope of the directive, in terms of sectors covered, should be scientifically sound.
  • New provisions included in Article 14a on Environmental Management Systems (EMS) and Article 79a on penalties are unwise and risk creating legal uncertainty.

Supporting emissions reduction while avoiding double regulation

  • Eurelectric welcomes the proposed flexibilities to test new emerging techniques.
  • The revision shall minimise overlap with existing regulations on decarbonisation and reporting requirements (e.g. the Corporate Sustainability Reporting Directive and EU Emissions Trading System) and ensure a coherent across policies. For instance: Medium Combustion Plants (MCP) between 20-50 MWth should not be included in the scope of the Industrial Emissions Portal (IEP) Regulation as combustion plants of a least 20 MWth are already covered by the MCP Directive.


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