ZVO position paper on BREF documents published

With the amendment of the Industrial Emissions Directive, the downstream BREF documents are coming even more into focus. They are one of the central levers for approvals, investment decisions and the daily operating practice of ZVO member companies. Against this background, the ZVO has published a comprehensive position and criticism paper on the new BREF guideline. The ZVO sees a clear paradigm shift in the current BREF Guideline: away from technology-related requirements and towards quantitative environmental performance parameters (AEPLs) and comprehensive management specifications. This approach is understandable in principle, but often falls short in practice.

ZVO sees urgent need for action on BREF guideline

The association is particularly critical of the lack of a reliable methodology for deriving the AEPLs, the lack of operationalization of the "applicability" of techniques and the threat of legal uncertainty in approval procedures. In addition, there are high and sometimes unrealistic data requirements, which can put small and medium-sized companies in particular at a structural disadvantage. From the ZVO's point of view, there is an urgent need for action in order to meet the demand for uniform, fair and practical enforcement throughout Europe. Among other things, clear assessment standards, transparent criteria for data quality and instruments for resolving conflicting objectives in environmental management are required. The full position paper with a detailed analysis and specific political demands can be downloaded from the ZVO website.