The proposed revision of the Industrial Emissions Directive (IED), presented by the European Commission on April 5 this year, needs to reflect the actual reality for companies. Some of the proposed changes, such as the reduction of emission limit values, the unilateral introduction of performance values, or the significant increase in substances to be controlled, pose a severe risk of increased bureaucracy and administrative costs for both companies and authorities, at a time that work should be underway to simplify and accelerate the procedures for authorising investment projects in the EU.
These additional delays in licensing are concerning for several reasons, and to the extent that they will occur at a critical moment for the implementation of decarbonisation projects or other projects that are essential to the achievement of the Green Deal and European reindustrialisation goals in companies.
In parallel, the unpredictability of the rules and requirements, which will only be fully known in 2028 (e.g., requirements of the transformation plan to be included in EMSs), is unfavourable to the intensification of investment that will be essential for these purposes. See CIP’s full comments on this proposal here.