Proposal for a Directive of the European Parliament and of the Council on industrial emissions (Integrated Pollution Prevention and Control) (Recast) COM (2007) 844 final

The European Parliament voted in its first reading the 10th of March 2009 on the Industrial Emission Directive – recast of the current IPPC directive. This proposal aims at regulating emissions and pollutants in the EU through the use of permits granting to single operators.

Although we share and understand the environmental objectives of such a proposal, the variety of industry involved under this Directive (from metal and small surface treatment to large combustion plants, from textiles to refineries) calls for a balanced approach that would benefit not only industry and its competitiveness but also protection of environment and human health.

We are in particular very concerned to see that the proposal strongly reinforces the requirements and burdens placed on the manufacturing sector in a way that is neither proportionate, nor takes any account of the economic reality that our industry which employs over 11 million people and whose member companies are for the most part SMEs (>90%) includes faces today. We believe that it is time that regulators take due account of the impact that progressively more stringent and ever changing regulation is having on our companies, if they want the EU to remain an attractive base for our industry. Our companies today need to be able to focus their investment on keeping their skilled personnel for the time when the economic recovery arrives.

We therefore very much hope that the Council will see fit to take account of our comments.