Combating climate change: New IED and ETS interactions required

The document argues that the EU's current legal framework, which excludes installations under the Emissions Trading System (ETS) from certain Industrial Emissions Directive (IED) requirements, is insufficient to meet the goals of the Paris Agreement and the European Green Deal. ClientEarth contends that the ETS alone cannot drive full decarbonisation because it lacks a focus on prevention technologies and allows for the displacement of pollution. The brief proposes a synergetic approach where the IED provides mandatory, scientifically-based greenhouse gas (GHG) emission limit values (ELVs) and energy efficiency standards based on Best Available Techniques (BAT). This would align EU policy with the 'prevention principle' and the 'Hierarchy of action on pollution', ensuring that emissions are avoided by design rather than just traded. The author concludes that deleting Art. 9 IED and Art. 26 ETSD would create a 'win-win-win' for operators, the climate, and the environment by stimulating technological innovation and ensuring a level playing field.

• The current interaction between the IED and ETSD hinders industrial decarbonisation because GHG emission limit values and binding energy efficiency standards are excluded for installations covered by the ETS.
• The EU ETS is insufficient as a standalone tool for climate goals because it does not prioritise the technical prevention of emissions and creates risks of pollution displacement or industrial 'lock-in'.
• A revised IED could offer a more systematic response to climate change due to its broad scope, which covers the EU's largest GHG emitters, and its integrated approach to air, water, and soil pollution.
• The IED's focus on Best Available Techniques (BAT) can drive innovation in decarbonisation, as seen in the iron and steel sector where pollution abatement for SO2 and NOx coincided with CO2 reductions.
• The proposed 'Hierarchy of action on pollution' prioritises prevention 'by design and during production' over the 'minimise & control' approach used by the ETS cap-and-trade system.
• Integrating the IED and ETS would align with the 'Energy Efficiency First' principle, which prioritises efficiency investments over new energy infrastructure.

APA

Bartolucci, B. (2021). Combating climate change: New IED and ETS interactions required. ClientEarth. https://www.clientearth.org/media/mleppyf1/clientearth_combating-climate-change_new-ied-and-ets-interactions-required_march-2021.pdf

Chicago

Bartolucci, Bellinda. Combating climate change: New IED and ETS interactions required. ClientEarth, 2021. https://www.clientearth.org/media/mleppyf1/clientearth_combating-climate-change_new-ied-and-ets-interactions-required_march-2021.pdf.

Wikipedia

{{cite report |last1=Bartolucci |first1=Bellinda |title=Combating climate change: New IED and ETS interactions required |publisher=ClientEarth |date=March 2021 |url=https://www.clientearth.org/media/mleppyf1/clientearth_combating-climate-change_new-ied-and-ets-interactions-required_march-2021.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{bartolucci2021combating, author = {Bartolucci, Bellinda}, title = {{Combating climate change: New IED and ETS interactions required}}, institution = {ClientEarth}, year = {2021}, month = mar, url = {https://www.clientearth.org/media/mleppyf1/clientearth_combating-climate-change_new-ied-and-ets-interactions-required_march-2021.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }