Revision of the Industrial Emissions Directive – Targeted Stakeholder Survey

ClientEarth argues that the IED revision must shift from a static, activity-based approach to one that promotes the industrial activity with the least environmental impact for a given service. The organization advocates for expanding the IED's scope to include mining, upstream oil and gas, and aquaculture, while making greenhouse gas (GHG) emission limit values and energy efficiency standards binding, even for installations covered by the EU ETS. Key recommendations include restricting Article 15(4) derogations to a maximum of 48 months, introducing a right to compensation for victims of pollution, and strengthening Aarhus Convention rights through periodic permit renewals every four years and mandatory public participation for all permit updates.

• ClientEarth proposes redefining 'industrial activities' to encompass all activities producing a public good or service, prioritizing those with the lowest environmental impact, and expanding the IED scope to include mining, upstream oil and gas extraction, and aquaculture.
• The organization argues that the IED should include scientifically-based GHG emission limit values and binding energy efficiency requirements, necessitating the deletion of Article 9 exemptions for plants regulated by the EU ETS.
• ClientEarth recommends a fundamental overhaul of Article 15(4) derogations, suggesting they be deleted entirely or restricted to a maximum duration of 4 years (48 months) without the possibility of prolongation.
• To ensure a high level of environmental protection, ClientEarth advocates that emission limit values (ELVs) in permits should be set at the lowest limit of the BAT-AEL range by default, treating any higher value as a derogation.
• The document proposes introducing a mandatory periodic renewal of IED permits every four years to prevent 'lifelong' permits and ensure regular public participation and technological updates.
• ClientEarth suggests a new legal right to compensation for individuals suffering material or non-material damage from IED permit breaches, including a rebuttable presumption of harm if prima facie evidence is provided.
• The organization calls for the establishment of a centralized, EU-wide IED register with open-access, real-time emission data to improve transparency and public oversight.
• ClientEarth argues that the IED should be replaced by a Regulation to ensure clearer, more precise, and unconditional obligations across Member States, reducing the current 'patchwork' of implementation.
• The document highlights failures in Bulgaria, where coal power plants were granted indefinite derogations for SO2 and mercury with emission limits significantly higher than BAT-AEL ranges.
• ClientEarth identifies a lack of enforcement in Romania, where operating without an IED permit can result in lower fines than breaching the conditions of an existing permit.

APA

ClientEarth (2021). Revision of the Industrial Emissions Directive – Targeted Stakeholder Survey. https://www.clientearth.org/media/of0p2ull/clientearth_ied-revision_response-to-targeted-stakeholder-survey_april2021.pdf

Chicago

ClientEarth. Revision of the Industrial Emissions Directive – Targeted Stakeholder Survey. 2021. https://www.clientearth.org/media/of0p2ull/clientearth_ied-revision_response-to-targeted-stakeholder-survey_april2021.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Revision of the Industrial Emissions Directive – Targeted Stakeholder Survey |date=April 2021 |url=https://www.clientearth.org/media/of0p2ull/clientearth_ied-revision_response-to-targeted-stakeholder-survey_april2021.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2021revision, author = {{ClientEarth}}, title = {{Revision of the Industrial Emissions Directive – Targeted Stakeholder Survey}}, publisher = {ClientEarth}, year = {2021}, month = apr, url = {https://www.clientearth.org/media/of0p2ull/clientearth_ied-revision_response-to-targeted-stakeholder-survey_april2021.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }