Draft legislation must be revised

In many respects, the draft legislation goes far beyond a one-to-one transposition of the EU Industrial Emissions Directive and will result in additional costs for operators. From the BDI’s perspective, the drafts therefore require significant revision.

Unbureaucratic implementation

When transposing the IED into German law, every effort should be made to ensure that the transposition is as streamlined as possible (one-to-one transposition) and unbureaucratic. In doing so, they should be guided by the principle of imposing as few additional burdens as possible on authorities and installation operators.

Offsetting of burdens necessary – further reduction of red tape required

Any additional bureaucratic burden on licensing authorities and plant operators resulting from the IED should be offset by measures to reduce the burden elsewhere. In parallel with the implementation of the IED, proposals for further reducing red tape and speeding up planning and authorisation procedures should also be put forward, adopted and implemented swiftly.

Transpose all exemptions into German law

The exemptions set out in the IED Directive should be fully transposed into German law. This applies in particular to water law. The draft legislation in this area needs to be improved. German companies must not be placed at a competitive disadvantage compared with companies in other European countries.

Do not allow the environmental management system to become a bureaucratic burden

The new environmental management system and its components should be allowed to be implemented in an unbureaucratic manner, utilising existing internal company processes and documentation. New requirements for a chemicals register (substance register, risk assessment and evaluation of alternatives) are already fully covered by the applicable provisions of national environmental, chemicals and occupational health and safety legislation. The draft for the new 45. BImSchV, for example, goes far beyond European requirements with regard to the risk assessment of hazardous substances and would create a significant amount of new red tape and financial burdens.