Summary
As suggested by DG ENV in the Art 13 Forum workshop on June 12, 2020, Cefic shares its views on the next BREF (Best Available Techniques reference documents) review cycle. Cefic advises against introducing intermediate BREF reviews between review cycles, suggesting instead a full review to avoid inconsistencies. The association highlights issues of planning security, as frequent changes are not in line with long-term investment cycles. Additionally, Cefic raises concerns on the addition of more chemicals to the Key Environmental Issues (KEIs) list due to data collection and monitoring challenges, emphasising the need for practical and manageable approaches. Finally, Cefic stresses the complexity of the current BREF landscape and suggests that it would be more effective to finalise reviews before starting on others.
Concrete Takeaways:
- Cefic raises concerns about intermediate BREF reviews and supports whole reviews to avoid inconsistencies and planning issues.
- Monitoring and data collection must be practical, feasible, and prioritise real data over literature research.
- The BREF landscape is already complex; reviewing OFC/SIC/POL BREFs before finalising WGC BREF would lead to confusion and operational challenges.