IOGP input to the consultation on the Industrial Emissions Directive

This document provides IOGP’s input to the EU public consultation (questionnaire) on the Industrial Emissions Directive (IED) and an accompanying written submission with further observation and key messages.



This initiative would update EU rules on industrial emissions.

The initiative supports the zero pollution ambition under the European Green Deal, as well as the EU’s policies on energy, climate and the circular economy.


Key Points

IOGP proposes the following suggestions to be taken into account when revising IED:

  • A thorough cost-benefit analysis and comprehensive impact assessment taking into account all environmental pressures
  • The Medium Combustion Plant Directive (MCPD) is functioning well, limiting environmental impact sufficiently, so there is no direct need for lowering the 50 MW IED threshold
  • The EU ETS should remain the main instrument to drive the reduction of GHG emissions
  • It is important to maintain the specific derogations secured by IED Article 15, which are subject to scrutinized justification and monitoring by the competent authorities
  • Imposing BATs and breakthrough technologies that have not been commercially proven would create considerable challenges and uncertainties that are not compatible with investment planning
  • Sufficient public participation is already achieved through the Åarhus Convention on access to information, public participation in decision-making and access to justice in environmental matters, and through Article 24 of the IED



  • Introduction
  • Executive Summary
  • IED scope extension
    • Upstream oil and gas contribution to pollution prevention
    • Upstream oil and gas activities are already well covered by the existing legislation and industry standards
    • Extending the production capacity thresholds (MCPD thresholds under LCP)
    • Decarbonization instruments
  • Other outstanding issues
    • Derogation (IED Art.15.4)
    • Emerging techniques and breakthrough technologies
    • Participation of public
  • Conclusions

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