Promoting non-toxic material cycles in the preparation of Best Available Technique Reference Documents (BREFs)

The main instrument at the EU level to control industrial releases is the Industrial Emissions Directive (IED), particularly through the publication of BAT reference documents (BREFs) for industrial sectors, which include a BAT conclusions chapter setting a reference for permit conditions throughout the EU for IED installations. The EU action plan for the Circular Economy states that Circular Economy in industry will be promoted through the BREF documents, but so far this aspect is not reflected in concrete requirements in BREFs. The aim of this study is to provide input on how circular economy issues can be addressed in the BREFs in accordance with this new EU policy in order to facilitate recycling, reuse and improve the uptake of secondary raw materials. A general finding is that CE objectives cannot be reached by amending single regulatory frameworks and, instead, a systematic review of the whole regulatory system is required. IED and BREFs can promote CE objectives only to a limited extent, but, however, more can be done by making better use of the existing mechanisms in a systematic way. Many BREFs already include BATs on waste recovery and treatment, but requirements promoting non-toxic cycles should be more concrete than at present. For example, cross-contamination of waste materials should be prevented through requirements on source separation in BREFs. More emphasis could also be put on the practical implementation of waste hierarchy, which is the leading principle in supporting efficient material cycles. The traditional scope of IED and BREFs covers a single industrial installation from gate to gate, whereas the promotion of CE requires life cycle thinking and better connections to upstream and downstream processes. HAZBREF-project recommends introducing a BAT for chemical inventory in sectoral BREFs to support information on the chemical content of the products throughout the whole supply chain. Product requirements may limit the use of secondary raw materials and quantitative BATs (BAT-AEPLs) in BREF documents are rarely feasible, but increased information on possibilities to use secondary raw materials would support the recovery of waste and prevent waste generation.