The CER BREF covers industrial installations manufacturing ceramic products, incl. wall and floor tiles, bricks and roof tiles, sanitaryware, but also table- and ornamentalware (household ceramics) and technical ceramics.
These installations cause pollutant emissions to air, e.g., dust from the handling/processing of raw materials and nitrogen/sulphur oxides from the firing process, emissions to water, e.g., insoluble particulate matter, inorganic materials, and emissions to land (waste).
A further important aspect is energy consumption, and CO2 emissions: all sectors of the ceramic industry are energy intensive, esp. the drying and firing process steps. According to Cerame-Unie, for the ceramics sector 64 % of emissions come from fuel combustion (drying and firing of ware), 17 % correspond to direct process emissions (transformation of the materials), and 19 % correspond to indirect emissions associated with the operator’s energy use (mainly from electricity production), and with assets not owned or directly controlled by the operator, such as transportation and distribution outside the production site.
The CER BREF was published in 2007 (under the Integrated Pollution Prevention and Control Directive of 1996, which was repealed and replaced by the Industrial Emissions Directive in 2014), and it is currently under review.
CER BREF review: key milestones of the process
The key milestones of the review process are the following:
1. The Kick-off Meeting (KoM) of the technical working group (February 2021)
- The KoM report, incl. decisions taken on the scope of the review and the key environmental issues to focus on, is available here.
- The KoM background paper, summarising the stakeholders’ positions on key issues is available here.
2. The release of the first draft of the BREF (D1) (November 2024)
- The D1 of the BREF is available here.
- The EEB comments on the D1 are available here.
3. Deadline for comments on the D1: 28 February 2025
4. The Final Meeting (FM) of the technical working group (scheduled for December 2025)
- The draft BAT conclusions as decided at the FM (not yet available).
- The background paper of the FM, summarising the stakeholders’ positions on key issues (not yet available), and the draft BAT conclusions discussed at the final meeting (not yet available).
- The Commission’s assessment on dissenting views following the FM (not yet available).
5. The meeting of the IED Forum
- the opinion of the Forum (not yet available).
6. The IED Article 75 Committee vote
7. The publication of the BAT conclusions in the Official Journal of the EU (OJEU)
- The updated BAT conclusions (not yet available).
- The updated BREF (not yet available).
The publication of the BAT conclusions in the OJEU sets a four-year deadline for installations across the EU to comply with the updated requirements. However, if the BAT conclusions are published before an installation’s permit is issued, the installation must comply with the requirements immediately.
Current state-of play: discussion on environmental issues, BAT and BAT-AE(P)Ls
The CER BREF D1 certainly presents improvements comparing to the 2007 version. The new features of the IED 2.0 are reflected therein, incl. the inclusion of decarbonisation and circularity aspects, the proposals for environmental performance levels (other than pollutant emission levels), the elaboration on the circumstances allowing the achievement of the strictest end of the (BAT associated) emission ranges, and the further elaborated elements of a comprehensive Environmental Management System. Furthermore, the pollutant emission levels, esp. regarding emissions to air have been tightened, reflecting the results of the data collection.
On the other hand, the EEB regrets that the key issue of decarbonisation has been downplayed in the draft. The decarbonisation of energy-intensive industries (EIIs), such as the ceramics industry, is essential to achieve the goal of net-zero emissions of greenhouse gases by 2050 and timely tackle the climate crisis. IED 2.0 includes provisions on climate protection and decarbonisation – incl. regarding the criteria for the determination of the best available techniques. It is of the utmost importance to ensure that the BREFs adopted under the new Directive, applying to EIIs, are driving the decarbonisation efforts in coherence with other EU instruments. Being of the first BREFs to be adopted under the new Directive, it further sets an important precedent for the upcoming BREF reviews for more impactful industries to the climate, such as the steel and cement sectors.
However, in the current draft, we note that no strong provisions supporting the decarbonisation of the sector are in place. Even if techniques that can deliver on decarbonisation are mentioned, due to the wording of the ”chapeaux” in the relevant BAT conclusions, these techniques can easily be dismissed in implementation, e.g., in BAT 14 (emissions to air from firing), the operator is asked to consider an appropriate combination of techniques (g) to (q), incl. the use of kilns powered by electricity (or other fossil-free energy sources), but also low-NOX burners, fabric filter, electrostatic precipitator, and scrubbers etc.
Furthermore, the wording on Deep Industrial transformation (DIT) does not reflect the latest developments regarding the use of hydrogen in the ceramics industry. Most importantly, when successful trials firing products with 100% hydrogen are taking place (more information on these trials in the EEB comments on D1 here [link to file in the folder]), the current vague wording (”in such a proportion”) would allow operators blending e.g. 20% hydrogen with natural gas to claim they are delivering on the DIT – being put unfairly in the same position with the part of industry that indeed engages and invests in DIT. We need to ensure that the BAT conclusions text is clear, and in support of industry frontrunners.
Contacts
Aliki Kriekouki, Senior Policy Officer for Industrial Production: aliki.kriekouki@eeb.org