Process and status
The current (IPPC) STM BREF has been published in August 2006. The kick off started in April 2002, the final meeting took place in September 2004, but additional water collection was performed shortly after. All in all, it took 4.5 years to elaborate the STM BREF from scratch to its publication.
- Kick off meeting: 30 May – 7 June 2024 (see here)
- D1 release – 16 Feb 2025 (see here)
- Commenting deadline D1: 9 May 2025
- Final meeting – tentatively initially Q2 2024 – more likely Q3 2025
- Comitology date – tentatively initially Q3 2025
- Publication date – tentatively initially Q4 2025.
Main Environmental issues and discussion points on BAT / BATAE(P)Ls
The most important environmental aspects arising from the surface treatment of metals and plastics relate to energy and water consumption, the consumption of raw materials and emissions. These include emissions to surface water and groundwater, emissions to air and water, solid and liquid waste and the condition of the site at the end of operations. The revision pays particular attention to chemical pollution caused by the substance chromium and the “forever chemicals” PFAS. The latter is a group of persistent chemicals that cause emerging risk and concern, since they don’t break down and thus built up in the environment.
The above-mentioned aspects and issues have been recognised as such at the Kick off Meeting Background paper (April 2022), see here.
EEB pushed in this revision for:
- Supporting the newly introduced PFAS group as pollutants beyond the previous far too limited focus of only the single substance PFOS. A list of PFAS that are identified from literature sources for these activities you can find here.
- Declaring Chromium VI based plating as negative BAT to support the transition towards cleaner Chromium III or chromium free techniques.
- Protecting water sources beyond pollution by promoting practices that reduce water consumption in this very water intensive industrial activities. Notably building on the French water consumption limit set at 8l/m2/rinse stage introduced in 1985 in legislation applying to all surface treatment installations with a total volume of treatment tanks of more than 10m³.
- Promoting decarbonisation measures such as increasing the share of renewable electricity to 100%.
The full set of EEB comments made available to the EU BRITE is available here:
- EEB comments to Draft 1 (May 2025)
- Relevant PFAS list for STM sector list
“How can you make a difference?”
- Data on the type, function and volumes of PFAS in the production of semiconductors would be welcome, as well as emission monitoring data (see PFAS listing provided during the D1)
- Information on PFAS substitution and abatement techniques for waste water streams & for concentrated industrial waste water with monitoring data as to performance (abatement efficiencies).
- Information on decontamination of PFAS polluted soils / sites
- PFAS monitoring techniques that are standardised / normed, securing detection limits below 0,1 µg/l.
- Load limits (flow) in regard to water pollutants relevant for STM BREF
- Best practice for decarbonisation in the sector (e.g. use of renewable electricity for the relevant processes).
- Support to win PFAS phase out action by Member States.
Contacts
Please send information to Christine.Hermann@eeb.org