The IED 2.0 Directive introduces significant changes for operators of installations subject to the requirement to obtain an integrated permit. The new requirements concern not only emissions to the environment, but also environmental performance, energy, water and raw material consumption, the management of hazardous substances, and the long-term planning of installation transformation.
For many companies, this means the need to prepare documentation in advance, organise environmental data, and verify whether their current environmental management system and integrated permit are ready to meet the new requirements.
Echo Energy and Safety Sp. z o.o. supports companies in analysing their obligations under IED 2.0, assessing the compliance of installations with BAT requirements, and preparing a practical action plan for adaptation.
IED 2.0 is the commonly used term for the amendments to the Industrial Emissions Directive. These provisions primarily affect installations that require an integrated permit, i.e. installations which, due to the scale and nature of their activities, may have a significant impact on the environment.
The new approach assumes that an installation should be assessed more broadly than solely in terms of permissible emission levels. Increasing importance will also be placed on:
In practice, IED 2.0 means a greater focus on data, technical analysis, documentation, and systematic management of the installation’s environmental impact.
One of the key changes is the new approach to setting emission limit values. The permitting authority will assess the full range of levels associated with the BAT conclusions, rather than considering only the upper limit of permissible emissions.
This means that the operator of the installation should be prepared to demonstrate:
The new regulations also strengthen the importance of BAT-associated environmental performance levels. In practice, an integrated permit will no longer focus solely on emissions, but may also cover other parameters related to the operation of the installation, such as energy, water, raw materials, and waste.
One of the most important changes introduced by IED 2.0 is the obligation to implement an environmental management system for installations covered by an integrated permit.
The system should include, among other things:
For many companies, this will mean the need to implement a new system or adapt their existing ISO 14001 / EMS system to the additional requirements arising from IED 2.0.
IED 2.0 also introduces the obligation to prepare an installation transformation plan. This document is intended to show how the installation will be adapted to the objectives of climate neutrality, efficient use of resources, and the circular economy by 2050.
The transformation plan should not be merely a formal document. In practice, it can become a tool for planning investments, modernising installations, reducing emissions, improving energy efficiency, and preparing the company for future regulatory changes.
The new regulations also increase the importance of managing hazardous substances. The operator of the installation will be required to demonstrate that it analyses the substances used, assesses the risks associated with their use, and considers the possibility of replacing them with substances with a lower hazard potential.
In practice, this means the need to organise data on chemicals, safety data sheets, technological applications, environmental risks, and possible alternatives.
This area will be particularly important for manufacturing plants, chemical installations, paint shops, electroplating facilities, waste treatment installations, and other facilities where substances that may have an impact on the environment are used.
IED 2.0 retains the possibility of obtaining a derogation from BAT requirements, while at the same time placing greater emphasis on the justification for such a derogation.
When assessing a derogation, the following factors may be taken into account, among others:
This means that a general justification alone may be insufficient. The operator should have a technical, environmental, and economic analysis demonstrating why achieving a specific BAT level is either not feasible or would involve disproportionately high costs.
The changes resulting from IED 2.0 will affect integrated permits, environmental documentation, management systems, and the way data is reported. In many cases, adapting an installation to the new requirements will not be possible overnight.
Early analysis makes it possible to:
The scope of our cooperation is tailored to the type of installation, the industry, the integrated permit held, the existing management system, and the level of available data.
As part of our support, we can carry out, among other things:
The outcome of our cooperation may include, depending on the agreed scope:
Further cooperation is also possible in implementing the recommendations, preparing documentation for the relevant authorities, conducting internal audits, and providing ongoing environmental compliance support for the installation.
The IED 2.0 audit is intended in particular for companies that:
For the preliminary assessment of the scope of work, the following information is helpful, among other things:
Based on this information, it is possible to identify which areas require urgent analysis and determine the most practical scope of support for the installation concerned.
Echo Energy and Safety Sp. z o.o. supports companies in the areas of environmental protection, integrated permits, air emissions, management systems, compliance audits, and obligations arising from national and EU legislation.
Our aim is to provide practical support to companies in preparing for the changes resulting from IED 2.0 — from analysing obligations and identifying risks, through preparing the necessary documentation, to implementing the recommended measures.
Contact ECHO if you would like to verify your installation’s compliance with IED 2.0 requirements, prepare an environmental management system, assess BAT-related risks, or plan an update to your integrated permit.
