The European Commission defines the current state of the art for almost all industrial sectors in the form of BREF documents (Best Available Techniques Reference or Best Available Techniques Reference Document).
The BREF Surface Treatment of Metals and Plastics (BREF STM) contains the key regulations for the surface treatment industry. The planned update started back in 2021 with the active involvement of the German Aluminum Surface Finishing Association (VOA) and is still ongoing today. No wonder, because the regulation involves an incredible amount of work, both by the national expert group - in Germany under the leadership of the Federal Environment Agency - and the European Technical Working Group, which compiles all the necessary information and data for the European Integrated Pollution Prevention and Control Bureau (EIPPC).
Of particular importance: the collection of data from numerous, differently positioned EU companies, from which emission values will be derived in future that are to be implemented on a binding basis throughout Europe; supplemented by visits to selected companies, which naturally also include VOA member companies.
Visits by the BREF STM
In 2024, the BREF STM delegation visited a total of six companies in Germany that had previously been selected by the Federal Environment Agency in consultation with the EU Bureau for Research on Industrial Transformation and Emissions (EU-BRITE).
The aim: to gather background information and discuss issues relevant to the review. Coordinated by the VOA office, several member companies had agreed to receive the delegation and to answer questions. For example, the planned visit to Albea Oberflächenbearbeitung GmbH, a member company of the VOA, took place.
The delegation paid particular attention to the emission values in air and water as well as their monitoring and the external disposal of residues in the form of concentrated sludge. They were also interested in the specific consumption of natural gas and electricity, which the company mainly uses for processes and cooling/heating and monitors to some extent. The visit showed that although the expected energy consumption for a specific part of the process can be predicted based on many years of experience, estimates are only accurate when focused on specific vats due to the wide and varying range of orders for different workpieces. The estimated total amount of surface treated varies by as much as 20 percent. In the end, there are also no exact figures available for the treated surface area in order to make a concrete calculation. This lack of precision makes it difficult to determine valid figures in practice and therefore also to comply with certain consumption limits. This is where reality and the more theoretical development of regulations that would actually have to be complied with come together.
VOA calls for participation in BREF STM
It is therefore particularly important and a concern of the VOA as a trade association for the industry to provide the delegation representatives with a deep insight into the practice of the companies through the factory tour. This will provide valuable information on the technical conditions on site in order to formulate realistic, practicable requirements throughout Europe when updating the BREF STM. The new edition is therefore of particular importance, as it will set standards in the future once it has been released. It is therefore particularly important that the new regulation standardizes realistic figures, which is why the VOA is calling on its members to get involved and provide their input for the industry. In this way, sensible regulations can be formulated that can be adhered to by the industry in Europe.
INFO
How does the BREF STM update work and who is involved?
In the run-up to a BREF revision, the industry experts at the Federal Environment Agency (UBA) set up the (Extended) National Expert Groups ((E)NEG) for each BREF and the so-called "Seville Process" begins. The NEG, the national committee for the revision, is made up of representatives of the authorities, while the ENEG also involves experts from industry, science and associations. The group meets at regular intervals under the leadership of the Federal Environment Agency and discusses the current status, upcoming work and possible positions on the individual steps in the process. It accompanies the entire BREF revision and thus directly supports the Federal Environment Agency, which represents the German position in the negotiations in Seville. The European Integrated Pollution Prevention and Control Bureau (EIPPC office - known as the "Seville office" for short, as it is based in the city) acts as a neutral, technically competent body and is responsible for planning and implementing the new development and revision processes for BREFs (Best Available Techniques).
