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Emission Trading Scheme

On 23 January 2008, the Commission adopted a proposal designed to amend the current EU Emission Trading Scheme Directive (Directive 2003/87/EC). The major change, beside the introduction of a Unique European ceiling instead of 27 different MS ceilings and the introduction of a linear emission reduction factor, is that the emission allowances will not anymore allocated for free. By means of a progressive allowance plan, the allowances will be gradually subjected to auctioning. By 2020 each single allowance will have to be purchased and it has been estimated that the price will be approximately 40 euro/ton CO2.

Given the relevant impact that the proposal has on the industry and considering the risk of carbon leakage (movement of production site outside EU), the Commission has initiated a study on Energy Intensive Industries for assessing the necessity to guarantee free allowances for specific sector. The tyre industry is actually under assessment and ETRMA working in direct contact with Tyre Corporate Members and the Commission for providing the necessary data required for this evaluation.

Implementation of the VOC Directive

The Directive 1999/13/EC of 11 March 1999 sets the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain in stationary commercial and industrial sources, including the rubber industry plants when their consumption is exceeding the threshold levels set in the annexes.

VOC Directive requirements

The Directive sets emission limits for such compounds and is laying down operating conditions for installations using organic solvents. For the existing installations not subject to IPPC legislation, the Industrial operators obliged to obtain a registration/ authorisation for their installation or activities from the national Competent Authorities before 30 October 2007. In order to obtain this registration they can choose to conform to the specified emissions limits via either of the following ways:

  • by installing equipment to reduce emissions (i.e. abatement techniques) to comply with the emission limit values and the fugitive emission values, or total emission limit values;
  • by introducing a reduction scheme to arrive at an equivalent emission level, in particular by replacing conventional products which are high in solvents with low-solvent or solvent-free products.

Member States may define and implement national plans for reducing emissions from the activities and industrial installations covered by the Directive to reach at least the same level of reduction within the timeframe of the EU Directive. These national plans must contain:

  • a list of the measures taken or to be taken;
  • binding interim reduction targets against which progress towards the aim can be measured;
  • a full description of the range of instruments through which its requirements will be achieved, evidence that these instruments will be enforceable and details of the means by which compliance with the plan will be demonstrated.
  • May exempt certain existing installations from implementation of the emission values laid down in article 5(2) and (3) and Annex II.

Rubber Industry recommendations for national VOC Directive implementation

In the light of the implementation of national allocation plans, the Rubber Industry developed a Sector reduction scheme that has been submitted to Member States, as the most and unique cost-effective way for the rubber-manufacturing sector to reach the VOC Directive objectives.

A further example of a national plan is available for France:
Guide de rédaction d'un schéma de maîtrise des émissions dans le secteur de la transformation du caoutchouc, Avril 2002 (French Rubber Industry Association, SNCP)

Integration of the VOC Directive in a single directive on industrial emissions

On 21 December 2007 the Commission adopted a Proposal for a Directive on industrial emissions. The Proposal recasts seven existing Directives related to industrial emissions into a single clear and coherent legislative instrument. The recast includes in particular the VOC Directive and the IPPC Directive.

ETRMA is acting for easing the interpretation of the regulatory requirements and harmonising their implementation among the Member States.

Update 25 August 2008