On 15 July 2024, Directive (EU) 2024/1785 of 24 April 2024 was published in the Official Journal of the European Union, amending two key pieces of European environmental law: Directive 2010/75/EU on industrial emissions (IED) and Directive 1999/31/EC on the landfill of waste.
BOE.es – DOUE-L-2024-81092 Directiva (UE) 2024/1785 del Parlamento Europeo y del Consejo, de 24 de abril de 2024, por la que se modifican la Directiva 2010/75/UE del Parlamento Europeo y del Consejo sobre las emisiones industriales (prevención y control integrados de la contaminación) y la Directiva 1999/31/CE del Consejo relativa al vertido de residuos. . This reform is one of the most significant changes of recent years in the environmental regulation of industrial and livestock activities.
Although the Directive still has to be transposed into the legal systems of the Member States, the timetable is clear: the transposition deadline is 1 July 2026. From that moment, the new obligations will begin to have real effects on the competent authorities and, above all, on the operators of the installations concerned. The key question is: what does this obligation actually involve and how should companies prepare for it.
An ambitious reform of the Industrial Emissions Directive
Directive (EU) 2024/1785 is not a minor amendment. It responds to the objectives of the European Green Deal and to the aim of moving towards a more sustainable industry, with less environmental impact and better protection of human health.
The main pillars of the reform include:
- a more integrated approach to pollution control,
- the incorporation of broader environmental performance criteria,
- the strengthening of prevention over correction,
- and greater consistency with decarbonisation and circular economy policies.
These changes translate into new legal obligations that will affect both existing installations and new activities.
1 July 2026: a key date
The Directive requires Member States to adopt and publish the provisions needed to comply with it before 1 July 2026. This means that, from that date:
- national and regional legislation must have been adapted
- the new criteria will apply in environmental permitting
- the progressive application of the new regime to existing installations will begin, in line with the transitional periods that are defined.
It is important to note that not all obligations will be required immediately of all installations, but the Directive will be fully binding from a legal point of view. This means that any administrative decision adopted from that date will have to take the new regulatory framework into account.
Main changes with a direct impact on companies
From a practical perspective, the IED reform introduces changes that may have a significant impact on the environmental management of many activities:
1. Environmental management system
Installations concerned will be required to have a structured environmental management system, adapted to the size and nature of the activity. This system must make it possible to identify, prevent and reduce environmental impacts on a continuous basis.
2. A strengthened approach to BAT
Best available techniques (BAT) gain weight not only as a technological reference but also as a tool for assessing the overall environmental performance of installations, beyond mere compliance with emission limit values.
3. Extension of the scope
The Directive extends its scope to new activities and sectors, including certain intensive livestock farms and other activities that until now fell outside the IED regime. This may bring into the integrated environmental permitting system many operators that were not previously subject to it.
4. More transparency and control
Information, inspection and control obligations are reinforced, as is the sanctioning regime, with the aim of ensuring a more uniform and effective application of the rules throughout the European Union.
What should companies already be doing?
Although the national implementing legislation is still pending, waiting before starting to act is not advisable. The companies concerned should already be considering, as a minimum:
- a preliminary screening analysis to determine whether the activity falls within the scope of the Directive
- a review of the current environmental situation against the new requirements
- the planning of technical, organisational or documentary adaptations
- the integration of these changes into the medium-term business strategy
In this context, the support of a specialised environmental consultancy can be key to anticipating risks, optimising investment and ensuring an efficient, safe adaptation to the new regulatory framework.
A regulatory change to be addressed early
Directive (EU) 2024/1785 marks a turning point in the regulation of industrial emissions. 1 July 2026 is not just an administrative date but the start of a new regulatory landscape that will demand more planning, more control and more integrated environmental management.
Getting ahead of these changes is, without doubt, the best strategy and at auma we can help you auma