The previous phase of the IED Serbia project included drafting of the Directive Specific Implementation Plan (DSIP) for the Industrial Emissions Directive (IED), but as a result of the necessity of including operators using Volatile Organic Compounds (VOC) in their production processes, who were identified during the implementation of the eVOC Serbia project, the preparation of a part of the DSIP to include Chapter V of this Directive was required.
The methodology for preparation of the DSIP includes various aspects, such as technical and financial analysis, as well as analysis of the socio-economic impact resulting from the implementation of regulations related to VOC. The technical analysis of operators using volatile organic compounds in their production processes involved checking compliance with Chapter V of the IED and identifying potential non-compliances. Along with the technical analysis, project experts also conducted the analysis of socio-economic impact, i.e., assessment of how the implementation of Chapter V would affect employment, local communities, etc.
A total of 390 companies from 19 industrial sectors were analysed, including operators engaged in printing (heatset web offset printing, flexography, rotogravure for packaging, publications, etc.), painting and other coating activities (winding wires, vehicles, agricultural and construction equipment, furniture, coils, metal packaging and other metal and plastic surfaces), cleaning and degreasing in combination with other surface treatment activities, dry cleaning, wood coating and impregnation, rubber conversion, extraction and refining of vegetable oils and animal fats, etc. The analysis found that a number of companies were no longer in operation or were not subject to the requirements of Chapter V of the IED as their solvent consumption was below the prescribed threshold. On the other hand, for several companies, a detailed check of solvent consumption, revealed that they are also subject to Chapter 2 of the IED, which pertains to the integrated pollution prevention and control, i.e., that these operators are obliged to obtain IPPC permits.
Several missions of the international technical expert from Germany were dedicated to visiting installations belonging to different industrial sectors and identifying activities that are potential sources of VOC emissions. More than 15 visits to operators using solvents in their production processes were organised during and after these missions with the aim of better preparation of the DSIP.
The technical compliance analysis of the Directive revealed non-compliance in a little over one hundred and sixty companies, primarily in the dry-cleaning sector. The analysis concluded by identification of measures needed for each company that does not meet the requirements of Chapter V of the IED to achieve full compliance with the Directive. In the coming period, these measures will be further discussed with companies and the necessary investments to achieve compliance will be assessed. After that, sustainability of these investments will be defined, as well as potential need to introduce transitional periods for these companies, i.e., extended period for achieving full compliance with the Directive, so that they are included in the DSIP and in the group of operators for which transitional periods for full compliance with the Directive will be negotiated during the accession negotiations with the European Union.