With the call for the re-activation of the Technical Working Group (TWG) in July 2018, the revision of the BREF (Best Available Techniques Reference Document) for the Smitheries and Foundries was launched. The TWG is the crucial panel in the BREF review process. In order to represent the interests of the European foundries in this revision adequately, the European Foundry Association (CAEF) participates in the TWG with 17 members, including the Cast Metals Federation which will be representing the UK Castings Industry. The TWG consists of delegations from the European Member States, the Industry, the EU Commission as well as European Environmental Associations.
Against the background of the long-lasting process required to complete the previous BREF, the European Commission has drawn up new guidelines to speed up the review this time. Before the official Kick-off Meeting, certain work is carried out within a so-called front-loading procedure. Unlike the “Wish List” used in the past, in which the members of the TWG could formulate their revision requests related to the BREF contents, “Initial Positions” are now developed by the BREF authors and submitted to the TWG for comment. These “Initial Positions” include proposals and requests for potential adjustments to an existing BREF; for example regarding the scope and structure of the document, relevant Key Environmental Issues (KEI) and organization of data collection as well as potential BAT candidates.
From CAEF´s point of view, the SME structure of the foundry industry has to be taken into account during the whole BREF revision activities. Thus, the European Foundry Association welcomes the more focused approach as required by the EU Commission. Only processes and parameters being definitely of environmental relevance should be part of the review. In particular, some of the proposed KEI have been seen as very critical by the foundry industry.
For instance, CAEF does not consider requirements for energy or material efficiency as being reasonable. Due to the huge variety of applied materials, technologies, processes and manufactured products, the setting of certain limit values would never be able to satisfy the individual conditions of our companies.
In March, the assessed items of the Initial Positions had to be submitted to the Seville Bureau. They form the basis for the Kick-off Meeting which is now scheduled for September 2019.
