Two Myths, One Truth – The Game of Industry Rules 

Two myths, one truth – what is the reality of rules for industry? EU decisionmakers reviewing key pollution prevention rules have an opportunity to enact pollution prevention that works for people and the environment. Let’s play – and win – the game of industry rules.

We have all been there. You are new and need to get to know the people around you – what better way than a game? You give a couple of statements about yourself, and others need to figure out which ones are true or false. Maybe you were a model as a teenager, maybe not. A fun way to get to know each other.  

If you find yourself in a room with European rules with environmental impact, it is important to get to know the Industrial Emissions Directive (IED). It has the potential to become the legislative flagship for the EU’s zero pollution, climate neutrality and circular economy ambitions, while improving public health and public accountability. It covers 20% of the EU’s overall pollutant emissions into the air, 20% of pollutant emissions into water and approximately 40% of greenhouse gas emissions.  

The IED is currently under discussion, and the European Parliament and Council are expected to take a position on this issue in the Spring. Ideas about this proposal are flying around the EU policy room and myths might distort the reality of rules for industry. The proposal is not yet fit for cleaning up industrial production and generating transformative change so it’s time to play – and win – the game of industry rules.  

Myth – It Is Just Too Much To Pollute Less 

An idea often thrown around the room is that it is too much effort for industry to pollute less. A clarification that pollution levels should only go up to the minimum amount technically possible has opposers worried about administrative burden and economic effort to move beyond business-as-usual.  

However, this does not correspond to reality. EU rules allow industry to pollute within a certain range that is set by Member States, civil society and industry itself. Between 75% and 85% of all pollution limits are set at the higher end of this range, under-delivering on emissions reduction at the expense of public health and environmental protection. This means there is potential pollution reduction that could take place right now. The IED can use this potential by asking industry to pollute at the lowest level that is feasible – as already previously established by the very same industry.  

Only what is technically feasible is requested of industry. A lack of compliance with rules they chose for themselves for any non-technical reason is therefore not reasonable. This also means that there is no need for setting new rules or transition periods, setting the process of de-polluting the environment back for decades. This gambling into the future is a tactic to avoid stopping pollution that would prevent the EU from achieving its climate goals on time. 

In fact, it is only asked of industry to pollute the minimum possible that current techniques allow, as decided by themselves. Sounds reasonable? It is.  

Myth – What’s Climate Got To Do With It? 

“We should not have to worry about climate because it is the scope of other EU rules” – yet another myth. Polluters want to constrain IED action to tackle greenhouse gas emissions and decarbonisation, pointing to the EU’s Emission Trading System (ETS), saying it would be unnecessary double regulation or that the ETS is more cost effective.  However, the IED accounts for 40% of these emissions in Europe and the ETS is not keeping its promise to achieve carbon neutrality by 2050. 

A combined approach is the more effective option. If the two directives were to be combined, higher rates of decarbonisation could be achieved. As it stands, the IED misses its chance – public authorities cannot set binding greenhouse gas emission limits to industrial installations covered by the ETS. The IED is an opportunity to help the EU emissions market deliver its promise. 

True climate action in industry can only be achieved by a broad scope for the IED. Intensive livestock is responsible for 12 to 17% of the total European greenhouse gas emissions. In turn, 55% of methane emissions stem from the agricultural sector, mostly from intensive livestock. The revised IED should provide for pollution prevention for intensive cattle rearing. Despite claims of overburden, only 13% of the EU’s largest livestock farms would be affected – but they would represent 60% of ammonia and 43% methane emissions. An easy win all around.  

Truth – People are Key in the Game

People are key in the game of industry. The health of people and planet is at stake and the IED cannot play with it. Therefore, society should be able to participate in the process of setting the rules for industry and enforce accountability towards polluters.  

At the core of industry rules is people’s health. The need for meaningful sanctions is overdue – competition law breaches have higher penalties than infringements related to human health. Compensation rights can be strengthened by enabling compensation claims against any damage to human health and the environment occurring due to failure to prevent pollution at source. 

Society needs to be able to participate in the making of industry rules. No proper access to information hinders effective participation. Data should be available to civil society organisations for analysis and comparison at the EU level. There’s no way to win a game without knowing all the rules.  


The game of industry rules is easy to play and essential to win. Many myths abound about the Industrial Emissions Directive, but it is straightforward that we cannot play with the health of people and planet. Winning at this game will bring Europe towards circular, decarbonised and zero-pollution industry. Decisionmakers, it’s time to make your move – will you be on the winning side?