The Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety (BMUKN) presented a draft regulation at the beginning of 2025 to implement the EU Industrial Emissions Directive (IED) and the BAT conclusions for textiles into German law. The somewhat cumbersome title of the draft is: “Allgemeine Verwaltungsvorschrift zur Umsetzung des Durchführungsbeschlusses (EU) 2022/2508 über Schlussfolgerungen zu den besten verfügbaren Techniken in Bezug auf die Textilindustrie.” The revised draft was sent to the relevant associations for comment as part of the consultation process under § 51 of the Federal Immissionsschutzgesetz (BImSchG).
This administrative regulation aims to transpose the requirements of the 2022 BAT conclusions for textiles and the revised IED Directive into national law. It includes extensive provisions on emission limit values, technical measures, and monitoring obligations. The impact on the textile industry is therefore enormous.
*BAT = Best Available Techniques
TEGEWA represents suppliers to this sector and is committed to the appropriate implementation of the European IED requirements, within which the BAT conclusions are regulated. From TEGEWA’s perspective, the draft regulation goes significantly beyond the European requirements and the BAT conclusions for textiles. We therefore advocate for a consistent and unchanged 1:1 implementation of the IED Directive as a whole, as well as the sector-specific European BAT conclusions. Additional national requirements contradict the harmonization objective of the IED and the current German government’s stated goal of implementing EU regulations on a 1:1 basis. Deviating from harmonization and the government’s goal would lead to competitive distortions to the detriment of Germany as a business location within the European internal market.
The joint statement developed with VCI, which was submitted as part of the association hearing at the end of August, includes a proposal to clarify which textile finishing plants fall under the scope of the permitting requirement, as well as detailed and scientifically substantiated proposals for implementing the requirements for flame-retardant finishes and for water-, oil-, and dirt-repellent treatments.
Further details can be found in the attached position paper, which is also available for download on the website of the Federal Ministry for the Environment. (In German only)