A Directive Already in Force, and a Deadline That Is Approaching
The revised Industrial Emissions Directive (IED 2.0) entered into force on 4 August 2024. This is not a regulation that is “coming”—it is already part of EU law.
Member States were required to transpose it into national law by 1 July 2026. This means that from that date onward, national competent authorities will permit and regulate IED installations under the transposed national law.
For film coating factories, the timeline is tightening.
A Critical Reality: Transposition Is Behind Schedule
As of May 2026, no Member State had completed transposition of IED 2.0 into national law. A priority question submitted to the European Parliament explicitly states that this delay is creating “legal uncertainty” for Member States, competent authorities, and industrial operators alike.
The reason is that the Commission has simultaneously tabled the Environmental Omnibus, which would significantly modify and simplify the very provisions that Member States are expected to transpose. Requiring transposition of a directive that is simultaneously being renegotiated is inherently contradictory.
What does this mean for factories?
First, legal uncertainty does not mean regulatory suspension. The legal force of IED 2.0 already exists; transposition into national law is only a matter of time. Competent authorities may delay formal enforcement, but the logical basis for compliance obligations is already established.
Second, transposition delays may compress transition periods. If Member States complete transposition in the second half of 2026, the compliance countdown for BAT-associated limits will start simultaneously.
Does Film Coating Fall Within the Scope of IED
This is the first question factories need to answer.
Annex VII of the IED explicitly lists “Other coating, including metal, plastic, textile, fabric, film and paper coating,” with a solvent consumption threshold of 5 tonnes per year.
In other words: if your film coating line consumes more than 5 tonnes of solvent per year, you are within the scope of the IED.
This is not a high threshold. A medium-sized coating line easily exceeds this figure in annual solvent consumption.
For installations exceeding the threshold, Annex VII sets emission limit values for waste gases and fugitive emissions. For “other coating” activities with solvent consumption above 15 tonnes per year, existing installations face waste gas emission limits of 50 mg C/Nm³ (drying processes) or 75 mg C/Nm³ (coating processes), and a fugitive emission limit of 20% of solvent input.
Three Substantive Changes Brought by IED 2.0
Change One: Mandatory Environmental Management System (EMS)
IED 2.0 requires all IED installations to establish an Environmental Management System aligned with ISO 14001 or EMAS. This is not a “recommendation”—it is an “obligation.”
Existing installations must implement and demonstrate EMS conformity by 1 July 2030. New installations (starting operation after 1 July 2026) must prove conformity at start-up.
For film coating factories, a core element of the EMS is the Solvent Management Plan. BAT conclusions explicitly require: “monitor total and fugitive VOC emissions by solvent mass balance.”
Change Two: Stronger Binding Force of BAT-Associated Emission Levels (BAT-AELs)
The core logic of IED 2.0 is: permit conditions must be based on BAT-Associated Emission Levels (BAT-AELs). BAT-AEL is an “achievable range of emission concentrations or loads” that competent authorities must use as the basis for setting permit limits.
For surface treatment using organic solvents, BAT conclusions (Commission Implementing Decision (EU) 2020/2009) have already established a complete system of BAT requirements. These include:
- Detailed EMS requirements (BAT 1)
- Solvent use optimization management plan (BAT 3)
- Selection of low environmental impact raw materials (BAT 4)
- Leak and spill prevention and control plan (BAT 5)
- Solvent mass balance monitoring (BAT 10)
- Waste gas emission monitoring (BAT 11)
- Energy efficiency optimization (BAT 19)
Film coating factories need to assess their gaps against these BAT requirements.
Change Three: Significantly Increased Penalties
IED 2.0 introduces turnover-based fines. Serious infringements may trigger fines of up to 3% of annual EU turnover. Additionally, operators may face civil liability for health harms resulting from breaches of core duties.
For film coating factories, this is not a theoretical risk. If emissions exceed limits or fugitive emission controls fail, the financial impact of penalties could be significant.
What Factories Should Do Now
First, confirm whether you are within the scope of IED.
Check your annual solvent consumption. If it exceeds 5 tonnes, you need to plan compliance under the IED framework. This is not a number that can be ignored.
Second, assess your current solvent management status.
BAT 10 requires monitoring total and fugitive emissions by solvent mass balance. Has your factory established a complete solvent mass balance system? Can you quantify fugitive emissions? If not, this is step one.
Third, understand what BAT-AEL means for film coating specifically.
For “other coating” activities with solvent consumption above 15 tonnes per year, existing installations face waste gas limits of 50/75 mg C/Nm³ (drying/coating) and a fugitive emission limit of 20% of solvent input. Can your existing treatment infrastructure meet these limits?
Fourth, monitor transposition progress and BAT updates.
The compliance countdown for BAT conclusions is “4 years after publication of BAT conclusions.” For BAT conclusions published after IED 2.0 enters into force, this countdown starts simultaneously. Film coating factories should continuously monitor BAT conclusion updates in the Official Journal of the EU.
A Pragmatic Judgment
The transposition delay of IED 2.0 has created a “window period.” But the nature of this window needs to be accurately understood.
This is not a window for “procrastination”—it is a window for “advance preparation.”
Once transposition is complete, BAT-AEL compliance obligations will formally take effect. For existing installations, the compliance deadline for BAT limits is typically “4 years after publication of BAT conclusions,” extendable to up to 8 years for installations with substantial transformation plans.
This means: from BAT conclusion publication to mandatory compliance, there are 4 to 8 years. But the preparatory work—establishing a solvent mass balance system, implementing an EMS, evaluating treatment infrastructure—needs to start now.
For film coating factories, the RTO equipment cycle from design to installation and commissioning is approximately 5 to 6 months. If action is delayed until the compliance deadline approaches, this cycle may become a bottleneck.
Next Step
Evaluating the specific compliance impact of IED 2.0 on film coating factories? We provide an “IED 2.0 Compliance Pre-Assessment” for the film coating industry, helping you benchmark against BAT conclusion solvent management requirements, identify gaps in your existing system, and assess whether your treatment infrastructure can meet future BAT-AEL limits.