Communication from the Commission to the Council, the European Parliament, the Economic and Social Committee and the Committee of the Regions - Towards an improved policy on industrial emissions {COM(2007)844 final} {SEC(2007)1679} {SEC(2007)1682}
Date: 2007-12-21
Institutions: European Commission
Subjects: administrative formalities, air quality, environmental policy, impact study, industrial pollution, pollution control measures, waste incineration

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 21.12.2007 
COM(2007) 843 final 

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE 
EUROPEAN PARLIAMENT, THE ECONOMIC AND SOCIAL COMMITTEE AND 
THE COMMITTEE OF THE REGIONS 

Towards an improved policy on industrial emissions 

{COM(2007)844 final} 
{SEC(2007)1679} 
{SEC(2007)1682} 

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COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE 
EUROPEAN PARLIAMENT, THE ECONOMIC AND SOCIAL COMMITTEE AND 
THE COMMITTEE OF THE REGIONS 

Towards an improved policy on industrial emissions 

1. 

INTRODUCTION 

Industrial  activities  play  an  important  role  in  the  economic  well-being  of  Europe, 
contributing  to  sustainable  growth  and  providing  high  quality  jobs.  However, 
industrial activities also have a significant impact on the environment.  

The largest industrial installations account for a considerable share of total emissions 
of  key  atmospheric  pollutants  (83%  for  sulphur  dioxide  (SO2),  34%  for  oxides  of 
nitrogen (NOx), 43% for dust and 55% for volatile organic compounds (VOC)). They 
also have other  important environmental impacts,  including emissions  to  water  and 
soil, generation of waste and the use of energy. 

Emissions  from  industrial  installations  have  therefore  been  subject  to  EU-wide 
legislation  for  some  time.  Since  the  1970's  various  directives  have  been  drawn  up 
which have ultimately led to the adoption of the following main pieces of legislation: 

•  Directive  96/61/EC  concerning  integrated  pollution  prevention  and  control1 
(IPPC) sets out the main principles for the permitting and control of installations 
based on an integrated approach and the application of best available techniques 
(BAT)  which  are  the  most  effective  techniques  to  achieve  a  high  level  of 
environmental protection, taking into account the costs and benefits.  

•  The so-called sectoral directives lay down specific provisions, including minimum 
emission  limit  values  for  certain  industrial  activities  (large  combustion  plants, 
waste  incineration,  activities  using  organic  solvent  and  titanium  dioxide 
production). 

Notwithstanding  minimum  emission  limit  values  set  in  the  sectoral  directives,  all 
industrial  installations  which  are  subject  to  the  above  pieces  of  legislation  need  to 
orient  their  permitting  regimes  towards  the  implementation  of  best  available 
techniques. 

Innovative  technologies  can  reduce  the  cost  for  compliance  with  legislation  on 
industrial  emissions.  Innovation  also  provides  opportunities  for  industry  to  benefit 
from  the  emergence  of  new  markets  in  environmental  technologies.  The  Lisbon 
Strategy  identifies  sustainable  development  and  environmental  protection  as  an 
important  pillar  of  current  and  future  European  policy  and  stresses  the  role  of 
environmental  technologies  as  having  “significant  economic,  environmental  and 

1 

OJ L 257, 10.10.1996, p. 26 

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employment potential”2. Industrial emissions legislation has an active role to play in 
stimulating the development and deployment of these types of technologies. 

IPPC and the body of legislation on industrial emissions also have a part to play in 
addressing  the  calls  from  the  Member  States,  the  European  Parliament  and  other 
stakeholders for "Better Regulation." With this in mind the Commission launched in 
20053 a review of the body of legislation on industrial emissions in order to ensure its 
environmental and cost-effectiveness and to encourage technological innovation. 

Based on a detailed analysis of the current situation and the outcome of the review 
process, the Commission proposes to streamline and enhance its policy on industrial 
emissions.  For  the  large  combustion  plants  alone  the  proposals  should  lead  to  net 
environmental  and  health  benefits  of  at  least  €7–28  billion  per  year  including  the 
reduction of premature deaths / years of life lost by 13,000 and 125,000 respectively. 
Significant  health  and  environmental  benefits  would  also  be  achieved  in  other 
sectors. Furthermore in collaboration with Member States the proposals would lead 
to  a  net  reduction  in  administrative  burden  by  between  €105  and  255  million  per 
year.  

This  Communication  also  includes  the  results  of  reviews  prepared  under  Article 
16(3) of the IPPC Directive4 (including a review of the Commission's Action Plan for 
IPPC  established  in  2005,  as  presented  in  annex  1)  and  Article  14  of  Directive 
2000/76/EC on the incineration of waste5 (see annex 2). 

2. 

CURRENT SITUATION 

full 

required 

IPPC  Directive 

implementation  by  30  October  2007. 
The 
Approximately  52  000  installations  across  all  Member  States  fall  within  the 
Directive's  remit,  and  by mid 2006  approximately 50 per cent of these installations 
had been permitted under the IPPC Directive. Whilst further progress has been made, 
it  has  become  clear  in  the  meantime  that  the  efforts  made  were  insufficient  for  all 
Member States to comply by the Directive's deadline. 

Furthermore, the Commission has carried out a detailed analysis of the quality of the 
permits issued and of the permitting, compliance and enforcement regimes adopted 
by  Member  States.  Based  on  a  two-year  process  of  data  collection  through  an 
extensive programme of ten studies and continuous consultation of stakeholders, the 
Commission has come to the conclusion that the key principles of the current IPPC 
directive, in particular the integrated approach based on 'Best Available Techniques', 
remain  a  sound  basis  for  the  future  development  of  EU  legislation  on  industrial 
emissions.  

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4 

5 

Common Actions for Growth and Employment : the Community Lisbon programme; COM(2005)330 
final 
COM(2005) 540final  
The  second  reports  from  Member  States  to  the  Commission  on  the  implementation  of  the  IPPC 
Directive cover the period 2003-2005. These reports were analysed in the context of an external study, 
"Analysis of Member States’ second implementation reports on the IPPC Directive”, LDK-ECO  
The  assessment  of  the  application  of  the  WI  Directive  was  included  within  an  external  study, 
"Assessment of the application and possible development of Community legislation for the control of 
waste incineration and co-incineration" (Ökopol, 2007) 

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However,  there  are  significant  shortcomings  in  the  implementation  of  the  current 
legislation  that  hinder  the  full  exploitation  of  best  available  techniques  originally 
intended by the Directive, that make enforcement at Community level very difficult 
and  that  are  not  conducive  to  the  prevention  or  reduction  of  unnecessary 
administrative burden. 

In this context, five main areas for concern have been identified:  

•  Insufficient  implementation  of  BAT.  The  analysis  showed  in  particular  that 
without further emission reduction from IPPC installations, the positive health and 
environmental  effects  that  are  to  be  obtained  from  the  objectives  set  in  the 
Thematic Strategy on Air Pollution will not materialise. In addition, distortion of 
competition within the EU due to large differences in environmental standards is 
being observed. 

•  Limitations  with  regard 

to  compliance,  enforcement  and  environmental 

improvements hinder environmental protection. 

•  Unnecessary  administrative  burdens  due  to  the  complexity  and  inconsistency  of 

parts of the current legal framework. 

•  Insufficient scope and unclear provisions of the current IPPC Directive that could 
hinder  the  achievement  of  the  objectives  set  in  the  Commission's  Thematic 
Strategies. 

•  Constraints  on  the  use  of  more  flexible  instruments,  such  as  NOx  and  SO2 

emission trading systems. 

These  problems  were  discussed  and  assessed  in  detail  in  the  context  of  the 
Commission's impact assessment on the IPPC review. 

3. 

IMPROVING LEGISLATION ON INDUSTRIAL POLLUTION AND ITS IMPLEMENTATION 

In  response  to  the  obstacles  encountered  and  described  above  and  based  on  a 
thorough  impact  assessment,  the  Commission  is  putting  forward  a  package  of 
measures designed to address specific problem areas, which, over time, will lead to 
an improvement of the situation. 

Two key initiatives are envisaged in this context: 

•  Revision of the current legislation on industrial emissions through simplification, 

clarification and strengthening.  

•  Reinforcement of the Commission's Action Plan on implementation. 

Further  to  these  two  initiatives,  the  Commission  will  continue  to  work  on  possible 
EU rules for an emission trading scheme on NOx and SO2. 

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3.1. 

Revision of the current legislation 

The  impact  assessment  undertaken  as  part  of  this  initiative  has  indicated  that  the 
problems  identified  cannot  be  addressed  without  some  changes  in  the  legislation. 
Some of the main amendments to the legislation are the following: 

(1) 

(2) 

(3) 

(4) 

Recasting  the  existing  pieces  of  legislation  (seven  in  number6)  into  a  single 
Directive  on  industrial  emissions.  This  will  improve  clarity  and  coherence 
both  for  Member  States  and  for  operators,  has  the  potential  to  reduce 
through  combined  permitting  and 
unnecessary  administrative  burdens 
streamlined 
some 
reporting 
environmental benefits.  

requirements,  and  will  also  achieve 

Improving  and  clarifying  the  concept  of  BAT  to  create  a  more  coherent 
application  of  the  current  IPPC  directive  and  by  requiring  decisions  that  set 
permit  conditions  outside  BAT  to  be  justified  and  documented.  In  addition, 
current  minimum  emission  limit  values  in  some  sectors  (e.g.  large 
combustion plants) are tightened to ensure the progress needed for achieving 
the objectives of the Thematic Strategy on Air Pollution. 

Introducing minimum provisions with regard to inspection, review of permit 
conditions  and  reporting  of  compliance.  Incentives  for  eco-innovation  and 
support for the creation of lead markets are also considered.  

Extending  the  scope  of  the  IPPC  Directive  to  cover  certain  activities  (e.g. 
combustion  plants  between  20  and  50  MW)  and  clarifying  the  scope  for 
certain sectors (e.g. waste treatment) to increase consistency and coherence of 
current permitting practices.  

(5)  Where the Commission is to take measures to amend non-essential elements 
of the re-cast Directive, the Commission will be supported by a Comitology 
Committee and will ensure broad involvement of stakeholders. 

3.2. 

2008-2010 Action Plan on implementation of legislation on industrial emissions 

With the revised legislation not entering into force for some years, the Commission 
will  need  to  ensure  that  Member  States  apply  the  current  legislation  to  the  fullest 
extent  possible.  It  will  therefore  strengthen  its  monitoring  and  supporting 
mechanisms  by  revising  and  refocusing  the  current  IPPC  Action  Plan  on 
Implementation  (see  assessment  of  progress  in  Annex  1)  for  the  time  period  2008-
2010 as set out below.  

Action 1. Ensure full transposition of the legislation on industrial emissions 

The  legislation  that  controls  industrial  emissions  has  been  produced  to  protect  and 
improve  the  European  environment  and  to  protect  the  health  and  well-being  of 
Europe's  citizens.  The  success  of  the  legislation  relies  first  of  all  on  effective 

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the  IPPC  Directive  and  Directive  1999/13/EC  on  solvents  emissions,  Directive  2000/76/EC  on  waste 
incineration,  Directive  2001/80/EC  on 
large  combustion  plants  and  Directives  78/176/EEC, 
82/883/EEC and 92/112/EEC related to the titanium dioxide industry 

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transposition  by  Member  States  in  their  national  legal  systems.  Several  Member 
States  have  not  fully  transposed  the  IPPC  Directive  and  related  legislation  on 
industrial emissions by the required deadlines. The Commission will therefore pursue 
all necessary actions, including through infringement proceedings, to ensure full and 
correct transposition of the legislation. 

Action 2. Support Member States in cutting unnecessary administrative burdens 

The  Commission  recognises  that  unnecessary  and  disproportionate  administrative 
burdens  can  have  a  real  economic  impact,  as  well  as  being  an  irritant  and  a 
distraction for business, and it is committed to reducing the administrative burden at 
EU  level  of  existing  legislation  on  industrial  emissions.  Furthermore,  there  are 
significant opportunities to cut administrative costs at Member State level in addition 
to those achieved at EU level. 

To address these issues the Commission will organise an information exchange with 
Member  States  on  the  establishment  of  specific  Action  Programmes  on  reducing 
unnecessary  administrative  burdens  at  Member  State  level  in  respect  of  the 
permitting and control of IPPC installations.  

These  specific  Action  Programmes  will  be  based  on  the  administrative  costs 
measurement exercise currently being conducted by the Commission in collaboration 
with  Member  States  as  part  of  the  Action  Programme  for  Reducing  Administrative 
Burdens in the EU7. 

Action 3. Support Member States in their implementation of the legislation 

The  Commission  recognises  that  successful  implementation  of  industrial  emissions 
legislation requires an effective exchange of information between Member States in 
order to ensure consistency of approach and also to promote best practice. 

The Commission will reinforce its efforts to support Member States and competent 
authorities  across  the  EU.  This  will  include  aspects  of  enhanced  information 
exchange, guidance development, visits to authorities and training. This support will 
continue throughout the introduction and implementation of the revised legislation. 

Action  4.  Enhanced  monitoring  and  compliance  checks  of  the  application  of  the 
legislation on industrial emissions 

The  effective  implementation  of  industrial  emissions  legislation  requires  a  robust 
system  of  monitoring  and  compliance  checks  to  be  in  place  to  ensure  that  industry 
complies with environmental requirements, as well as to reassure the public that their 
health and environment are being offered the protection required. 

The  Commission  will  continue  to  monitor  the  number  of  IPPC  permits  issued  and 
updated and, where required, investigate the system of monitoring and inspection at 
IPPC installations. Such investigation will cover specific industrial installations and 
sectors, the use of general binding rules, and the analysis of complaints. 

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COM(2007)23 

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Action  5.  Improve  data  collection  for  review  of  BREFs  and  create  stronger  links 
with the Research Framework Programme 

The permit conditions, including emission limit values (ELVs), used in IPPC permits 
must  be  based  on  BAT  as  defined  in  the  IPPC  Directive.  To  help  the  licensing 
authorities and companies to determine BAT, the Commission organises an exchange 
of  information  between  experts  from  the  EU  Member  States,  industry  and 
environmental  organisations.  This  results  in  the  adoption  and  publication  by  the 
Commission of BAT Reference Documents (BREFs). 

The review of the BREFs will continue, based on the agreed work programme and in 
close  cooperation  with  stakeholders.  The  guidelines  established  on  the  improved 
collection  of  data  for  the  BREF  process  will  also  be  implemented.  Furthermore,  to 
provide fuller information on, and support for, emerging techniques the Commission 
will  ensure  closer  links  between  the  BREF  elaboration  process,  the  European 
the  Competitiveness  and  Innovation 
Research  Framework  Programme  and 
Programme. 

Monitoring and review of the Action Plan 

Regular  reports  on  the  implementation  of  the  Action  Plan  will  be  published  on  the 
internet  and  discussed  with  stakeholders.  A  further  review  of  the  Action  Plan  is 
envisaged towards the end of 2010.  

3.3. 

Development of EU rules for an emission trading scheme on NOx and SO2 

The  Commission  will  further  explore  the  use  of  IPPC-compatible,  market-based 
instruments  such  as  an  emission  trading  scheme  for  NOx/SO2,  with  a  view  to  the 
potential development of a legal instrument laying down EU-wide rules on this issue. 
This will include a full analysis of options, including the scope and the allocation of 
allowances,  and  will  look  into  potential  direct  and  indirect  impacts  for  economic 
sectors as well as drawing on the experience from greenhouse gas emissions trading. 

4. 

EXPECTED IMPACTS 

The  impact  assessment  carried  out  during  the  review  process  of  the  IPPC  directive 
and related legislation has assessed the impacts of the package of measures proposed.  

The  assessment  has  shown  that  the  environmental  and  health  benefits  linked  to  the 
proposed  measures  are  considerable.  A  higher  uptake  of  BAT,  for  instance,  would 
play a significant part in helping to close (by 30 to 70%) the existing gap between the 
2020 baseline8 for SO2 and NOx and the objectives set in the Thematic Strategy on 
Air Pollution leading to net environmental benefits of €7–28 billion per year for the 
large combustion plant sector alone. The benefits of the proposals greatly outweigh 
the  economic  impacts  (by  a  factor  of  between  3  and  14).  Furthermore,  there  is  an 
expectation of positive, but less quantifiable, impacts with regard to other Thematic 
Strategies, such as those on soil, water and waste. 

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Projection of Member States' implementation of current legislation 

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The  proposals  made  will  make  a  significant  contribution  to  the  implementation  of 
Better  Regulation  and  simplification  of  the  legislation.  Further,  the  recast  of  the 
different  pieces  of  legislation  into  a  single  Directive  is  shown  to  reduce  net 
administrative burdens by between €105-255 million per year. 

No  significant  long  term  impacts  on  competitiveness,  detrimental  social  impacts  or 
negative  effects  on  economic  growth  have  been  identified  as  a  result  of  a  higher 
uptake of BAT or of other improvements suggested. Rather the analysis shows that a 
more unified application of BAT would help to create a more level playing field and 
reduce  distortion  of  competition  within  the  EU  in  the  industrial  sectors  covered  by 
the  IPPC  Directive.  The  proposals  will  also  help  to  promote  the  development  and 
deployment of innovative technology. 

5. 

CONCLUSION  

The  package  of  policy  actions  outlined  above  and  the  accompanying  Commission 
Proposal for a new and coherent Directive on Industrial Emissions will improve the 
effectiveness  and  efficiency  of  the  legislation  by  achieving  a  high  level  of 
environmental protection, reducing administrative burden and minimising distortions 
of  competition  within  the  EU,  without  hampering  the  competitive  position  of 
European industry. 

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Annex 1: Assessment of progress (by end 2007) in implementing the 2005 Commission's IPPC Action Plan 

Description of Actions 

Assessment of progress 

Action 1: Ensure full transposition of the IPPC Directive 

IPPC  Directive  correctly  transposed  in  12  of  the  EU15  Member  States.  Conformity 
checks carried out for the EU10 and possible infringement cases to be launched. 

Action  2.  Enhanced  monitoring  of  the  progress  made 
towards  the  full  implementation  of  the  IPPC  Directive  by 
30 October 2007 

Action 3. Compliance checks 

Close monitoring by the Commission of the number of permits issued or updated. 

Assessment  by  the  Commission  of  the  permitting  and  operating  conditions  of  certain 
specific  installations  and  general  binding  rules.  Shortcomings  in  implementation 
identified and taken into account in the context of the IPPC review process. In addition, 
several infringement cases for mis-application have been launched  

Action 4. Finalisation of the first round of BREFs and start 
of their review 

Finalization  of  the  first  round  of  31  BREFs  at  the  end  of  2006;  review  of  7  BREFs 
launched; work programme established for the review of the remaining BREFs. 

Action  5.  Need  to  clarify  certain  legal  issues  and  to 
technically review the Directive 

Publication  on  the  internet  of  a  detailed  guidance  document  clarifying  aspects  of  the 
IPPC Directive based on an extensive exchange of views with Member States; guidance 
on  the  legal  and  technical  limitations  on  capacity  will  remain  valid  under  the  revised 
Directive; several studies carried out to inform the review of the Directive. 

Action  6.  Assessment  of  ways  to  streamline  existing 
legislation  on  industrial  emissions  in  the  context  of  Better 
Regulation 

Carried out as part of the IPPC review process 

Action  7.  Assessment  of  the  use  of  possible  market-based 
instruments and other incentives 

Carried out as part of the IPPC review process 

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Annex  2:  Summary  report  on  the  implementation  of  Directive  2000/76/EC  on  the 
incineration of waste 

Background 

Directive 2000/76/EC on the incineration of waste (WID) was adopted on 4 December 2000. 
Transposition  into  national  legislation  was  due  by  28  December  2002.  From  that  date  new 
incineration  and  co-incineration  plants  have  had  to  comply  with  the  provisions  of  the 
Directive. The deadline for bringing existing plants into compliance was 28 December 2005. 

Under the terms of Article 14 of the Directive the Commission shall submit a report on the 
implementation of the Directive to the European Parliament and the Council before the end of 
2008. The first reporting from the Member States required by the Directive is due in 2009 and 
will cover the period 2006-2008. Pending this reporting, collection of data and information9 
has  been  carried  out  in  connection  with  the  review  of  the  IPPC  Directive  and  related 
legislation on industrial emissions in order to ensure a close synergy between these initiatives. 
This  Annex  summarises  the  main  results  in  order  to  fulfil  the  Commission's  reporting 
requirement. 

In the data collection exercise data on dedicated waste incinerators and cement and lime kilns 
co-incinerating  waste  have  been  gathered  from  the  respective  industry  organisations. 
Information  on  other  types  of  co-incineration  plants  has  been  gathered  from  the  Member 
States. 

Number of plants and permits  

It has been found that there are around 1 400 plants incinerating or co-incinerating waste in 
the  EU.  Fewer  than  half  of  these  plants  (39  %)  are  dedicated  waste  incinerators.  Co-
incineration takes place in a number of sectors, the most important being the energy sector (15 
%) and the cement sector (10 %). The waste streams to/in other sectors are relatively small. 
The large majority (96 %) of the plants are "existing" plants10. 

Around 20 % of the installations do not yet have the required permits due by 28 December 
2005.  However,  since  this  mainly  concerns  one  Member  State,  it  is  not  seen  as  a  problem 
related to the Directive itself. The overall compliance in terms of issued permits can therefore 
be considered as good, and the Commission will take all the necessary actions to ensure that 
all Member States comply with this requirement.  

More than 90 % of the installations covered by the WID also fall under the IPPC Directive. 
Only  three  Member  States  were  reporting  using  a  combined  permitting  strategy  for  the 
implementation of the two directives.  

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10 

Assessment  of  the  application  and  possible  development  of  Community  legislation  for  the  control  of 
waste incineration and co-incineration (Ökopol, 2007) 
Existing  plants  as  defined  in  the  WID  are  plants  for  which  a  permit  existed  or  a  permit  request  was 
made before 28 December 2002. 

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Compliance with environmental requirements 

The  assessment  of  compliance  with  environmental  requirements  has  found  that,  in  general, 
incineration  plants  meet  the  air  emission  limit  values  set  in  the  WID.  In  about  50  %  of  the 
Member States either the permits contain even stricter limit values than those required by the 
WID,  e.g.  for  air  emissions  of  dust,  CO,  HCl,  HF,  NOx,  SO2  and  Hg,  or  they  include 
additional  requirements,  e.g.  relating  to  energy  efficiency,  noise  abatement  and  accident 
prevention.  Only  a  small  number  of  permits  have  been  issued  that  include  emission  limit 
values for parameters other than the compulsory ones, e.g. PAH, PCB or zinc. 

The  possibility  of  exemptions  from  certain  requirements  has  been  applied  in  many  cases. 
Around  1 000  exemptions  from  air  emission  monitoring  have  been  granted.  On  the  other 
hand,  more  extensive  monitoring  than  that  required  by  the  WID  is  being  applied  in  some 
Member States. 

Emission control techniques 

The  Reference  Document  on  the  Best  Available  Techniques  (BREF)  for  waste  incineration 
established  under  the  IPPC  Directive  was  published  in  August  2006.  It  states  that  there  is 
continuous development of techniques which limit costs while still maintaining or improving 
environmental  performance.  The  BREF  document  lists  what  are  considered  to  be  the  best 
available techniques for waste incineration, together with a number of techniques regarded as 
emerging  techniques  and  so  far  only  demonstrated  on  a  pilot  or  trial  scale.  In  general,  the 
emission limit values in the WID are relatively close to the emissions that correspond to the 
application of the best available techniques identified in the BREF. 

Further development 

The assessment of the implementation of the WID has indicated that, whilst the Directive has 
brought significant improvements in the control of waste incinerators across the EU, several 
issues require further action: 

•  The  measurement  requirements  under  the  WID  have  been  highlighted  as 
sometimes imposing an unnecessary burden on the operators. In this respect, the 
possibility  for  the  competent  authorities  to  grant  further  exemptions  for  certain 
measurement  requirements  under  specific  conditions  has  been  considered  in  the 
Impact  Assessment  related  to  the  review  process  and  been  included  in  the 
proposal for a new single Directive. 

•  The  review  clause  of  the  WID  specifically  provides  for  an  investigation  of  the 
feasibility  of  existing  cement  kilns  co-incinerating  waste  to  observing  the  NOx 
emission limit value for new cement kilns. A cost-benefit analysis is presented in 
the Impact Assessment to the proposed Directive on Industrial Emissions, on the 
basis of which a proposal has been put forward to apply the lower limit value to 
all  cement  kilns  co-incinerating  waste.  The  lower  limit  value  would  also  bring 
consistency with the BAT associated levels presented in the BREF for the cement 
and lime sector and is proposed in the new Directive. 

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Lastly,  Member  States  and  other  stakeholders  have  highlighted  some  difficulties  with  the 
implementation  of  the  WID  which  would  not  necessarily  require  amending  the  Directive. 
Instead these may be addressed through clarification and guidance on the interpretation and 
implementation  of  the  Directive.  As  part  of  its  revised  Action  Plan  on  implementation,  the 
Commission will therefore take further steps to develop any necessary guidance documents in 
close collaboration with Member States. 

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