REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on progress in implementing Regulation (EC) 166/2006 concerning the establishment of a European Pollutant Release and Transfer Register (E-PRTR)
Date: 2013-03-05
Institutions: European Commission
Subjects: EU emission allowance, EU environmental policy, Internet address, access to EU information, data processing, disclosure of information, environmental monitoring, industrial pollution, reduction of gas emissions

EUROPEAN 
COMMISSION 

Brussels, 5.3.2013  
COM(2013) 111 final 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on progress in implementing Regulation (EC) 166/2006 concerning the establishment of 
a European Pollutant Release and Transfer Register (E-PRTR) 

(Text with EEA relevance) 

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REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on progress in implementing Regulation (EC) 166/2006 concerning the establishment of 
a European Pollutant Release and Transfer Register (E-PRTR) 

(Text with EEA relevance) 

TABLE OF CONTENTS 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE 
COUNCIL on progress in implementing Regulation (EC) 166/2006 concerning the 
establishment of a European Pollutant Release and Transfer Register (E-PRTR) ......................  

1. 

2. 

3. 

3.1. 

3.2. 

3.3. 

4. 

4.1. 

4.2. 

4.3. 

4.4. 

4.5. 

5. 

5.1. 

5.2. 

5.3. 

6. 

Background and introduction....................................................................................... 3 

About this assessment .................................................................................................. 3 

Status of implementation of the Regulation at EU level.............................................. 4 

E-PRTR website........................................................................................................... 4 

Data flow and quality assurance at the EU level.......................................................... 5 

Commission guidance .................................................................................................. 5 

The status of implementation of the E-PRTR at Member State level.......................... 6 

General aspects............................................................................................................. 6 

Releases to air .............................................................................................................. 6 

Releases and transfers to water .................................................................................... 7 

Releases to land............................................................................................................ 7 

Transfer of waste.......................................................................................................... 7 

Scope for further improving the implementation of the E-PRTR................................ 7 

Enhancing quality of data and user confidence............................................................ 8 

Improving data use and exchange ................................................................................ 9 

Further examination of the legal basis of the E-PRTR and links with other legislation9 

Conclusion ................................................................................................................... 9 

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1. 

BACKGROUND AND INTRODUCTION 

Pollutant  release  and  transfer  registers  provide  public  access  to  emissions  data 
concerning  releases1  and  off-site  transfers2  of  pollutants  and  waste  and  their  trends 
for the most polluting industries. As such, they can assist public and private decision 
makers with the setting of priorities for cost-effective emissions reduction strategies 
as well as demonstrating progress in reducing pollution. Such registers can also assist 
in  the  monitoring  of  progress  and  compliance  with  certain  national,  EU  or 
international obligations or agreements.  

Regulation (EC) 166/2006 established the European Pollutant Release and Transfer 
Register  (E-PRTR)  that  implements  the  UNECE  PRTR  Protocol  to  the  Aarhus 
Convention3 in the EU. It builds upon and expands the European Pollutant Emission 
Register (EPER) that was previously established in 2000.  

The E-PRTR's main objective is to provide access to environmental information on 
the largest industrial facilities. Reporting obligations for emissions are linked specific 
types of industrial activity and pollutant thresholds set out in the Regulation with a 
view to address the major sources of industrial pollution, notably activities covered 
by  Directive  2008/1/EC  on  Integrated  Pollution  Prevention  and  Control.  Reporting 
covers data on releases of any of the listed pollutants into the environment as a result 
of any human activities, whether deliberate, accidental, routine or non-routine, at the 
site of the facility and above the prescribed thresholds. The reported values are to be 
based  on  the  best  available  information  from  measurements,  calculations  or 
estimations. 

Article 17 of the E-PRTR Regulation calls on the Commission to review the Member 
States'  emission  reports  submitted  through  the  E-PRTR  and,  more  generally,  to 
provide an assessment of experience gained during the first three years of operating 
the  register.  This  Report  covers  the  first  three  years  of  implementation  of  the  E-
PRTR. 

2. 

ABOUT THIS ASSESSMENT 

First  E-PRTR  data  for  2009  were  made  available  in  May  2011  on  a  dedicated 
website4, at which point data covering three years was available and this assessment 
could begin. Datasets and tools to ensure the quality of the data were established with 
the  assistance  of  the  European  Environment  Agency  (EEA).  Information  on  the 
implementation  of  the  E-PRTR  at  a  national  level  and  on  data  reporting  has  been 
collected  from  Member  States  with  the  assistance  of  a  consultant.  Additional 
information  has  been  gathered  for  assessing  the  performance  of  the  E-PRTR 
website5.  The  EEA  has  been  associated  to  this  exercise  and  experts  from  Member 

1 

2 

3 

4 
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‘Release’ means any introduction of pollutants into the environment as a result of any human activity, 
whether  deliberate  or  accidental,  routine  or  non-routine,  including  spilling,  emitting,  discharging, 
injecting, disposing or dumping, or through sewer systems without final waste-water treatment. 
‘Off-site  transfer’  means  the  movement  beyond  the  boundaries  of  a  facility  of  waste  destined  for 
recovery or disposal and of pollutants in waste water destined for waste-water treatment. 
The Aarhus Convention on Access to Information, Public Participation in Decision-making and Access 
to Justice in Environmental Matters. 
http://prtr.ec.europa.eu/  
"Final  report,  Three  years  of  implementation  of  the  E-PRTR,  Supporting  study  for  the  European 
Commission",  Umweltbundesamt  GmbH  Austria,  commissioned  by  Directorate-General 
for 
Environment (DG ENV). 

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States  and  stakeholders  were  consulted  on  the  results  and  recommendations  of  the 
analysis  performed.  Furthermore,  in  order  to  assess  the  complementarities  and 
possible  gaps  between  the  E-PRTR  and  other  databases  the  Commission  has  also 
examined relevant existing European legislation and initiatives.  

It  should  be  noted  that  the  experience  with  the  reporting  of  the  2010  data  that  was 
posted on the web in April 2012 confirms the assessment and conclusions provided 
in this Report. 

3. 

STATUS OF IMPLEMENTATION OF THE REGULATION AT EU LEVEL 

3.1. 

E-PRTR website 

According to Article 10(1) of the Regulation, the Commission shall make the register 
publicly  accessible  by  dissemination  free  of  charge  on  the  Internet.  The  E-PRTR 
website is hosted and maintained by the EEA, allowing also the further integration of 
E-PRTR data with other data sets. It is designed to ensure maximum ease of public 
access and the information is continuously and readily accessible. 

At  present,  the  E-PRTR  website  provides  online  access  to  data  reported  by  some 
29,000  major  industrial  facilities  covering  65  economic  activities  from  the  main 
industrial  sectors6  and  provides  information  concerning  the  amounts  of  pollutant 
releases to air, water and land, as well as off-site transfers of waste and of pollutants 
in  wastewater  for  91  key  pollutants  including  heavy  metals,  pesticides,  greenhouse 
gases  and  dioxins.  In  addition  to  those  core  datasets,  which  are  the  main  point 
sources  of  pollution,  the  E-PRTR  also  contains  spatially  disaggregated  data  on 
releases from diffuse sources into air while data on diffuse emissions to water will be 
added soon.  

Analysis of the E-PRTR website user protocols and an ad hoc user survey has shown 
that the E-PRTR website is accessed by a variety of users, including public services, 
private enterprises, and the general public. In general users consider the design of the 
website  suitable  and  convenient.  They  consider  that  the  data,  in  aggregated  and 
disaggregated form, are presented in a comprehensive manner and an easy to access 
format.  These  positive  findings  have  been  echoed  by  users  outside  the  EU  and 
several non-EU countries have shown an interest in using the European system as the 
basis  for  the  development  of  their  own  national  registers.  Several  users,  however, 
suggested  that  there  remained  scope  for  further  improvement  regarding  the  user 
friendliness  of  the  webpages  (e.g.  improving  navigation  and  search  functions)  and 
more  regular  maintenance  (e.g.  to  fix  broken  hyperlinks).  Others  suggested 
streamlining the terminology used. Users and Member States agreed that contextual 
information  could  usefully  be  added  to  clarify  the  data  displayed  and  their 
comparability (e.g. method of measurement). 

Whilst the E-PRTR website is frequently used as an authoritative source of emissions 
data  accessed  by  a  variety  of  users,  with  an  average  of  590  visitors  per  day,  there 
remains a clear potential to increase the knowledge of its existence and increase the 
number of users. 

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The  nine  main  sectors  are:  energy;  production  and  processing  of  metals;  mineral  industry;  chemical 
industry;  waste  and  waste  water  management;  paper  and  wood  production  and  processing;  intensive 
livestock production and aquaculture; animal and vegetable products from the food and beverage sector; 
others. 

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3.2. 

Data flow and quality assurance at the EU level 

Pursuant to Article 5 of the Regulation, facility operators falling within the scope of 
the Regulation have to annually report specific data to the competent authority in the 
Member State in which they are based. Member States must compile and check the 
quality  of  the  reported  data  and  transmit  them  to  the  Commission  and  EEA  for 
dissemination  via  the  E-PRTR  website.  The  possibility  of  resubmission  of  data 
exists. 

An automated validation tool was developed to help Member States with validating 
E-PRTR  data  prior  to  submission  and  assure  compliance  with  the  agreed  reporting 
format.  The  validation  covers  information  such  as  the  type  of  pollutants,  the  codes 
for  industrial  sectors,  geographical  coordinates,  mandatory  checks  for  formatting, 
quantitiative  checks  of  release  or  waste  values  including  outliers,  checks  for 
conformity to confidentiality. 

During  the  first  years  of  implementation  of  the  Regulation,  the  quality  of  the  data 
included  in  the  E-PRTR  register  was  checked  by  the  EEA  through  a  process 
generally referred to as the 'informal review': 

•  Member  States  were  provided  with  detailed  feedback  concerning  the  quality 
and completeness of the data submitted. EEA checks covered an evaluation of 
the number of facilities and release reports, amounts of releases and  transfers 
reported, confidentiality claims, and accidental releases; 

• 

The  E-PRTR  data  were  subsequently  compared  with  data  reported  under 
different  reporting  obligations  (e.g.  National  Emission  Ceilings  Directive7, 
Emission  Trading  System8,  Urban  Waste  Water  Treatment  Directive9  and  the 
Waste Statistics Regulation10) to identify and address differences and potential 
inconsistencies. 

The  automated  validation  tool  and  the  possibility  for  data  to  be  resubmitted  have 
proven to be very useful for the Member States. The informal review was considered 
equally useful to promote good practice during the first years of the E-PRTR. It has 
also  proven  useful  in  helping  to  identify  inconsistencies  and  possible  errors  in  the 
reported data as well as to build good practices in quality assurance by the Member 
States. There remains a clear need for the Member States to continue to improve the 
upstream quality assurance of reported data. 

3.3. 

Commission guidance 

in  2006  a  guidance  document  supporting 

The  Commission  published 
the 
implementation  of  the  E-PRTR11  as  required  under  Article  14  of  the  Regulation 
covering  matters  such  as  who  has  to  report,  what  and  how,  including  an  indicative 
list of sectors and pollutants for which reporting of data is expected. It also provides 
helpful information to members of the public on the E-PRTR itself. All the consulted 
stakeholders  considered  the  guidance  document  to  be  extremely  useful  in  the 
reporting  process.  A  revision  of  the  guidance  might  help  in  clarifying  still  open 
issues  such  as  those  concerning  activity  descriptions  and  further  improving  the 
implementation of the Regulation. 

7 
8 
9 
10 
11 

Directive 2001/81/EC 
Directive 2003/87/EC 
Directive 91/271/EEC 
Regulation (EC) No 2150/2002 
http://prtr.ec.europa.eu/docs/EN_E-PRTR_fin.pdf 

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4. 

THE STATUS OF IMPLEMENTATION OF THE E-PRTR AT MEMBER STATE LEVEL 

4.1. 

General aspects 

All EU Member States, Norway, Iceland, Liechtenstein, Switzerland and Serbia have 
implemented the E-PRTR Regulation. 

During  the  period  2007-2009  Member  States  satisfactorily  reported  the  requested 
data.  This  is  reflected  in  the  detailed  information  available  in  the  register.  This 
outcome is encouraging also bearing in mind that setting up new reporting systems 
typically requires a certain learning process by all parties involved. Problems related 
to  missing  information  seemed  to  relate  to  specific  interpretation  issues.  Such 
difficulties related in particular to the releases to land including reporting of leachate 
from waste landfills. Some implementation difficulties reported were attributed to an 
apparent lack of resources at competent authorities to adequately check the quality of 
data  prior  to  submission  to  the  Commission.  Finally,  there  remains  an  outstanding 
issue  with  one  Member  State  concerning  the  confidentiality  of  data  under  the 
Regulation. 

According to Article 5(4) operators subject to the E-PRTR Regulation are required to 
provide competent authorities with the best available data on their pollutant releases 
and  transfers.  Furthermore,  according  to  Article  9(1)  and  Article  9(2)  of  the 
Regulation it lies within the remit of the national competent authorities to assess the 
quality of the data and whether the information provided by the individual facilities 
is satisfactory with respect to its completeness, consistency and accuracy. 

The  assessment  undertaken  indicates  that  the  E-PRTR  data  reported  had  a  varying 
degree of completeness, from consistency for the releases of major pollutants to air, 
to  less  comprehensive  reporting  of  releases  to  water  and  transfer  of  waste  to 
somewhat poor reporting of releases to land.  

Such issues may hinder the potential use of E-PRTR data both by the general public 
and by the national and EU authorities, including the possibility to fulfil other EU or 
international reporting obligations12. 

4.2. 

Releases to air 

Considering  the  increasing  need  for  more  accurate  air  quality  management  also  at 
national,  regional,  and  local  level,  the  scaling  of  national  emission  data  features 
amongst  one  of  the  largest  added  values  of  the  E-PRTR.  Reporting  of  nitrogen 
oxides,  sulphur  dioxide  and  carbon  dioxide  releases  at  the  national  level  is  mostly 
complete  and  is  found  to  be  consistent  when  compared  to  other  international 
reporting obligations or inventories. 

Reporting of the other pollutants shows, to a varying extent, some inconsistency with 
other national inventories. In some cases national reporting did not include data that 
would  have  been  expected  according  to  the  indicative  lists  of  sectors  and  expected 
pollutants  included  in  the  Guidance  Document.  This  might  reflect  either  deficits  in 
reporting,  inaccuracies  in  the  Guidance  Document,  or  specificities  of  individual 
installations. 

12 

For  example  emission  inventory  data  required  under  the  National  Emission  Ceilings  Directive,  the 
Convention  on  long  range  transboundary  transport  of  atmospheric  pollution  and  the  EU  Emission 
Trading Scheme 

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4.3. 

Releases and transfers to water 

Reporting of emissions to water is considered of acceptable quality, albeit that it is 
less complete than the reporting of emissions to air.  

Issues  with  regard  to  reporting  of  emissions  to  water  that  were  identified  relate  to 
several  pollutants,  in  particular  from  urban  waste  water  treatment  plants,  which 
show,  to  a  varying  extent,  discrepancies  with  the  releases  that  would  have  been 
expected according to the indicative lists of sectors and expected pollutants included 
in  the  Guidance  Document.  Missing  release  reports  could  be  due  to  the  absence  of 
adequate emission factors or analytical methods for routine measurements of some of 
the  Water  Framework  Directive  Priority  Substances.  Reporting  of  leachate  from 
landfills  must  also  be  clarified.  Finally,  the  limited  reporting  of  chlorpyrifos, 
tetrachloroethylene, 
isoproturon, 
hexachlorobutadiene, 
tetrachloromethane, and trichloroethylene is of particular concern. 

ethylene 

oxide, 

4.4. 

Releases to land 

In  comparison  to  emissions  to  air  and  to  water  there  are  only  a  limited  number  of 
reports of releases to land submitted by a small number of Member States. Due to the 
fact  that  other  data  sources  which  could  be  used  for  verification  are  not  publicly 
available,  no  clear  conclusions  on  releases  to  land  can  yet  be  drawn.  As  already 
noted in the Communication on the implementation of the Soil Thematic Strategy13 
the  E-PRTR  is  a  potential  important  tool  for  tracking  industrial  pollutants  and 
improvements in its implementations is encouraged. It is apparent that differences in 
the  interpretation  of  releases  to  land  by  Member  States  exist,  and  these  need  to  be 
resolved.  

4.5. 

Transfer of waste 

Reporting  of  transfer  of  hazardous  and  non-hazardous  waste  by  facilities  under  E-
PRTR has been compared to data reported for 2008 by Member States in accordance 
with  Regulation  (EC)  No  2150/2002  on  waste  statistics.  The  E-PRTR  reporting 
covers  only  transfers  of  hazardous  and  non-hazardous  waste  from  major  individual 
facilities, whereas the Waste Statistics Regulation covers entire sectors and concerns 
generation  of  selected  categories  of  waste  where  data  is  collected  by  means  of 
administrative sources, surveys, statistical estimation procedures or a combination of 
these  means.  Consequently,  the  methodologies  for  reporting  under  the  two 
instruments are different. However, this analysis has made clear that the thresholds 
set by the E-PRTR Regulation only allow the reporting of about 39% of hazardous 
waste  and  17%  of  non-hazardous  waste,  with  large  differences  between  different 
economic sectors. 

Whilst  it  is  apparent  that  lowering  the  minimum  reporting  thresholds  in  E-PRTR 
could  increase  the  degree  of  coverage  of  waste  transfers,  the  two  instruments  are 
complementary  and,  considered  together,  presently  provide  a  sufficiently  useful 
knowledge base.  

5. 

SCOPE FOR FURTHER IMPROVING THE IMPLEMENTATION OF THE E-PRTR 

Creating  an  operational  E-PRTR  is  a  challenging  undertaking  involving  a  large 
number  of  public  and  private  stakeholders.  Based  on  the  present  assessment  of  the 
first  period  of  implementation,  the  Commission  considers  that  the  Regulation  has 

13 

COM(2012) 46 

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been  relatively  well  implemented.  Subsequent  improvements  could  be  observed 
year-on-year as Member States and other stakeholders have gained experience with 
its operation. Compared to the situation before the E-PRTR Regulation was adopted, 
EU  citizens,  analysts,  policy  developers  and  decision  makers  have  now  more  easy 
access to comprehensive information on the types and quantities of emissions from 
the largest industrial activities as well as from diffuse air emission sources.  

Whilst  the  results  of  the  assessment  indicate  that  a  review  of  the  Regulation  itself 
would be premature, a number of improvements remain possible inter alia by means 
of enhanced Commission guidance documents.  

Special  attention  will  be  given  to  enhancing  the  quality  and  completeness  of  data 
reported as well as enhancing data usage. Where necessary, enforcement actions will 
be undertaken. 

5.1. 

Enhancing quality of data and user confidence 

Further  increasing  the  reliability  and  quality  of  the  Register  will  enable  enhanced 
confidence of the users and thus increase of usage.  

The  Commission  will  review  the  Guidance  Document,  in  particular  with  regard  to 
the scope of the Regulation and its interpretation.  More  detailed  definitions will be 
given (e.g. regarding releases to land, and leachate) and clarification will be included 
on  which  elements  of  the  reporting  can  be  held  confidential.  A  number  of  other 
specific issues will be addressed e.g. on sub-activities that need reporting and the list 
of pollutants expected from the various activities will be revised.  

Member States are expected to increase their efforts to assure the quality of the data 
provided.  The  E-PRTR  Regulation  places  an  obligation  on  operators  to  assure  the 
quality  of  data  and  the  competent  authority  to  assess  it.  Checks  on  completeness, 
consistency  and  credibility  of  the  data  submitted  must  be  performed  more 
comprehensively  prior  to  data  delivery  to  the  Commission.  Member  States  should 
not rely on the informal review performed by the EEA as a substitution for their own 
quality  checks  to  later  correct  reported  data.  In  the  ongoing  second  phase  of 
implementation of the Regulation the Commission will promote ownership of quality 
of data by operators and Member States. If appropriate this will be enforced by the 
use of infringement procedures.  

As  the  transfer  of  ownership  of  data  assurance  to  the  Member  States  proceeds,  the 
systematic  review  at  EU  level  of  national  data  will  be  scaled  down.  The  Member 
States are encouraged to build on the good national practices that have resulted from 
the informal review undertaken by the EEA during the first years of implementation 
of the Regulation. To help assure high quality national data the possibility of data re-
submission will be maintained. 

The Commission will continue to promote the involvement of relevant expert groups. 
The  Water  Framework  Directive  Working  Group  on  Chemical  Aspects  will  be 
encouraged to share its experience with the E-PRTR expert group in relation to the 
development  of  emission  factors  for  compounds  released  to  water.  Co-operation 
between  the  E-PRTR  expert  group  and  other  expert  groups,  such  those  on  the 
implementation  of  the  ambient  air  quality  and  the  National  Emission  Ceilings 
Directive, will also be encouraged.  

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5.2. 

Improving data use and exchange 

The  E-PRTR  website  will  be  improved  to  enhance  user-friendliness  in  accordance 
with  the  priorities  identified:  improved  functionality,  navigation  and  search 
functions, addition of technical information to the data presented, standardisation of 
terminology and links to datasets resulting from other reporting obligations. 

The Commission will exploit the available opportunities for promoting the use of the 
E-PRTR  for  scientific,  technical,  and  policy  analysis  as  well  as  for  general  public 
awareness  purposes.  Given  the  current  proposals  or  revision  of  some  reporting 
systems  for  environmental  monitoring,  the  use  and  impact  of  E-PRTR  is  likely  to 
further increase. In this context, the further implementation of Directive 2010/75/EU 
on Industrial Emissions, Directive 2004/101/EC (ETS) and the ongoing review of the 
Thematic  Strategy  on  Air  Pollution  will  offer  opportunities  to  further  develop 
synergies  across  the  dataflows.  In  particular,  synergies  will  be  sought  in  order  to 
facilitate  the  drawing  up  and  review  of  Best  Available  Technique  reference 
documents according to Commission Implementing Decision 2012/119/EU. 

5.3. 

Further  examination  of  the  legal  basis  of  the  E-PRTR  and  links  with  other 
legislation 

The Commission will again examine the need to revise the Regulation to better serve 
its goals and the interests of EU stakeholders and will give its findings in the second 
three-yearly report on the implementation of the E-PRTR that will cover the period 
(2013-2015). This will also include an evaluation of the differences in scope between 
the E-PRTR, the IED and other EU law. 

6. 

CONCLUSION 

An integrated and coherent E-PRTR is an important tool to increase the knowledge 
base  for  a  cost-efficient  and  transparent  management  of  air,  water,  and  land 
resources.  

The  establishment  of  the  E-PRTR  has  been  an  important  step  forward  in  ensuring 
greater  transparency  on  the  types  and  quantities  of  industrial  emissions  and 
environmental monitoring. The E-PRTR comprises a unique dataset covering a wide 
variety  of  pollutants,  addressing  releases  and  transfers  to  all  media  and  based  on  a 
bottom-up approach.  

The  assessment  of  the  Commission  of  the  implementation  of  the  Regulation 
demonstrates a reasonable success story. Member States came to terms with the new 
obligations in an expeditious manner to the point where data collection, assessment 
and submission to the Commission is now completed for most releases in a reliable 
fashion.  

However, there remains a need and potential for further improvements. The actions 
contained  in  this  Report  will  help  address  some  of  the  most  important  issues 
identified during the review and take the E-PRTR forward in a way that will further 
improve  its  usability  and  encourage  wider  use  of  the  important  environmental 
information  contained  therein.  Those  actions  will  be  pursued  following  an 
appropriate  degree  of  prioritisation  in  order  to  effectively  target  those  actions  of 
greatest potential benefit.  

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