7/10/2005
IPPC Directive - Annex 1
CIAA position on the interpretation of Annex 1 of the IPPC Directive

Original 96/61/EC Directive Text

6.4
(b) Treatment and processing intended for the production of food products from:
•  animal raw materials (other than milk) with a finished product production capacity greater than 75 tonnes per day.
• vegetable raw materials with a finished product production capacity greater than 300 tonnes per day (average value on a quarterly basis).
(c) Treatment and processing of milk, the quantity of milk received being greater than 200 tonnes per day (average value on an annual basis).

Proposed Revised Text

6.4 (b) Processing of raw materials (processed and unprocessed) used as ingredients for the production of products intended for human and animal consumption from:
• animal raw materials (other than milk and milk products) with an animal content of the actual finished product output (excluding packaging) greater than 75 tonnes per day (average value on annual basis).
•  vegetable raw materials with an actual finished product output (excluding packaging) greater than 300 tonnes per day (average value on annual basis, except for seasonal vegetables (average value based on operating days per campaign period).
•  a mixture of animal raw materials (other than milk and milk products) and vegetable raw materials with

an animal content of the actual finished product output (excluding packaging) greater than 75 tonnes per day (average value on an annual basis).

OR

with an animal content of the actual finished product output (excluding packaging) less that 75 tonnes per day (average value on an annual basis), with an actual finished product output (excluding packaging) greater than 300 tonnes per day (average value on an annual basis, except for seasonal vegetables (average value based on operating days per campaign period).

6.4 (c) Processing of milk and/or milk products, the quantity of milk and/or milk products received being greater than 200 tonnes per day (average value on an annual basis).

CIAA reasons for technical amendments Annex 1 section 6.4

6.4. (b)
•  Removal of the word “treatment” CIAA believes that ”processing” covers treatment operations so the word “treatment” is unnecessary.
•  Addition of the word “processed and unprocessed”. To make the interpretation of “raw materials” clearer.
•  Addition of word “ingredient” to ensure only raw materials which form part of the product are included. E.g. cleaning agents, cooling water are excluded.
•  Addition of words “for human and animal consumption” to ensure no ambiguity in the meaning of “food”.
•  Addition of the words “excluding packaging” as packaging is peripheral to the main manufacturing operations and should not therefore be included in the calculation of production capacity.
•  A more pragmatic approach for defining thresholds. Different products can be produces on the same production line on a hourly, daily or monthly basis with significantly different production outputs. It can therefore be extremely difficult to determine the design or theoretical capacity for any one production unit. CIAA proposes a more pragmatic and workable approach based on actual production output averaged over a year.
•  For seasonal vegetables the CIAA proposes that the average production output should be based on the operating days of the campaign period rather than an arbitrary basis of a quarter.
•  The 3rd indent provides criteria for a product containing a mixture of animal and vegetable raw materials. The criteria used are based solely on the thresholds for animal and vegetable raw materials i.e. 75 and 300 tonnes per day respectively. If the quantity of animal raw material in the actual finished product output is greater than 75 tonnes per day then the lower threshold applies; if this quantity is less than 75 tonnes per day but the total actual finished product output is greater than 300 tonnes per day then the higher threshold applies.
•  Clarification of the fact that packaging should not be included in the calculation of actual finished product output. Packaging should be excluded because installations do not typically calculate finished product output (nor capacity as per the current Directive wording) to include this. Moreover, including packaging would introduce wide distortions between sectors, penalizing those reliant on heavier materials such as metals and glass. CIAA is not aware of any member state interpreting the Directive to require installations to count packaging towards capacity tonnage.

6.4. (c)

•  Regarding dairy processing, all milk and/or milk products (whey, cream, dairy and non-dairy creamers) > 200 tonnes/day should be within the scope of the IPPC. The new wording allows to avoid misunderstanding on raw materials (ingredients, chemicals, etc.) and to remain as close as possible to the present text.