The proposed UK Best Available Techniques conclusions for Waste Gas for Chemicals risk imposing disproportionate costs on the UK chemical sector by applying tighter air emission limits across all permitted chemical sites. This would affect around 75% of UK chemical facilities, require compliance by late 2030 and trigger further obligations under the Common Waste Water BAT conclusions. Given the sector’s limited contribution to UK air emissions, Government should adopt a targeted, risk-based approach focused on new facilities and the highest-emitting sites.

Introduction

The Governments Consultation on UK Best Available Techniques, proposes tighter emission limits to air under Waste Gas for Chemicals (WGC) for all permitted chemical sites. This impacts 75% of all UK chemical facilities (approximately 300 manufacturing sites). Compliance is required within 4 years post publication of the BAT conclusions i.e. by late 2030. The issuance of the UK WGC BAT conclusions will also trigger compliance requirements under the Common Waste Water (CWW) BAT conclusions.

Impact To Chemical Sector

The table below illustrates the cost impact, some of which is likely to risk commercial viability of sites with 100’s of direct job losses and knock on implications for key supply chains including those critical to national infrastructure. The overall cost impact on chemical businesses within CIA membership alone is estimated to run into hundreds of millions of pounds (which is significantly more than the estimated cost within the Governments consultation) with little or no benefit for business or the environment. More importantly, these sites are trading and competing globally meaning they are unable to pass the cost to customers.

Table A – Examples of WGC compliance cost impact for the Chemical Sector (and CWW)

CompanyCost of compliance to WGC and CWW (£)

A*

WGC = 30-50 million* + OpEx costs of £1.3 million/yr

B

WGC = 12.5 million + 7.5 million for CWW

C

WGC = 1 million + 16 million for CWW

D

WGC = 5 million

E

WGC = 18 million (additional 5.9 million just spent & commissioned)

F

WGC = 10 million + OpEX costs of £0.7 million/yr

G

WGC = 0.2 million plus installation costs

H

WGC = 1.9 million plus significant new waste costs/safety risks.

I

WGC = 10 million+ OpEx costs of £2million/yr

J

WGC = 10 million+ OpEx costs of £1million/yr (for 15 years)

UK BAT WGC was last reviewed over two years ago. Since then, many UK chemical sites have continued to close (26 sites since 2021). UK chemical output has seen a 60% reduction, predominantly fuelled by a lack of competitive policy and regulatory framework.

* The chemical sector has been highly regulated since the 1990’s and is NOT a major emitter of UK VOC’s (or other air pollutants) in the UK. In 2021 total emissions from the chemical sector represented only 1.1% of the UK total across the five main National Emissions Ceilings (ammonia, nitrogen oxides, sulphur oxides, non-methane volatile organic compounds, and particulate matter).

The need for a targeted, risk-based approach

Given the significant contraction across the UK chemical sector as well as emissions from the sector accounting for just 1%* of UK air emissions, CIA are urging the Government to avoid blanket implementation of WGC across the whole chemical sector and instead adopt a targeted, risk-based approach, focused on new facilities and existing sites with the highest emissions. This risk-based approach would much better support the sector along with UK growth and resilience aspirations. Failing that, we ask Government that regulator flexibility beyond a derogation process in instilled so that consistent and pragmatic decisions can be taken where little or no benefit to the environment can be achieved (e.g. some sites have calculated that their carbon emissions and with that the carbon bill will triple due to having to install a thermal oxidiser to meet WGC limits).

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