ZDHC acknowledges that the EU BAT BREF 2007, used in the Changing Market’s VSF sustainable chemical management target setting, was a good starting point to determine the MMCF producers’ goals for 2023. Since ZDHC’s release of the MMCF Guidelines V2.2 to V3.0, we believe we have created a global implementation roadmap for the MMCF industry’s sustainable chemical management and tried to align with the latest EU BAT BREF. Within this roadmap MMCF producers are guided towards standards set by the EU BAT BREF’s best-available techniques. While the ZDHC MMCF Guidelines provide clear progress milestones, identified in consultation with MMCF producers from different regions.
In addition, one needs to understand the purpose of the publications. The EU BAT BREF serves as a reference document to issue operating permits for industrial installations that have potential of significant pollution in the EU region. Whereas the ZDHC MMCF Guidelines specifically targets the global MMCF industry’s chemical management.
ZDHC believes it is important to take into account all MMCF producers’ chemical management journeys, wherever they may be, whilst also setting ambitious targets for everyone to reach.