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Figure 11. Three approaches for bringing circular economy issues into the EU BREF process

50  5. POSSIBLE SOLUTIONS AND RECOMMENDATIONS FOR INTEGRATING VALUE CHAIN CONCEPTS

 when evaluating candidate BAT, consider cross-sectoral effects and collaborate with upstream and downstream partners to also identify techniques that will reduce environmental impacts elsewhere in the value chain (Anderson, Natalia et al, 2018[3]). The HAZBREF project further proposes three approaches for bringing circular economy objectives into the process of developing EU BREFs, as presented in Figure 11 (Dahlbo et al., 2021[39])  a production waste approach, involving BAT criteria concerning materials, chemicals and processes affecting the quality of production waste;  a secondary raw material approach, involving BAT criteria related to secondary raw materials; and  a product end-of-life approach, involving BAT criteria on materials, chemicals and processes affecting the product recyclability.

Figure 11. Three approaches for bringing circular economy issues into the EU BREF process

Source: (Dahlbo et al., 2021[39])

A circular economy-based approach could possibly help incorporate the consideration of value chain aspects when developing BREFs, for example by introducing criteria in the assessment of techniques that concern reduced waste generation, the reuse of materials downstream in the value chain, and regeneration of natural systems. This could be done in line with VITO’s (Huybrechts, D et al, 2018[3]) proposals for how to take a value chain approach to establishing BAT Reference Documents (see Box 3 below). In addition, the Ministry of Environment and Food of Denmark (2016[52]) has investigated whether the EU BREFs contribute to resource efficiency in industries. Their report emphasises that some of the EU BREFs already include approaches to ensure resource efficiency; however, there is potential for making the BAT conclusions more focussed upon, or accommodating of, resource efficiency. The Ministry suggests that

BEST AVAILABLE TECHNIQUES (BAT) FOR PREVENTING AND CONTROLLING INDUSTRIAL POLLUTION © OECD 2022

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