Food and Drink BREF Update - Changes in Emissions to Water

Further to our previous Food and Drink BREF Update in April, the final draft of the revised Food and Drink BREF was unanimously approved in June. The Best Available Technique Conclusions (BATc) then had to be translated, which normally takes 2 to 3 months, indicating the earliest publication date of September 2019. The date of publication will trigger the four year implementation period of the BATc and BAT-AELs under the Industrial Emissions Directive.

Our previous Updates published in January and April highlighted the Key Changes in the updated BREF.

Changes in Emissions to Water

Table 17.1 of the BREF details BAT-associated emission levels (BAT-AELs) for direct emissions to a receiving water body. This table (simplified) includes the following determinands and limits:


Implications of the Changes to Emissions to Water

Notice is drawn to the introduction of a Total nitrogen (TN) limit for emissions to water. For plants that discharge effluent to water it is possible that current waste water treatment practices and infrastructure are not designed to remove TN. Even for sites that employ biological treatment for reduction of BOD and COD it is likely that the need to reduced TN will pose issues with existing plant designs ability to achieve the proposed TN limits.

Additionally, in consequence of the recent World Wildlife Fund report that stated that targets for 75% of England’s river to meet healthy status by 2027 are ‘very unlikely’ to be met, the Environment Agency is applying increased pressure on Water Companies to improve their performance. This may have the knock-on effect of water companies requiring businesses that discharge trade effluent to improve the quality of that effluent.

Therefore, significant re-design of existing infrastructure or construction of new treatment facilities may be needed to meet the new emission limits or discharge consent limits.

For more information please contact:

Paul Wright (Technical Director - Environment Management, Permitting & Compliance) at:, or

Danny Jones (Principal – Process Engineering & Process Safety) at

Key Contacts:

Paul Wright

Danny Jones