BAT 2026 Checklist: is your company truly in compliance? Here is what to check.

BAT 2026 Checklist: Is your company truly in compliance? Here is what to check.

Is your company ready for Directive (EU) 2024/1785? Discover the parameters to check immediately to verify BAT 2024 compliance and how to take action before July 2026, the final deadline for compliance.

If you have arrived here, you are likely wondering if your facility would pass an inspection after the transposition of IED 2.0. Many operators are convinced they are compliant simply because they hold a currently valid authorization, but with the entry into force of the new 2024 BAT Conclusions, compliance criteria have become dynamic and much more severe.

Here are the critical points that we at EPC srl recommend you monitor immediately:

1. Is the Solvent Mass Balance (SMB) updated?

It is no longer enough to declare how much solvent was purchased. BATs (particularly for the STS and Printing sectors) require a rigorous Mass Balance. You must be able to demonstrate where every kilogram of solvent ends up: how much is recovered, how much is abated, and, most importantly, how much constitutes fugitive emissions. If your data uncertainty is high, you are at risk of sanctions.

2. Monitoring: channeled or continuous emissions?

Check your mass flows. Regulations mandate continuous monitoring for stacks that exceed certain thresholds (e.g., 4 kg/h of total organic carbon). If your plant still relies on sporadic or "one-off" sampling, you may no longer comply with the new data transparency obligations required by IED 2.0.

3. Hazardous substance substitution: do you have a plan?

Check the Safety Data Sheets (SDS) of your products. The new BATs and IED 2.0 push for the replacement of substances with specific hazard statements (such as H340, H350, H350i, H360D, H360F). If you still use mutagenic or reprotoxic compounds, the law now requires you to prove that no feasible alternatives exist or to plan for their substitution "as soon as possible."

4. Efficiency of abatement systems

The new emission ranges (BAT-AEL) are much narrower. An abatement plant that was considered "excellent" in 2020 might be barely sufficient or even obsolete today. It is necessary to test the real efficiency of the system against the new seasonal or annual limits provided by the sectoral BAT Conclusions.

What to do if you discover you are not in compliance?

If the analysis of these points reveals any gaps, do not panic: there is still time to act, but it must be used with extreme technical precision.

As an EPC (Engineering, Procurement, Construction) firm, we don’t just tell you what is wrong. We support you through a complete journey:

  • Technical-Regulatory Audit: We verify the gap between your current parameters and the new BAT limits.
  • Design and Engineering: We design custom solutions for solvent recovery or the optimization of abatement systems (RTO, adsorbers, etc.).
  • Construction and Installation: We provide "turnkey" upgrades, ensuring the final plant is fully compliant with authority requirements by July 2026.
  • AIA Revision Support: We assist you in preparing the technical documentation for the authorization review.

Don't wait for an inspection to tell you that you are out of compliance. Contact us for a feasibility study and secure the future of your company.