BAT for Ukraine - Improving the framework conditions for the implementation of the European Directive 2010/75/EC on industrial emissions and promoting the use of best available techniques (BAT) in industry

Under the Association Agreement with the EU, Ukraine is obliged to implement the EU Industrial Emissions Directive. The project improves the administrative and technical capacities of government bodies and plant operators to implement the Directive. This reduces resource and energy consumption during the operation and decommissioning of industrial plants. To this end, the project supports the Ukrainian government in further developing the relevant legal framework, as well as in strengthening and developing institutional and administrative structures. Targeted technical capacity-building for specialist and management staff at the Ministry and the Environmental Inspectorate, as well as for industrial plant operators, ensures that the changes are sustainably embedded. The project provides financial incentives to industrial plant operators for the piloting and demonstration of BATs.

Project data

Countries: Ukraine
IKI funding: 10,000,000.00 €
Duration: 02/2019 till 06/2027
Status: open
Implementing organisation: Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH
Political Partner: Ministry of Economy and Environment of Ukraine

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State of implementation/results

Following several years of preparation and with the support of the project, Law No. 3855-IX on the transposition of the EU Industrial Emissions Directive (2010/75/EU, or IED for short) was passed. The Act officially came into force on 8 August 2025. This milestone brings Ukraine into line with EU standards and introduces a modern system of integrated environmental permits based on Best Available Techniques (BAT), as well as a comprehensive approach to the management of industrial emissions.
The drafting of the secondary legislation required for the full implementation of BAT in Ukraine is already well advanced. With the support of the project, three key pieces of secondary legislation were adopted in 2026: 1) the state target programme to support companies introducing Best Available Techniques by 2030; 2) the template for operators’ compliance reports and the reporting requirements for integrated environmental permits; 3) the template for the baseline report (which forms part of the application for an integrated environmental permit), the content requirements and the methodology for assessing soil and groundwater contamination. In total, 18 regulations were adopted in 2026 pursuant to Law No. 3855-IX, whilst two further draft laws are still awaiting inter-ministerial approval.
Following the launch of the register for integrated environmental permits via the digital platform supported by the project, the project continued to facilitate its operation and further development. The register was used to process the first application for an integrated environmental permit, marking the transition from system development to practical implementation. Technical improvements continued on the basis of the experience gained during the first implementation phase. Preparations are currently under way to hand over the IT system to MinEconomy.
The project has developed a funding mechanism to support Ukrainian companies in implementing Best Available Techniques. The plan includes modernisation measures to reduce emissions to air and water and to treat on-site waste in food production and metal manufacturing companies, as well as to improve energy efficiency in paper and cardboard production. To date, a total of two funded projects have been completed (Zhytomyr Cardboard Factory and Radyvylivmoloko), whilst two further projects (Kremenchuk Steel Works and LVN Limited) are currently being implemented.
Following the training session held in 2025 on the new, integrated permitting system, an online training course was held on 28 July 2026 on the so-called ‘Baseline Report’ (AZB for short) as part of the application for an integrated environmental permit. The training was aimed at operators of industrial installations, representatives of government authorities at national and regional level, and other stakeholders involved in the reform. It provided an overview of the preparation and submission of the AZB in accordance with the requirements of the legislation on integrated prevention and control of industrial pollution, as well as the recently adopted methodology for assessing soil and groundwater contamination.
With the support of the project, a high-level round-table discussion on the introduction of the unified environmental permitting system took place in Kyiv on 27 May 2026, organised jointly with the Ukrainian Ministry of Economy and Environment. The event brought together the Minister, the Deputy Head of Mission at the German Embassy in Ukraine, representatives of the Verkhovna Rada, regional and local authorities, businesses and the expert community to discuss the future simplified and digitised permitting framework for small and medium-sized enterprises. Although these enterprises operate below the thresholds set out in Directive 2010/75/EU on industrial emissions, they nevertheless contribute significantly to overall emissions. The round table also reaffirmed its support for the project’s ongoing efforts to align Ukraine with the EU environmental acquis by complementing the implementation of the integrated environmental authorisation system introduced under the Law on the Integrated Prevention and Control of Industrial Pollution.

Latest Update:
11/2026