1.Context of the Implementing Decision
Directive 2010/75/EU on Industrial and Livestock Rearing Emissions, as amended by Directive (EU) 2024/1785 (IED), is the main EU instrument to reduce emissions into air, water and land, and to prevent waste generation from large industrial installations and livestock farms (pig and poultry). The 2024 revision amended the scope of the Directive in respect to farms, extending its scope for pig and poultry farms and thereby covering the largest and most polluting pig and poultry farms in the EU, amounting to approximately 30% of pig and poultry farms. However, the new obligations do not apply to small and medium-sized pig and poultry farms, which represent 70% of pig and poultry farms in the EU. Organic pig farming is also excluded from the scope of the Directive.
The 2024 revision also introduced a specific Chapter under the IED for farms, removing them from the more general provisions of Chapter II regime applicable to industrial activities and providing a more tailored approach to mitigating emissions from the farms concerned. This Chapter includes a new simplified system covering both permitting and reporting for farms falling within the scope of the Directive allowing for a simple registration of farms, instead of having them subject to individual permits. The revision also introduced the concept of operating rules, aiming to reduce emissions and improving resource efficiency whilst ensuring a consistent Best Available Techniques (BAT) based approach to pig and poultry rearing is applied across the EU. These operating rules for rearing of poultry and pigs are commonly referred to as UCOL and are the subject of this Implementing Decision. The Commission was requested to adopt UCOL by 1 September 2026 in accordance with IED Article 70i.
The Implementing Decision establishing these rules was informed by an information exchange, explicitly required by the revised IED, through a dedicated sub-expert group (E00373/1) bringing together Member States, farming organisations, and environmental and animal welfare NGOs to provide data and comment on draft rules for livestock operations covering poultry and pig rearing. The work of this sub-group took place from November 2024 to April 2026.
This Implementing Decision sets uniform conditions for operating rules including emission limit values, the environmental performance limit values, associated monitoring requirements, pollution prevention and mitigation practices, nutritional management, feed preparation, housing, manure management, including collection, storage, processing and land spreading of manure, and storage of dead animals. All of these provisions are consistent with the use of BAT as requested by IED Article 70i(2).
This Implementing Decision also contributes to the implementation of the relevant aspects of the communication “A Vision for Agriculture and Food”, which calls for futureproofing of the agri-food sector that works hand in hand with nature. In particular it explicitly states that like no other sector, food production is based on, and inextricably linked to, nature and ecosystems. The ability of farmers to produce food in the long run and be resilient depend on resilient ecosystems, maintenance of soils, fight against pests and diseases, pollination of crops, water quality and availability, clean air and climate conditions.
The rules set out in the Implementing Decision will become applicable at installation level in 2030-2032, depending on the farm size, as set out in Article 3(5) of Directive (EU) 2024/1785.
2.Objectives and main provisions of the Implementing Decision
The objective of the Implementing Decision is to ensure uniform and efficient implementation of IED for the livestock sector (pig and poultry), in order to contribute to the achievement of a high level of protection of human health and the environment taken as a whole.
The Implementing Decision supports the implementation of best practices as the uniform operating rules are consistent with BAT.
The Implementing Decision recognises the specificities of the livestock sector in several important ways.
-It embraces the simplification requests from the sector, e.g. it does not include management systems or planning tools. It focuses on mitigation measures for preventing and minimising pollution, i.e. what farmers are expected to do in their daily operation to contribute to the achievement of the IED objectives.
-It leaves the management choices for the operation of the farms to the farmers: there is flexibility in terms of what techniques to apply provided the level of environmental protection set is ensured. In this respect, where certain measures are more cost effective at reducing emissions e.g. through feed measures to reduce emissions of ammonia, it is expected that farmers will prioritise application of these measures in the first instance rather than applying more expensive measures that address the same pollutants.
-It considers that the economic feasibility of certain techniques varies depending on the farm size. In particular, it sets proportionate requirements for farms newly covered by the scope of the IED.
-It recognises that it would not be proportionate to require the implementation of certain techniques to existing farms since this would involve the reconstruction of houses at the farm, which would not be economically feasible. It consequently sets, for existing farms, maximum values for ammonia emissions that can be achieved by adopting feeding strategies aimed at reducing emissions, which are proportionate and realistic.
-It includes flexibility. For example, when implementing requirements on maximum values of ammonia emissions to air from animal housing, farmers can balance emissions across all houses at the same farm thereby enabling the implementation of cost-effective measures by farmers.
-The Implementing Decision provides for the optional use of a system based on minimum ammonia reduction requirements at each animal house.
-The Implementing Decision adopts a progressive approach, setting the strictest requirements for those farms whose construction will be authorised or registered after the deadlines for the application of the Decision, as it will be easier for these farms to implement the most efficient techniques from the start.
Taken together, these tailored solutions embedded in the Implementing Decision will assist farmers in applying a BAT based emissions control regime in a cost-effective manner.
In addition to the general flexibilities described above others are applicable at the Member State level as follows:
-The ability to use techniques not listed in the UCOL (Article 2 / General consideration)
-The ability to establish new or different environmental performance for a technique or a combination thereof (Article 2 / General consideration)
-Application of maximum values of total nitrogen/phosphorus excreted across all animal categories on the same farm (UC 1, 3)
-Further development of monitoring systems according to Member States’ needs (UC 14 – 17)
Furthermore, flexibilities applicable at farm level include the possibilities to:
-For total nitrogen/phosphorus excreted, use higher values for Iberian/heavy pigs or when co-products (e.g. whey) are used for pig feeding (UC 1).
-For ammonia emissions, apply less stringent values for pig production for existing farms, specific farms with technical limitations, Iberian/heavy pigs, and systems enhancing animal welfare (UC 2).
-For ammonia emissions, apply less stringent values for poultry production for existing farms, specific farms with technical limitations, and mixed turkey farms (UC 4).
Flexibility provisions in UCOL are intended to mitigate risks of disproportionate effects on farms.
3.Costs and benefits of the Implementing Decision
The expansion of the scope of the revised IED leads to an increase in the number of farms covered by its scope. For the purposes of this assessment, up-to-date Eurostat data was used [ef_lsk_main] to estimate the number of farms that will need to implement UCOL. The number of pig farms covered increased from 11,390 under the 2010 Directive to approximately 29,218 under the 2024 amendment. Similarly. the number of poultry farms covered has increased from 11,004 to 21,270. Finally, it is estimated that 2,937 mixed farms (pigs and poultry) will be newly covered under the IED.
The benefits of the Implementing Decision, which may be regarded as broadly equivalent to the monetised health and environmental benefits associated inter alia with reductions in methane and ammonia emissions, are estimated at EUR 2.9 billion per year under the VOLY (Value of a Life Year) EEA damage cost model and EUR 10.3 billion per year under the alternative VSL (Value of a Statistical Life) scenario. This is contrasted against the maximum total costs of the Implementing Decision estimated at around EUR 503 – 701 million per year. These cost estimates are likely to be overestimated because UCOL embeds significant flexibilities as outlined in Section 2 of this document. The estimates, in particular at the farm level, therefore, describe a maximum-cost scenario that is unlikely to be encountered in actual implementation.
It is expected that the majority of emissions reductions under UCOL will be addressed through the application of feeding measures under Uniform Condition (UC) 1 and UC 3. The cost of applying UC 1 and UC 3 is included within the range of EUR 23–111 million per year (EUR 405 – 3625 per farm per year).
Where feeding measures alone are insufficient, measures linked to animal housing would need to be employed. In such cases, it is anticipated that farmers will prioritise the use of the lowest-cost housing techniques laid down in UCOL. Whilst existing data does not allow a fully detailed model of such costs to be applied, an expert-informed range of 10-25% of newly covered farms has been estimated as potentially needing to take housing measures in addition to feed-based measures to meet emission limit values to reflect proportionality of the imposed requirements. Concerning “specific plants” (existing plants with a deep pit combined only with nutritional management) and for a significant part of newly covered farms under UC 2 (mainly due to dedicated footnotes with specific maximum values for ammonia), which represent a large proportion of the IED pig farms, it may be reasonable to expect that the cost component linked to housing will be minimal.
Using the approach laid out above, the maximum cost component linked to animal housing is estimated at EUR 480–590 million per year based on a maximum cost per farm estimated to be EUR 16,711 per year for a newly covered poultry farm to EUR 34,806 per year for a newly covered pig farm. These costs represent a theoretical maximum cost for 10 – 25% newly covered farms under IED that may need to implement low emissions techniques for housing on top of nutritional management because of their current set-up.
A summary of the costs and benefits assessed is presented in Table 1 by UC. The quantified impacts described assume a change for all newly covered farms under the revised IED and improvement in those farms already in the 2010 IED scope, incurring a relative change with respect to existing practices.
Table 1: Summary of costs and benefits by UC
|
UC
|
Considerations
|
Costs
|
Benefits
|
|
UC 1 Pig diet formulations and nutritional strategies
|
Maximum values for N and P excretion are set. Special consideration is given to heavy pigs and Iberian pigs, for which higher values are set.
The UC results into changes of feeding costs, the importance of which is relative compared to the farm total operational costs.
Flexibility is provided to enable MSs to apply maximum values across all animal categories at the same farm, subject to no net increase in total N and P excretion in the farm, as this enables the implementation of cost-effective measures by farmers. This flexibility is not considered in the cost calculation.
|
EUR 11 m per year
(Cost per farm: EUR 306 per year for 2010 IED farms; EUR 438 per year for newly covered farms under IED)
|
EUR 639-1,893 m per year (applying EEA VOLY and VSL cost damages respectively)
|
|
UC 2 Pig housing design and operation
|
Maximum values for ammonia emissions from each animal house are set (distinguishing among new, existing and specific plants). Special consideration is given to heavy pigs and Iberian pigs, for which higher values are allowed. Rrecognising that the economic feasibility of certain techniques varies depending on the farm size, higher values are set for newly covered farms under the IED.
Flexibility is provided 1) to enable MSs to apply maximum values across all animal houses at the same farm, subject to no net increase in ammonia emissions from housing in the farm, as this enables the implementation of cost-effective measures by farmers; 2) to enable MSs to apply minimum ammonia reduction requirements at each animal house, provided that they ensure at least the same reduction of ammonia emissions and that they are based on scientifically established methods.
As a result of these flexibilities, it is anticipated that the majority of ammonia savings can be met in most cases through feed measures achieved through UC1. As such, a range of 10-25% of newly covered farms are estimated to need to take housing measures in addition to feed-based measures to meet housing emission limit values. This is based on consideration of discussions in UCOL meetings as well as consideration of the current implementation of 2010 IED.
|
EUR 254-337 m per year
(Cost per farm: EUR 17,391 per year for those 2010 IED farms in need of low emissions techniques in housing for UC2 compliance on top of nutritional management; EUR 31,181 per year for those newly covered farms under IED in need of low emissions techniques in housing for UC2 compliance on top of nutritional management)
|
EUR 412 - 1,616 m per year (applying EEA VOLY and VSL cost damages respectively and considering different range of potential uptake in newly covered farms)
|
|
UC 3 Poultry diet formulations and nutritional strategies to be used
|
Maximum values for N and P excretion are set.
The UC results into changes of feeding costs, the importance of which is relative compared to the farm total operational costs.
Flexibility is provided to enable MSs to apply maximum values across all animal categories at the same farm, subject to no net increase in total N and P excretion in the farm, as this enables the implementation of cost-effective measures by farmers. This flexibility is not considered in the cost calculation.
|
EUR 6 m per year
(Cost per farm: EUR 337 per year for 2010 IED farms, 188 EUR per year for newly covered farms under IED)
|
EUR 252 - 752 m per year (applying EEA VOLY and VSL cost damages respectively)
|
|
UC 4 Poultry house design and operation
|
Maximum values for ammonia emissions from each animal house are set (distinguishing among new and existing plants). Higher values are set for existing plants with infrequent manure removal (in case of deep litter with a manure pit), in combination with a measure achieving a high dry matter content of the manure.
Flexibility is provided 1) to enable MSs to apply maximum values across all animal houses at the same farm, subject to no net increase in ammonia emissions from housing in the farm, as this enables the implementation of cost-effective measures by farmers; 2) to enable MSs to apply minimum ammonia reduction requirements at each animal house, provided that they ensure at least the same reduction of ammonia emissions and that they are based on scientifically established methods.
As a result of these flexibilities, it is anticipated that the majority of ammonia savings can be met in most cases through feed measures achieved through UC3. As such, a range of 10-25% of newly covered farms are estimated to need to take housing measures in addition to feed-based measures to meet housing emission limit values. This is based on consideration of discussions in UCOL meetings as well as consideration of the level of housing techniques that are considered to have been fitted in animal housing as a result of 2010 IED.
|
EUR 226-253m per year
(Cost per farm: EUR 18,939 per year for those IED 1.0 farms in need of low emissions techniques in housing for UC4 compliance on top of nutritional management; 16,306 EUR per year for those newly covered farms under IED in need of low emissions techniques in housing for UC4 compliance on top of nutritional management)
|
EUR 224 - 1,006 m per year (applying EEA VOLY and VSL cost damages respectively and considering different range of potential uptake in newly covered farms)
|
|
UC 5 Animal house design and operation
|
No maximum values specified.
Costs assumed to be in scope of other UCs (UC 2, 4., 10, 11, 12, 13)
|
Not estimated - linked to other UCs
|
Not estimated – linked to other UCs
|
|
UC 6 Manure storage
|
The UC specifies that coverage of slurry stores should ensure the highest environmental performance with flexibility provided for temporary solid manure heaps and for earth-banked storage.
|
EUR 1,143 m per year
(Cost per farm: EUR 2176 per year for 2010 IED pig farms, EUR 367 per year for 2010 IED poultry farms, EUR 3187 per year for newly covered pig farms under IED, EUR 217 per year for newly covered poultry farms under IED)
|
EUR 1,419 - 5,044 m per year (applying EEA VOLY and VSL cost damages respectively)
|
|
UC 7 On-farm processing of manure
|
Only applicable to farms implementing manure processing.
The costs are concluded to not be significant based on qualitative assessment and the fact that the requirement applies to a small number of IED installations processing manure on farm.
|
Not estimated - Costs across the EU concluded to not be significant based on qualitative assessment
|
Not estimated - Costs savings across the EU concluded to not be significant based on qualitative assessment
|
|
UC 8 On-farm land spreading of manure
|
Only applicable to land spreading of manure implemented within the IED installation.
Cost concluded to not be significant based on qualitative assessment and the fact that the requirement applies to a small number of IED installations where manure land spreading occurs within their boundaries.
|
Not estimated - Costs across the EU concluded to not be significant based on qualitative assessment
|
Not estimated – Costs savings across the EU concluded to not be significant based on qualitative assessment
|
|
UC 9 On-farm storage of dead animals
|
Cost concluded to not be significant based on qualitative assessment
|
Not estimated - Costs across the EU concluded to not be significant based on qualitative assessment
|
Not estimated - Costs benefits across the EU concluded to not be significant based on qualitative assessment
|
|
UC 10 Odour emissions and/or odour impact
|
Covered by UC 2, 4, 5, 6, 7 and 8 for animal housing and manure storage and management more generally.
Cost concluded to not be significant based on qualitative assessment.
|
Not estimated - Costs across the EU concluded to not be significant based on qualitative assessment
|
Not estimated
Cost savings /benefits expected
|
|
UC 11 Noise emissions and/or noise impact
|
Cost concluded to not be significant based on qualitative assessment. Potential effects on noise pollution are captured by the Environmental Impact Assessment process and are generally assumed to have been factored into the location of equipment on sites.
|
Not estimated - Costs across the EU concluded to not be significant based on qualitative assessment
|
Not estimated - Cost savings /benefits expected
|
|
UC 12 Water to be used efficiently and waste water properly managed.
|
Cost concluded to not be significant based on qualitative assessment.
|
Not estimated - Costs across the EU concluded to not be significant based on qualitative assessment
|
Not estimated - Cost savings for farmers are expected
|
|
UC 13 Energy to be used efficiently.
|
Cost concluded to not be significant based on qualitative assessment
|
Not estimated - Costs across the EU concluded to not be significant based on qualitative assessment
|
Not estimated - Cost savings for farmers are expected
|
|
UC 14 -20 Monitoring
|
With the exception of UC 16, no significant change from IRPP BATC. UC 16 is a new requirement - not present in IRPP BATC, which will therefore impact on all farms in the IED scope.
The wide range is due to the use of standard monitoring costs for all IED installations as the basis for calculations (with a certain reduction in the upper value). As the monitoring data is calculated rather than measured, the lower end is more likely to reflect reality.
|
EUR 5 million – 93 million per year (covering UC 14 – 20) across the EU
|
Not estimated – cost savings/benefits associated to compliance verification and enhancing the knowledge basis
|
It should be noted that the proposal for revised IED summarised the expected impact of the amendment to the IED as follows: “The measures with the largest impact were identified as extending the scope to cover cattle farms and a larger number of pig and poultry farms. The monetised health and environmental benefits from reduced methane and ammonia emissions are valued at over EUR 5.5 billion per/year, while the compliance costs are EUR 265 million and administrative costs (administrations and operators) are EUR 223 million, resulting in a very beneficial cost-benefit factor of 11.”
The figures from COM(2022) 156 final are not directly comparable with the analysis provided in this Staff Working Document. This is because:
-The scope of the final 2024 Directive differs significantly from that of the initial Commission proposal of 2022;
-The purpose of the assessment in COM(2022) 156 was to determine the costs and benefits related to the extension of the scope of the IED and did not examine the costs and benefits for measures related to farms already falling within the scope of the Directive;
-The analysis provided in this paper uses more recent farm statistics from EUROSTAT; and
-The contents of the final rules were unknown at the time of the Commission’s proposal.
Any comparison between the expected impacts of the proposal for the revised IED and the UCOL costs and benefits should consequently be interpreted with caution.
4.Methodology used for the cost and cost-saving assessment and associated uncertainties
The baseline was formulated according to the number of farms in scope of the IED, distinguishing between those covered under the 2010 IED and newly covered farms under the revised IED, with assumptions on baseline technique adoption taking into account existing livestock permitting regimes already applied in Member States. Quantitative analysis was modelled for UC 1-4 and UC 6 using GAINS data. Techniques in GAINS were reviewed to establish linkages with UC. This review also identified limitations where techniques in GAINS do not align well with UC. GAINS model data on emission factors by Member State, pollutant, and animal type as well as on costs and abatement efficiencies for techniques were extracted and supplemented by data from wider literature review. Assumptions were made on the level of uptake of new techniques driven by the implementing decision and costs and cost-savings calculated.
The following uncertainties and limitations apply to the findings presented.
-The exact numbers of farms within the scope of the revised IED (newly covered farms) may be over or under-estimated due to lack of information, notably due to the lack of granularity of LSU brackets in Eurostat. Similarly, numbers of animal heads associated with both 2010 and revised IED farms may also be over or under-estimated also due to limitations in Eurostat LSU bracket granularity. Estimates of number of farms is a core assumption influencing the results as it determines the overall uptake of techniques. Similarly, number of animal heads is also a core assumption as it is the metric through which costs and benefits are assessed in GAINS (costs and emissions per unit of activity, i.e. million animal heads in the case of pig and poultry farms). Finally, numbers of mixed farms are considered however not used to calculate costs and cost-savings, so there is an under-estimate on that basis.
-Information on baseline uptake of techniques in both 2010 and revised IED farms is a core uncertainty which has a key influence on results as it impacts the assumption on number of technique uptake driven by UCOL in the modelling. In the case of newly covered farms, a review of Member State permitting regimes and implementation of wider legislation such as the Nitrates Directive and National Emissions reduction commitment Directive was used to identify partial alignment with the UCOL, and in those cases a 50% reduction in costs and cost-savings was modelled. This is a broad assumption which may over or under-estimate the baseline implementation of techniques in Member States and therefore the overall costs and cost-savings. Finally, the extent to which operators will prioritise lowest cost techniques is not captured in the modelling and so costs may be over-estimated.
-Consideration of uncertainty was undertaken in a number of ways (damage costs, consideration of ranges of techniques costs and abatement efficiencies, reflecting ranges in uncertainty of assumptions e.g. on 10-25% of farms needing to implement housing techniques. Multiple sources were considered in some cases for sense-checking, for example use of wider literature for costs of techniques, and comparison with existing assessments to compare achieved cost-effectiveness of techniques.
-As outlined earlier in this document, costs and benefits associated to techniques in UCOL are likely to be over-estimated as a result of the flexibilities granted for Member States.