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Whisky distilleries take their turn in the emissions legislation queue

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As the battle to improve air quality goes on, the UK has been rolling out the EU’s Medium Combustion Plant Directive to curb harmful emissions. So, what are the implications of this legislation for medium sized businesses in the UK? 

Over one hundred million cases of Scottish whisky are distributed across the world every year. The growth in the industry and the volume of production has seen distilleries in the UK become increasingly reliant on the use of energy to ensure their businesses can keep up with demand.

The method of production has barely changed for centuries. But, as the industry begins to switch to more sustainable practices, a shift in the energy sources used to power the distilleries is taking place.

Governmental legislation around environmental protection is also driving change, with the implementation of enforceable targets. The most relevant one to the production of whisky is the Medium Combustion Plants Directive (MCPD).

The legislation explained

The purpose of the MCPD is to limit harmful emissions being pumped into the atmosphere from boilers and other stationary combustion plants in the 1-50 MWth (thermal megawatt) range. 

MCPD will regulate the concentration levels of sulphur dioxide (SO2), oxides of nitrogen (NOx), and particulate matter (PM) within process exhaust gases, as well as implementing ways to monitor emissions of carbon monoxide (CO). The limits on the levels these plants can emit depend on their type, size, age, fuel selection and operating hours.

It’s estimated that, when fully implemented, these limits will provide a 24% reduction in SO2 and 9% reduction in NOx emission targets

Made law in 2017, the MCPD regulation covers all fuel types and sets out specific Emission Limit Values (ELVs) most plants must meet by 2025. It also means that all new-build production facilities need a permit before commencing operations.

Existing plants may not require permits and testing right now, but companies are starting to realise the benefits of converting their combustion energy sources. 

The implications for distilleries

Whisky distilleries need a consistent and uninterrupted energy supply.  A review conducted by the research team at Energy Voice, estimated that Scotland’s 122 distilleries consume almost the same amount of energy each year as 250,000 British households.

Most Scottish whisky producers are in remote regions off the national energy grid.  For this reason, alternative fuel options must come with reliability of supply, in addition to cost and environmental benefits. Distillers are switching from oil to gas, in the form of liquefied petroleum gas (LPG) or liquefied natural gas (LNG).

Tamnavulin makes the switch                                                                                              

Tamnavulin distillery, owned by Whyte & Mackay, made the decision to switch to a more cost-effective, cleaner fuel solution that is liquefied petroleum gas (LPG).

The distillery has been operational since 1966 and produces over 4 million litres of single malt whisky per year. They were keen to take advantage of fuel cost savings, but also needed to ensure guarantee of supply.  

The company’s fuel requirements were assessed, and it was determined that LPG, supplied in bulk, would meet their need to comply with legislation, and deliver significant cost savings.

LPG is a lower-carbon alternative to oil with approximately 20% lower carbon intensity. Cleaner burning, it generates less CO2, SO2, NOx and PM than oil. In addition to reducing their emission levels, a gas storage system was designed to house the bulk LPG, installing a 30T mounded gas storage tank, along with the necessary pipework. 

Tamnavulin has since benefited from a 19.7% reduction in carbon emissions, and when compared to a similar distillery operating on HFO, Tamnavulin’s SO2 levels were 767 times lower, NOx 3 times lower and PM 269 times lower.

EU mulls stricter battery legislation

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The European Commission is proposing to modernise its legislation on batteries – delivering the first initiative among the actions announced in its new Circular Economy Action Plan.

The EU says batteries that are more sustainable throughout their life cycle are key for the goals of the European Green Deal and contribute to the zero pollution ambition set in it. They promote competitive sustainability and are necessary for green transport, clean energy and to achieve climate neutrality by 2050.

As such, the proposal seeks to address the social, economic and environmental issues related to all types of batteries.

It says batteries placed on the EU market should become sustainable, high-performing and safe all along their entire life cycle. This means batteries that are produced with the lowest possible environmental impact, using materials obtained in full respect of human rights as well as social and ecological standards. Batteries have to be long-lasting and safe, and at the end of their life, they should be repurposed, remanufactured or recycled, feeding valuable materials back into the economy.

The Commission proposes mandatory requirements for all batteries (i.e. industrial, automotive, electric vehicle and portable) placed on the EU market. Requirements such as use of responsibly sourced materials with restricted use of hazardous substances, minimum content of recycled materials, carbon footprint, performance and durability and labelling, as well as meeting collection and recycling targets, are essential for the development of more sustainable and competitive battery industry across Europe and around the world.

Providing legal certainty will additionally help unlock large-scale investments and boost the production capacity for innovative and sustainable batteries in Europe and beyond to respond to the fast-growing market.

The measures that the Commission proposes will facilitate achieving climate neutrality by 2050. Better and more performant batteries will make a key contribution to the electrification of road transport, which will significantly reduce its emissions, increase the uptake of electric vehicles and facilitate a higher share of renewable sources in the EU energy mix.

With the proposal, the Commission also aims to boost the circular economy of the battery value chains and promote more efficient use of resources with the aim of minimising the environmental impact of batteries. From 1 July 2024, only rechargeable industrial and electric vehicles batteries for which a carbon footprint declaration has been established, can be placed on the market.

To close the loop and maintain valuable materials used in batteries for as long as possible in the European economy, the Commission proposes to establish new requirements and targets on the content of recycled materials and collection, treatment and recycling of batteries at the end-of-life part. This would make sure that industrial, automotive or electric vehicle batteries are not lost to the economy after their useful service life.

To significantly improve the collection and recycling of portable batteries, the current figure of 45% collection rate should rise to 65 % in 2025 and 70% in 2030 so that the materials of batteries we use at home are not lost for the economy. Other batteries – industrial, automotive or electric vehicle ones – have to be collected in full. All collected batteries have to be recycled and high levels of recovery have to be achieved, in particular of valuable materials such as cobalt, lithium, nickel and lead.

The proposed regulation defines a framework that will facilitate the repurposing of batteries from electric vehicles so that they can have a second life, for example as stationary energy storage systems, or integration into electricity grids as energy resources.

The use of new IT technologies, notably the Battery Passport and interlinked data space will be key for safe data sharing, increasing transparency of the battery market and the traceability of large batteries throughout their life cycle. It will enable manufacturers to develop innovative products and services as part of the twin green and digital transition.

With its new battery sustainability standards, the Commission will also promote globally the green transition and establish a blueprint for further initiatives under its sustainable product policy.

IN FOCUS: UK carbon emissions and key legislation changes

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With environmental concerns continuing to hit headlines, governments across the globe are taking initiatives to help alleviate the situation.

The UK, in particular, has taken steps forward in recent years, and legislation continues to evolve to support emissions reduction in line with international targets.

From the way we work, to the transport we use, the impact of climate change affects every part of our day-to-day lives – so it’s important we understand the policy changes that are being made to safeguard our environment. 

Net Zero Now 

From June 2019 this year, the government’s target to cut greenhouse gas emissions and achieve ‘net zero’ status by 2050 was officially signed into law. This makes the UK the first major economy to legislate to end its contribution to global warming.[1] This latest move is a more ambitious plan than the country’s previous target of an 80% emissions reduction by 2050, taking it one step further – cutting emissions to as close to zero as possible in the same time period.

Head of Corporate Affairs and Innovation at Flogas, David Taylor, said: “With so many premises still relying on high-carbon traditional off-grid fuels like oil – and heating making such a major contribution to current emissions levels – the transition to lower-carbon alternatives is long overdue. LPG is the cleanest, most efficient and effective conventional off-grid fuel, so it is uniquely placed to help reduce emissions immediately.

“Building on this, we see biopropane (or BioLPG) as a hugely significant part of the UK’s renewable future. Produced using biological sources(such as waste, sewage and energy crops), bioLPG is chemically-identical to LPG.

This means it can be simply ‘dropped in’ to the UK’s existing, comprehensive LPG network – so it will become increasingly important as we strive to meet the UK’s new 2050 net zero deadline.”

The Clean Growth Strategy

Another key part of the UK’s move towards a carbon-neutral future is the government’s Clean Growth Strategy – a plan brought into place to help accelerate the pace of ‘clean growth’ by decreasing emissions whilst simultaneously increasing economic growth.

Most notably, the Strategy aims to reduce carbon emissions in the six areas that together make up 100% of the UK’s emissions.[2] These are:

  • Improving business and industry efficiency (25% of UK emissions)
  • Improving efficiency within our homes (13% of UK emissions)
  • Increasing the shift to low-carbon transport (24% of UK emissions)
  • Delivering clean, smart, flexible power (21% of UK emissions)
  • Enhancing the benefits and value of our natural resources (15% of UK emissions)
  • Leading the public sector (2% of UK emissions)

To turn this vision into a reality, the government has pledged to roll out lower-carbon processes, systems and technologies nationwide – doing so in the most cost-effective way possible for businesses and homes alike.

Road to Zero Strategy

Introduced in July 2018, the Road to Zero strategy outlines the government’s plans on how it intends to slash road transport emissions and build a greener infrastructure. Part of this plan will be encouraging the uptake of zero-emission cars, vans and trucks, as part of the government’s mission to tackle air pollution and deliver cleaner air across the country. Changes such as putting a stop to the sale of conventional petrol and diesel cars and vans by 2040 is one of the most significant ways in which it intends to deliver this plan.[3]

In fact, the UK government is aiming for at least 50% (and as many as 70%) of new car registrations to be ultra-low emission by 2030, with a target for 40% for new vans.[4] What this means for the UK is that we’ll begin to see a huge rise in electric charging points as the government throws it weight behind the adoption of electric vehicles (EV).

Unfortunately, whilst the government remains steadfast in its aim to reduce carbon emissions, there have been some delays introducing Clean Air Zones (CAZs) into various UK cities. Most recently, Leeds and Birmingham have experienced delays with their digital vehicle checking tools, which allow drivers to check the type of emissions their cars produce. Delays to the introduction of this software are likely to push back their plans to introduce Clean Air Zones.[5]

The Paris Agreement 

Representing a huge step forward in the united fight against climate change, The Paris Agreement was the original catalyst for many of these recent legislation changes. It saw more than 200 countries take part in the United Nations Framework Convention on Climate Change, resulting in an agreement that strengthened action for a more sustainable, low carbon future.

Essentially, all parties involved in The Paris Agreement (including the UK) have committed to limit temperature rises by no more than 2°C above pre-industrial times and, if possible, limit this further to 1.5°C.[6]

A regular five-year review will also take place to monitor progress as well as increased funding to developing countries to help keep them in line with similar national targets.


[1]https://www.gov.uk/government/news/uk-becomes-first-major-economy-to-pass-net-zero-emissions-law

[2]https://www.gov.uk/government/publications/clean-growth-strategy/clean-growth-strategy-executive-summary

[3]https://www.intelligenttransport.com/transport-news/69795/low-emission-road-zero-strategy/

[4]https://www.fleetnews.co.uk/news/fleet-industry-news/2018/07/09/government-launches-road-to-zero-strategy

[5]https://www.bbc.co.uk/news/uk-england-48679008

[6]https://unfccc.int/process-and-meetings/the-paris-agreement/what-is-the-paris-agreement