Chapter 2. How to charge taxes for air pollutants from stationary sources?

Kazakhstan’s industrial operators are subject to pollution charges for their emissions below and above their relevant emission limit values (ELV). This is part of a quite unusual system of “paying to pollute”, which originated before 1991. The pattern continues in various forms in the environmental regulatory framework of many other post-Soviet states.

Considering this command-and-control heritage, this chapter explores how Kazakhstan can incorporate elements of environmental policies from OECD member countries. Specifically, it asks what incentives can hasten the transition towards a scheme promoting the adoption of best available techniques to reduce pollution, in line with the Polluter-Pays Principle.


2.1. Introduction

As evidenced in (OECD, 2011[1]) and (OECD, 2017[2]), among other studies, environmentally related taxation is dominated by energy taxes, particularly those on fuels used in road transport. Quantitatively, the taxation of industrial air pollutants is a minor fraction of this sum. And it is largely the preserve of a small number of OECD member countries in Northern Europe (especially the Netherlands, Denmark, Sweden and Norway) or in Central Europe.

The rationale for their design is grounded in economic theory about how to “internalise” rather than “externalise” the true cost of environmental damage. In this theory, the government taxes a given item at a rate that reflects the costs of the environmental damage it has caused. This approach obliges business and consumers to confront the true cost to society of their production or consumption choices. A recent OECD report to the G7 Environment Ministers concluded that “to align taxes more closely with marginal external costs” is indeed “a pragmatic way forward” (OECD, 2017[2]).

From this relatively limited experience of OECD members in designing taxes on industrial air pollutants, two main theoretical types can identified:

  • a tax rate aimed at a targeted reduction in emission levels of a given pollutant and set at or close to the estimated marginal cost of abatement required to reach that target

  • a tax rate aimed at raising the relevant price to the corresponding marginal social cost, and set at or close to the outstanding marginal external cost: that is, the as-yet-unpriced marginal social cost of emissions of the given pollutant.

2.2. Comparative analysis

Pollution taxes in Kazakhstan for emissions within and above the ELV are the backbone of economic instruments and practices that are administratively heavy, inefficient and controversial (OECD, 2017[3]). Their main purpose is to raise revenues without any evidence of a relation to a marginal cost of abatement or to the corresponding marginal social cost.

At the origin, the system of pollution taxes relied on a formula reflecting the cost necessary to prevent and compensate for damages caused by emissions (discharges) of pollutants into the natural environment. Annex 1 provides an historical perspective on the evolution of the mechanism to collect payments for emissions. The aim to raise revenues was explicitly contained in the links with the national and regional environmental programmes and the plans to eliminate effects of environmental pollution. Over time and in practice, as noted by several analyses (UNECE, 2008[4]; OECD, 2017[3]; OECD, 2017[5]), the criteria for determining specific levels of pollution charges became obscure. Some enterprises have consistently complained about the lack of transparency of environmental regulations. They have expressed concerns that the taxes and fines were imposed to exert pressure and obtain additional funds (OECD, 2014[6]).

And Kazakhstan is not balancing the usage of pollution taxes with incentives that encourage companies to invest in techniques associated with reducing industrial air pollution.

In OECD member countries, the process for setting ELV is far more transparent than in Kazakhstan. Evidence is growing that the ELV in Kazakhstan might be too lenient, particularly compared to the European Union’s ELV for large combustion plants. In Kazakhstan, regulators have the excessive burden of discretionary power, while operators have opportunities to engage in strategic deception and regulatory capture.

As examined in OECD (2012[7]), the excessive emphasis on revenue raising continues to distort the functions of the individual monetary tools in the Eastern Europe, Caucasus and Central Asia region. In Kazakhstan, the practice erodes the government’s credibility in implementing these instruments and undermines their environmental effectiveness. This report makes several recommendations to address these concerns:

  • Taxes for emissions within and above the emission limits should be aimed at reducing releases of priority non-hazardous pollutants.

  • Non-compliance payments/penalties and administrative response should be designed to prevent violations of environmental requirements by removing the economic benefit of non-compliance (see Chapter 2).

  • Monetary pollution damages (or liabilities for environmental damage) should be focused on ensuring that the responsible parties finance the remediation of environmental damage they cause, using direct methods (see Chapter 3).

Box 2.1. The OECD Polluter-Pays Principle

The Recommendation on the Implementation of the Polluter-Pays Principle was adopted by the OECD Council on 14 November 1974. It specified the allocation “of costs of pollution prevention and control measures to encourage rational use of scarce environmental resources and to avoid distortions in international trade and investment.” The polluter should bear the expense of carrying out the measures “decided by public authorities to ensure that the environment is in an acceptable state”. It further elaborates the circumstances in which government assistance would be considered compatible with the principle. It also recommends conditions to the granting of government assistance in bearing the costs of pollution control through subsidies, tax advantages or other measures.

The principle did not feature in the 1972 Declaration of the United Nations Conference on the Human Environment in Stockholm. However, it was adopted as Principle 16 of the UN Declaration on Environment and Development in Rio in 1992. The European Community took up the OECD recommendation in its first Environmental Action Programme (1973-76). Its Recommendation of 3 March 1975 regarding cost allocation and action by public authorities on environmental matters also embraced the Polluter-Pays Principle. Since 1987, the principle has also been enshrined in the Treaty of the European Communities and in numerous national legislations worldwide.

Source: (OECD, 1974[8]); (European Commission, 2012[9])

Contrary to Kazakhstan’s approach, all OECD members with environmentally related taxes (ERTs) for industrial air pollutants share an approach that attempts to design policies, laws and instruments that:

  • follow the strict Polluter-Pays Principle for all (see Box 2.1);

  • shift the focus of environmental requirements from “end-of-pipe” solutions to integrated pollution prevention and control;

  • shift mentality of the largest and “high impact” polluters from command-and-control regulation, which just penalises non-compliance;

  • re-incentivise compliance; and

  • avoid undue overlap between policy instruments, as much as possible.

In practice, three main systems are in effect for some or all priority industrial air pollutants in OECD member countries. For each, OECD Europe member countries have a long-established regulatory framework of legislative administrative and judicial governance that can serve as a reliable guide.

2.2.1. The “pure” tax rate model

The tax rate is set as EUR/tonne and to incentivise abatement. It is linked to marginal abatement costs, which reflects the cost of one additional unit or tonne of pollution that is abated or not emitted. Because of the low cost of initial abatement, the heaviest polluting firms also tend to be the largest contributors to the reduction in pollution.

The tax base covers number of pollutants considered as significant (e.g. SOx, NOx total suspended particulates and heavy metals).

The collection rate is established following different methods:

  • For the Swedish NOx emission tax and refund system (Box 2.2), the rate was based on an estimate of the marginal costs of abatement measures. These costs were expected to trigger an emission reduction of some 5 000-7 000 tonnes of NOx per year. This represents the amount necessary to reduce NOx emissions by 30% between 1980 and 1995.1

  • For the Norwegian tax on NOx, the rate was derived from an estimate of the value of the damage caused by one kg of NOx emitted.

  • For the NOx tax in New South Wales Australia (the Load-Based Licensing System), a comprehensive flexible model was used to better reflect the actual damage posed by the emissions. Variations were based on the amount emitted, where the emission occurred and the time of year.

  • For other taxes on NOx emissions introduced in France, Italy and Galicia in Spain, the tax rates were quite modest in most cases and linked to the damages caused.

  • Some OECD member countries, such as the United Kingdom, use models to allocate contribution to operators based on the “cost to serve”. This will be subject to further discussion, as these models are best viewed as part of the cost regulation rather than as an ERT.

Box 2.2. The Swedish NOx Tax

The problem

Sweden was facing a serious soil acidification and water eutrophication problem caused partly by emissions of nitrogen oxides (NOx) from combustion processes in transport, industry and power.

The policy response

In 1992, Sweden introduced a high tax on NOx emissions from large combustion sources (e.g. power plants, industrial plants, waste incinerators). The tax was accompanied by a refund according to the amount of energy generated. This ensures that facilities with low NOx emission intensities are net beneficiaries of the scheme.

Continuous monitoring of emissions was also made mandatory. The tax was designed to accelerate and stimulate investment in advanced combustion and pollution-abatement technologies. It was also meant to supplement regulatory measures.

The impact

Within 20 months of implementing the tax, NOx emissions were reduced by 35%. Industry was encouraged to develop cheaper, more efficient technologies; emission intensities of energy production were cut by half.

The case of Sweden shows that a high emission tax rate can be made politically acceptable by: i) refunding revenues earned back to the firms affected; and ii) ensuring the policy is well designed.

Source: (OECD, 2013[10]).

2.2.2. The ELV/BAT model without payments for emissions within the limits

In the absence of payments for emissions within the limits set following an ELV model using best available techniques (ELV/BAT), the operator is not charged for emissions up to ELV. This might follow a recommendation (e.g. level in terms of mg/Nm3 for a specific industry/activity) and/or the BAT-AEL (e.g. in the EU-BREF of the European IPCC Bureau). The ELV is realistic and not based on zero human health impacts. Non-compliance payments may apply in case of emissions that exceed the limit. Most EU countries follow the Industrial Emissions Directive (see Box 2.3).

2.2.3. The ELV/BAT model with payments for emissions within the limits

In the case of countries in transition (mostly EU members), taxes for air emissions and water discharges are common. The taxes/payments are based on an ELV/BAT model for emissions up to the ELV. Other than that, there are no differences with the previous model. Non-compliance payments may apply for exceeding the limit for emissions. The base and rate are set based on ELV as part of the permitting process. The ELV follows a recommendation for a specific industry/activity (e.g. level in terms of mg/Nm3 as per the EU IED). For example, the Slovak Republic is one of the few OECD member countries still following this system for pollution taxes.

Box 2.3. The EU Industrial Emissions Directive

The European Union sets the overarching framework regulating the emissions of pollutants from the industrial facilities of its member states. Until recently, Directive 2008/1/EC concerning integrated pollution prevention and control (the “IPPC Directive”) and a series of narrower sectoral directives established the conditions for granting environmental permits to about 52 000 regulated installations. Those multiple directives have since been replaced by a single one. Directive 2010/75/EC (the “Industrial Emissions Directive” or IED) aims to provide a more comprehensive framework regulating industrial emissions in the European Union. Under this framework, environmental permits must “take into account the whole environmental performance of the plant, covering e.g. emissions to air, water and land, generation of waste, use of raw materials, energy efficiency, noise, prevention of accidents, and restoration of the site upon closure” (European Commission, 2018[11]). Greenhouse gas emissions are, however, excluded from the scope of permits in cases where industrial facilities are already covered by the EU Emissions Trading System. This integrated approach to addressing industrial pollution – as opposed to separately controlling emissions into different environmental media – ensures that pollution is not shifted from one medium to another.

Under IED rules, environmental permits must include requirements reflecting the performance of the BAT. They must also identify corresponding emission limits for each pollutant concerned and the suitable emissions-monitoring methods. Emission limits should be set for each permit so the regulated facility meets the emission levels prescribed in the associated BAT conclusions. To arrive at these BAT conclusions, the European Commission has put in place an information-exchange forum (sector-specific technical working groups). The forum allows for member states and stakeholders, including non-governmental organisations and industry, to draw up industry-specific BAT reference documents (the “BREF” documents). BAT conclusions form part of these documents. These conclusions, in turn, lead to the setting of industry-specific and facility-specific permit conditions that cover BATs and the corresponding emission limits.

At present, BAT conclusions have been published for 14 industrial sectors. A further 18 sectors benefit from BREF elaborated under the IPPC legislation; these are being reviewed to create Implementing Decisions. Thus, there are 32 sectoral BREF, developed over 1997-2018.

Deviations (“derogations”) from these standards are only permitted where local and technical characteristics would make their adoption disproportionately costly. As before, key parts of the necessary technical documents (the BAT conclusions) are to be adopted via implementing acts. These conclusions shall serve as a reference in the drawing up of permit conditions.

Source: (European Commission, 2018[11]).

2.3. Proposed recommendations

2.3.1. Reduce discretionary powers and avoid any forms of discrimination

Pollution tax/charge rates should be the same per unit of pollution, irrespective of the total load (so-called flat rates). Flat rates would help provide a continuous incentive for pollution reduction even beyond compliance with the permitted limit as long as this is economically feasible.

This approach would increase the overall incentive impact of the tax/charge and limit administrative discretion in applying it. The flat rate would also remove any incentives to adjust ELV depending on the enterprises’ tax burden (OECD, 2012[7]).

Against this backdrop, Kazakhstan should thus set rates for taxes for 1 tonne of emissions that are uniform for all sectors and, as much as possible, for all regions.

2.3.2. Further focus the tax base on priority pollutants

Regardless of its primary purpose, but especially if it is to reduce pollution releases, the pollution tax must be levied on a limited number of priority non-hazardous pollutants.

The number of pollutants subject to taxes should be reduced to a small number of priority air and water pollutants. Such pollutants should be based on international commitments or targeted air quality standards. An analysis of the main environmental problems in Kazakhstan that reflects an updated Green Economy Concept should guide the determination of pollutants that would continue to be charged.

To create an incentive, pollution taxes must be targeted at a few key pollutants that represent priorities of the government’s environmental management programme. These pollutants must be emitted by a relatively small number of big stationary sources and can be measured at a reasonable cost.

  • For example, for air pollution, taxes could target a reduction of SOx, NOx, particulates, and possibly some VOC emissions by the economic sectors contributing the largest share of the total emissions (and of the tax/charge revenue).

  • In Western European countries where air emission taxes exist (Sweden, Denmark, Norway, Italy), taxes are focused mostly on SO2 and NOx (OECD, 2012[7]).

  • In the Czech Republic, for example, all stationary sources of emissions have been divided into two categories since 2012: i) sources and industries directly specified in the special Annex No. 2 to the Air Protection Act; and ii) all other sources. At the same time, only 4 pollutants in emissions instead of 20 are charged with a fee: PM10, SO2, NOx and VOC (volatile organic compounds).

The same approach could be applied for releases of pollutants into water. This could focus on a small number of pollutants, such as organic matter, suspended solids, phosphorus and nitrogen (OECD, 2012[7]).

The reduction of the number of taxable pollutants and liable installations would lower the administrative burden of controlling and enforcing pollution tax payments. This would, in turn, lead to improvements in the administrative efficiency of this instrument (OECD, 2012[7]).

There are several reasons why Kazakhstan may encounter resistance against the pollution tax base. First, the country has substantially reduced the number of pollutants subject to taxes/charges over the last ten years. Further reduction may meet strong political resistance because of the perceived effect on revenues. However, as noted earlier, key pollutants likely already account for close to 90% of the revenue. This “loss”, therefore, will be heftily compensated by the increased tax rates on these pollutants.

Some may argue that reducing the pollution tax base would undermine the already weak system of industrial self-monitoring. In other words, enterprises would not report on pollutants other than those subject to the tax/charge. However, permit conditions regarding self-monitoring should be enforced irrespectively of the tax/charge liability. Moreover, the reporting of emissions or effluents for tax/charge assessment purposes is seldom based on actual monitoring and is simply inaccurate. This is quite difficult to control in such a complex system.

Given the evolving scientific understanding of air pollution and its impacts, Kazakhstan would be well advised to maintain, and to strengthen up to EU standards, a research and monitoring capacity concerning a larger range of pollutants. This should include a Pollutant Release and Transfer Register and/or a continuous emissions monitoring system. All lists of pollutants used for permitting and reporting purposes, as well as setting environmental payments, should also be combined in a unified national list of pollutants. This, in turn, should be harmonised with the list of pollutants in Annex II List of polluting substances (Air) of the Kyiv Protocol.

2.3.3. Progressively increase the tax rates/charges in line with abatement costs

Tax charges/fees in Kazakhstan are low compared to any marginal abatement costs and to rates in OECD member countries. Table 2.1 provides some data on the two most important pollutants in the country.

The few pollutants that will be covered by pollution rates/charges after the tax/charge base is reduced should be analysed. This process should determine typical tax burdens and pollution abatement costs for enterprises by sector and size. It should then estimate the degree to which the tax rates can be increased (as the number of pollutants subject to tax is drastically reduced). This estimate would enhance the incentive impact of the tax, while maintaining its economic feasibility and political acceptability. This analysis could not be undertaken as part of our joint project with Kazakhstan due to issues related to confidential and firm-specific data.

The economic feasibility here means that polluters (particularly in the public sector) should have financial resources to reduce their emissions in response to the tax.

Table 2.1. Selected cost per tonne emitted



Nitrogen oxides


59 (or 10 MCI)


Czech Republic


Major stationary sources



Air pollution fees

Slovak Republic


Air pollution charge – large and medium sources



Air pollution charge



Based on 0.5300 PLN per kg



NOx pollution tax



NOx emitted to the atmosphere



Air pollution charge for stationary sources





Duty on NOx


2 410

Tax on emissions of NOx


5 280

Tax on NOx emissions

Sulphur oxides 


59 (or 10 MCI)


Czech Republic


Major stationary sources



Air pollution fees

Slovak Republic


Air pollution charge – large and medium sources





SO2 pollution tax



Air pollution charge






SOx emitted to the atmosphere




1,570 - 3,130

Duty on sulphur



The rates differ according to the expected cost related to the handling of different applications.

Source: (OECD, 2019[12]).

If this condition is not met, some interim solutions are possible. These include a planned gradual increase of pollution tax rates along with management improvements in the sector.

Pollution tax rates should be increased gradually but announced early to soften the immediate cost effect on industry. Such an approach would give enterprises time to assess abatement costs versus paying the pollution taxes/charges and adjust their investment plans. Still, the high pollution tax rates will likely increase production costs and reduce competitiveness of polluting industry sectors. In the longer term, this may lead to structural changes towards greening the Kazakhstani economy.

Regardless of the incremental increase of the level at which pollution taxes are levied, they will most likely still seem low. The European Environmental Agency analysed that externalities in Europe from the emission of such pollutants are typically at least a factor of 10, and sometimes a factor of 100 or more. This is higher than the tax rates levied in Europe (see Table 2.2).

Table 2.2. Estimates of damage (EUR per tonne of emission) for NOX in 2010 and 2020
(2005 prices)


NOx 2010

NOx 2020



High VSL


High VSL


13 924

38 145

15 209

41 426


3 812

10 324

4 159

11 171


10 343

27 549

10 291

27 098


8 394

22 723

8 376

22 399


1 990

4 997

1 985

4 922

Slovak Republic

10 197

27 402

12 937

34 857

Note: This analysis follows the impact pathway methodology developed in the ExternE Project funded by European Commission's DG Research. The valuation of mortality is using the value of statistical life (VSL) and value of a life year (VOLY) approaches.

Source: (EEA, 2011[13]).

2.3.4. Carefully assess the option of setting up environmental funds

Revenues from ERTs, perhaps more often than from other taxes, are subject to multiple and specific claims on their use. This occurs particularly when instruments are newly introduced.

Some argue that earmarking can help create support for ERTs by increasing policy transparency. However, this can become counterproductive in the long term. As the need for flexibility in spending decisions rises and as ERTs become standard, they require the broadest possible support. The higher the revenues from ERTs, the stronger the need becomes to ensure whole-of-government support for them. Statements of policy intent on how to use revenues can be useful in the short term. They can help introduce ERTs, which avoids the risks associated with strong earmarking (OECD, 2017[2]).

There are few incidences of such funds in the OECD for industrial air pollutants. In 2008, Norway created a unique NOx fund that entities could pay into and avoid paying tax. The money collected was then used to fund projects to reduce NOx emissions (see Box 2.4). In 2004, the Netherlands established the Dutch Air Pollution Fund (Ministry of Housing, Spatial Planning and the Environment of the Netherlands, 2004[14]).2

These environmental funds have become quite substantial in some countries. In Poland and the Czech Republic, for example, annual budgets exceed USD 100 million for such funds. These generally derived revenues from environmental charges and taxes that were set aside (“earmarked”) for environmental purposes rather than transferred to the general government budget. Funds used these revenues to provide financial assistance to the private or public sector, usually on favourable terms, for investments and other projects to achieve environmental objectives (OECD, 1995[15]).

During the transition to a market economy, a series of market, policy and institutional failures impede the emergence or effective use of financing mechanisms characteristic of market economies. The OECD highlighted several problems, including weak or ineffective enforcement of environmental policy; severe financial constraints on enterprises and households; uncertainties in fiscal systems; poorly developed banking systems and capital markets; and inadequate information concerning costs of environmental damage.

Environmental funds (or green funds) could provide an interim means of circumventing these problems. By supplying financial assistance, such funds could leverage resources from other sources, and thus speed the pace of environmental improvements. Environmental funds could also help strengthen domestic capacities for project preparation and policy implementation. In conjunction with other policy instruments, funds could help develop and implement priority environmental activities in line with international commitments. This was underlined previously by the St. Petersburg Guidelines on Environmental Funds in the Transition to a Market Economy developed by the OECD (1995[15]).

Kazakhstan could consider earmarking environmental taxes and penalties for general environmental purposes. Without careful design and management, the potential advantages of green funds could become defects. From a fiscal policy perspective, “earmarking” has potential dangers: allocating and disbursing revenues outside the government budget may create long-term economic inefficiencies. Well-designed procedures and incentives are needed to ensure that environmental funds target priority environmental problems and spend revenues effectively. This requires effective project appraisal techniques, as well as sound financial and accounting processes, procedures and management capacities. Transparency on the funds’ operations is paramount. They should be accountable to the government, parliament and the public for their actions. This is important to ensure continued support from finance ministries and ultimately public acceptance of environmentally related taxes.

With all this in mind, establishing such a vehicle in Kazakhstan could be considered to earmark environmental taxes and penalties for general environmental purposes. However, the inclusion of monetary compensation for damage from industrial air pollution would deviate from OECD standards. Monetary damages are used to pay for restoration or remediation of the specific environmental resource that the polluter has damaged. These damages are never dedicated to financing unrelated environmental remediation initiatives.

Box 2.4. The Norwegian NOx Fund

Norway developed a fund supported by the public and private sector for green innovations

Norway set an ambitious target to reduce NOx emissions by 20% versus the baseline. This decision followed ratification of the Gothenburg Protocol under the UN Economic Commission for Europe Convention on Long Range Transboundary Air Pollution. The Protocol also covers other pollutants like SO2 and volatile organic compounds (VOC), but the Fund targeted NOx emissions. The rest of Norway’s obligations could be met without additional tax or had been met by the moment Norway had ratified the Protocol. The industry wanted the same arrangement for greenhouse gases, but it turned out to not be possible due to the EU Emissions Trading System.

In 2007, a state NOx fee was set at NOK 15 per kg of NOx emitted (approximately EUR 2.2 per kg). The industry paid the tax in 2007. The government had identified selective catalytic reduction (SCR) and selective non-catalytic reduction (SNCR) as the main technologies for industry to meet the NOx reduction goal. After several negotiations with authorities, 14 non-governmental organisations and the Ministry of Climate and Environment signed an Environmental Agreement on NOx, which entered into force on 1 January 2008. A three-year transition period was negotiated, at the end of which the 20% reduction was to be achieved. Ultimately, the 861 participating companies had reduced NOx emissions by 28 000 of the 38 000 tonnes committed by Norway.

Fifteen co-operating business organisations co-founded with the government a NOx Fund for the private sector, which exempted them from the NOx tax. Land-based industries could contribute EUR 0.5 per kg of NOx emitted to the Fund, while the oil and gas industry could pay EUR 1.3 per kg to the Fund. The members of NOx Fund achieved 74% of the emissions reduction target, while the industry as a whole was responsible for 32% of NOx emissions.

The Fund committed to support more than 1 000 applications from businesses to reduce NOx emissions. The government initially planned for most of these measures to result from end-of-pipe measures for cleaning exhaust gases. However, the reality was somewhat different. Only 20% of the emission reductions – as supported by the NOx Fund – resulted from implementation of SCR or SNCR. Most measures related to fuel switch, better combustion techniques and process optimisation, shift to modern burners, etc.

The Fund quickly became a success and accelerated efforts to cut NOx emissions. At the same time, it gave the industry financial support to implement competitive green technologies. It also became an important driving force for the strengthening of the government’s environmental functions. Instead of importing equipment, the Fund helped optimise projects with support from local consultants and engineers.

The NOx Fund thus became an important stakeholder for Norwegian policy makers. Two continuations of the Environmental Agreement were signed for the 2011-17 and 2018-25 periods. In its current incarnation, the Fund is giving more attention to the shipping industry.

Ultimately, through the Fund, companies met compliance requirements at a much lower cost than EUR 2.2 per kilo.

Source: Author’s elaboration based on interviews and desk research.

2.3.5. Sustain efforts towards OECD/EU acquis and analysis on AQS, BAT/ELV and IEP

Air quality standards

Kazakhstan should initiate a stepwise process to accede to the three amended protocols to the Convention: the Protocol to Abate Acidification, Eutrophication and Ground-level Ozone, the Protocol on Heavy Metals and the Protocol on Persistent Organic Pollutants. Since 2001, Kazakhstan has been party to the Convention on Long-Range Transboundary Air Pollution. However, it did not become a party to important protocols under the Convention, such as the amended Protocol to Abate Acidification, Eutrophication and Ground-level Ozone, amended Protocol on Heavy Metals and amended Protocol on Persistent Organic Pollutants (UNECE, 2019[16]). Kazakhstan started submitting emissions inventories to the European Monitoring and Evaluation Programme Centre on Emission Inventories and Projections (EMEP CIP). Accession to the EMEP Protocol would provide a good basis for quick accession to the other key protocols of the Convention. This would also give further access to the expert network under the Convention, which can help in providing guidance on ELV based on BAT. The Convention is increasingly providing expertise and guidance to the Eastern European, Caucasus and Central Asian countries. It aims to help them ratify and implement the key protocols and reduce air pollution (UNECE, 2019[16]).

Kazakhstan should draw up a roadmap to transfer the air quality assessment to air quality standards based on pollutant concentrations according to internationally accepted practices as outlined in Table 2.3 (European Commission, 2008[17]).

Table 2.3. Overview of AQS in Europe

Air quality standards










European Union




200 (less 18 hrs a year)

People’s Republic of China









(Only daily: 80-120)

United States





World Health Organization





Source: (European Commission, 2004[18]); (European Commission, 2008[17]); (US EPA, 2018[19]); (Ministry of Ecology and Environment of China, 2018[20]); (Ministry of Environment of Japan, 2018[21]); (WHO, 2006[22]).

Kazakhstan should also strengthen the national legislation to address air protection. At the same time, such legislation should help oblasts and other local authorities to draw up air quality plans and programmes to reduce and prevent the exceeding of air quality standards. For example, in the Czech Republic, public health targets are set in legislation. They chiefly limit values (especially for dangerous pollutants), build on annual health and environment surveys, and continue to establish objectives and targets for public health and the environment. Additional targets on air quality are included in the National Emission Reduction Programme. Moreover, reducing environmental and occupational health risks is a priority of the 2014 National Strategy for Health Protection and Promotion and Disease Prevention (OECD, 2018[23]).

“Quick-wins” for process improvements, before the adoption of a BAT-model

This sub-section examines how countries can improve processes in the most polluting sectors (i.e. power generation), even before the adoption of a BAT-model. Several OECD member countries, including Norway (Box 2.5) have shown that these “quick-wins” are well-known, proven and economically affordable.

The quick-wins harness a range of technologies. Transferring a boiler from fuel to gas, for example, can reduce NOx emissions by 50-75%. Using non-catalytic purification with ammonia reduces NOx emissions in the range of 60-80%. Investments in new cleaning technologies, or processes (e.g. conversion of a boiler to gas) or replacement of equipment (e.g. a burner) have reduced NOx emissions by 60%, 80% and 91%, respectively. These generate a pay-back of 6.5, 5.2 and 20 years, respectively. Box 2.5 provides more details, on the basis of a NOx charge of EUR 1.9 per kg of emissions.

Results from the use of these technologies show that operators have an economic incentive to engage in cleaner production techniques, processes or equipment. In Norway, the tax rate for NOx is more than 30 times higher than in Kazakhstan.3 In most cases, the benefits from reduced charges for emissions provide a foundation to recover investments in less than ten years.

Box 2.5. NOx reduction techniques and investments in Norway

The following list indicates the range of NOx emission reductions generated by specific technologies.

1) using catalytic purification with a catalyst (SCR) and non-catalytic purification with ammonia (SNCR): 60-80%

2) transferring the boiler from fuel oil to gas: 50-75%

3) improving the regulation of combustion processes; regulation of air supply/O2: 10-40%

4) lowering combustion temperature: 20-30%

Investments in new equipment have generated 60-91% NOx emissions reductions.

Table 2.4. NOx emission reductions and pay-back for three types of investment


Cleaning plant based on non-catalytic cleaning technology

Conversion of the boiler to gas in a titanium plant

Burner replacement (low NOx burner)

Amount of the investment


1 000 000

1 300 000

2 300 000

Baseline emissions

in tonnes




Emissions reduction

in tonnes




In percentage




Savings achieved


153 947

248 216

115 530

Investment ratio

Per kg baseline




Per kg reduced





6.5 years

5.2 years

20 years

Note: calculated on the basis of a NOx charge in Norway of EUR 1.9/kg.

Source: interviews with Norsk Energi – The Norwegian Association of Energy Users and Suppliers.

2.3.6. BAT/ELV

Scope and benefits of BAT

Recent activities have promoted the BAT concept in Kazakhstan. However, the country still does not commonly apply BAT when setting up air emission limits and monitoring environmental management of industrial facilities. Investing in BAT would support efforts to modernise the industrial and energy footprint. Ultimately, this would improve domestic industrial competitiveness and access to export markets. Three key actions are needed. First, filters should be retrofitted and installed at plants and industrial enterprises close to big cities. Second, Kazakhstan should further consider switching coal-fired power plants to gas, if gas infrastructure and volumes are available and if it is cost- effective. Third, retrofitting large boilers at coal power plants, with modern control technology for PM, SOx and NOx, could allow smaller units to operate until decommissioning. This would require more technical feasibility studies, but could help satisfy demand for electricity.

In OECD/EU countries, BAT are mandatory for large polluters. Although the recommended techniques and technologies are voluntary, the ELV based on BAT are legally binding. There are often thresholds e.g. combustion of fuels in installations with a total rated thermal input of 50 MW or more. BAT focus on best techniques, not just best technologies. In other words, they also refer to the way in which the installation is designed, built, maintained, operated and decommissioned.

For larger polluters, integrated permits are increasingly favoured for all media in OECD members. However, BAT can still be used as an instrument in the absence of IEP. In Israel, for example, permit conditions are still based on BAT-AEL from the EU BREF. While IEPs are suitable for higher risk, complex processes, a range of permits should be made available to reflect circumstances. The United Kingdom, for example, has four main types of permit to reflect the level of environmental risk: bespoke, standard, registrations and exemptions. These four types could be seen as reflecting the four categories of operator set out in the Environmental Code (high risk, some risk, minimal risk and no risk). Permitting all operators provides a reference point with which to locate and investigate the operator, in the event of an environmental incident.

In the OECD, the ELV are set at a reliable, practicable and enforceable level. They are not based on zero human health impacts, on the level of historic pollution and background concentrations or on the highest level of emissions measured during the maximum production output. Rather, the ELV are set to ensure that, under normal operating conditions, emissions do not exceed levels associated with BAT. The ELV are expressed in terms of mg/Nm3 as per the EU IED for a specific industry/activity and as an average over a given period.

During the application for a permit, the competent authority may ask the applicant to fill in a detailed spreadsheet. It refers to the BAT, explains any deviations and provides a detailed action plan to bridge the gap. The United Kingdom and Ireland have developed good practices to disclose permit information to the public. Permit decision documents are placed on the UK public register, to enable this transparency.

Some regions set emissions levels stricter than the BAT, depending on some regional environment priorities (e.g. in Germany).

Derogation in OECD members

The competent authority may as “a derogation” and “in specific cases” set less strict ELV. In the European Union, it must be shown that implementing the BREF levels would lead to disproportionately higher costs compared to the environmental benefits. These higher costs would be due to the geographical location or the environmental conditions of the installations concerned or their technical characteristics.

The derogation procedure may involve the public, including NGOs. The specific reasons (justification as well as conditions imposed) are made publicly available, including via the Internet. There is significant oversight for derogation. In the European Union, member states have to report all derogations granted to the European Commission. Further details on derogations are available on the EU collaborative platform CIRCABC.4 For example, according to article 15(4) of the IED, regardless of any derogation the competent authority must still ensure that no significant pollution is caused and that a high level of protection of the environment as a whole is achieved.

Specific BAT for large combustion plants (LCPs) have been developed.5 These offer certain flexibility instruments (e.g. Transitional National Plan, limited lifetime derogation). There is a possibility to apply less strict ELV for plants that operate for less than 1 500 hours per year.

The competent authority can grant temporary derogations from ELV associated with BAT to test emerging techniques in certain cases.6 In the first case, the techniques may provide for a higher general level of environmental protection, or at least the same level of environmental protection as the BAT. Second, they might provide higher cost savings than the BAT.

For small and medium-sized enterprises (SMEs), environmental issues could be included in other permits. In Germany, for example, they are included in construction permits. In the Netherlands, they are included through General Binding Rules.

Process followed

Official reference documents for BAT or similar concepts result from data exchanges through sector-specific technical working groups (TWGs).

These groups convene different sets of public and private stakeholders to ensure a deep understanding of each party’s requirements and expectations.

The participants first identify some techniques as candidate BAT, considering their environmental, technical and economic aspects. Further, they derive the BAT-AEL from the BAT. A separate body considers and approves the BREF developed by the TWG.

Participants tend to include governmental experts, industry representatives, NGOs, and public and private research institutes. Representatives of ministries other than energy or environment (e.g. economy) or experts appointed by a ministry, a business association, an operator or a specific academic institute, might help gather information on techniques. Increasingly, technology service providers are invited to apply for a position on TWGs or at the BAT forum (Article 13 Forum in the case of the IED).7

Preserving the transparency and diversity of the stakeholders is essential. This is especially the case in regard to the decision-making process to set BAT-AEL or the selection of experts mandated by ministries or academia. Their level of independence should be carefully guaranteed, with the disclosure of possible conflicts of interest (e.g. grants awarded in the past from private entities).

Recent OECD work8 on BAT suggests several areas to strengthen the BAT concept. These include, for example, considering value chain aspects when determining BAT. Another area is more stringent emission limits. These need to embrace global best-in-class techniques, moving beyond benchmarking restricted to a specific, geographic, legally binding scope. Strengthening BAT could also involve outlining the restrictive interpretation given in some eventual confidentiality claims that prevent the data exchange that establish BAT. In addition, the process of establishing BAT and BAT-AEL could be more transparent and standardised. Finally, it would be useful to increase access to information on techniques considered, permitting information and monitoring data.

Awareness development and communication

Some countries have invested in various approaches to create awareness among operators such as role-playing schemes (business games) and science challenges. The United States, for example, has created awards for green chemistry to promote the prevention of pollution through green approaches instead of focusing mainly on end-of-pipe responses. These countries also have well-staffed BAT centres. They provide experts on the technologies, on the process to establish BAT and on the monitoring of their implementation. The European IPPC Bureau or the Unit for Integrated Treatment of Industry at the Ministry of Environment in Israel are two examples that the IGTIC in Kazakhstan aims to emulate. These centres can also provide technical support to operators, in particular to establish the baseline.

The use of BAT is also often combined with practical advice on implementation. This is particularly needed on issues surrounding baseline, and takes the form of baseline reports in the European Union.9 The IMPEL Network also provides guidelines on how to implement derogations under various EU member states. The “Do the right things” documents by the EU guide inspectors in planning and executing inspection programmes.10

A communication platform11 is often developed and entails the following elements: i) an information portal building on the example of the European Union12, as well as the main IED bodies13; and ii) a “Frequently Asked Questions” (FAQ), which could also draw from the experience again of the European Union.14 An archived page of FAQs on the IPPC Directive is mostly still relevant.15

Implementation period

There are several ways OECD members have managed the transition to BAT. An inventory plan of the main installations was prepared covering three-quarters of emissions. Responsible government agencies conducted BAT compliance review of industries and assessed the level of preparedness, and considered feedback from industry. In Norway, for example, the Ministry of Environment and the Environment Protection Agency acted as advisors based on trust and open dialogue.

It generally takes almost four years to review a BREF. Compliance with the BAT conclusions is then required four years after their publication. In practice, however, the time allowed for the transition exceeded ten years in some cases. The revision of the original EU BREF for pulp and paper manufacturing (BREF-PP, published 2001) started in 2006. It was one of the first sectors to come under IPCC. Yet, all European pulp and paper mills had until 1 October 2018 to consider the new BAT conclusions and adhere to them in their permit to operate. Nevertheless, there were different priorities 20 years ago. Today, learning from and co-operating with EU/EC countries, institutions and networks, Kazakhstan could fast track the adoption of BAT. Industry should be engaged as early as possible in the process to ensure buy-in and active participation in the design and roll out of BAT for each sector.

Specific recommendations to plan for BAT-led environmental regulations

IGTIC is already initiating preparation of the implementation of BAT. While this is a promising expression of commitment, further clarification is needed to ensure its effectiveness. Among other areas, the key elements/tasks of the Kazakhstani transition to BAT must be elaborated in more detail. These include, for example, setting up an adequate institutional structure for BREF development and for issuance of permits, and clarifying linkages with other ministries, agencies and initiatives.16 The approach for selecting priority sectors for BREF development, as well as the definition of the BREF (and BAT conclusions) structure and legal status, must also be clearer. Other issues include the preferred method for identification of BAT, the derivation of AEL and translation into ELV; the systems for derogations and inspections; timelines and incentives for compliance with ELV; and the communication strategy and supporting tools such as the web portal.

A convergence to a BAT-model will certainly take time and the OECD is ready and able to support it. The level of ambition for the transition will depend highly on how Kazakhstan confronts some strong vested interests to maintain the status quo. Actions could, and should, be scaled up in preparation. In the short term, irrespective of the timeline for the transition, Kazakhstan should adjust the legislation on emission standards for LCP. A first step would be to base these standards on BAT that are defined in the annexes of the amended Protocol to Abate Acidification, Eutrophication and Ground-level Ozone under the Convention on Long-Range Transboundary Air Pollution.

Furthermore, several additional actions should be considered in the short term to continue preparation of the transition plan. Benchmarking ELV on sector-specific BAT might be of value. The inclusion in the list of technologies available of those eligible for complex permits from the oil and gas sector will help. This sector is among the biggest foreign contributors to the technological upgrading of the country, with the 1% subsoil user requirement.17 Technical co-operation with the BAT bureaus or technical centres of OECD members should be deepened. This would build on initial contacts between the IGTIC and the European IPPC Bureau in Seville. It could possibly involve a temporary exchange of staff who know how to run a BAT-led ELV development process.

The OECD is already providing some support on the design of the transition path. More and adequate strategic planning and targeted implementation support will be required. The OECD project to assist governments on BAT18 and the GREEN Action Task Force stand ready to engage. Well-thought co-operation at a regional level would be paramount to reach the right critical mass to attract potential donors and co-developers.

Framework conditions for innovation

Innovation plays a critical role in delivering improved environmental outcomes at lower costs. Environmentally related taxes can thus encourage the development and adoption of market-ready innovation.

However, the breakthrough technologies that will lead to fundamental environmental improvements are less likely to be developed under a tax-only regime. They will be more likely to flourish under a regime that includes incentives for research and development (R&D). The long-term and more fundamental nature of such projects, however, creates uncertainty for investors and entails a high probability of failure. There are asymmetries of information between the owner of knowledge or innovation and possible users and/or funders. The time horizon might be long for fundamental research, with uncertain prospects facing applied research. And there will be gaps between private and societal returns on R&D. Undoubtedly, there is a role for an empowering, activist and catalytic state in Kazakhstan. Environmental taxes may need therefore to be supplemented by targeted investments in R&D.

Some countries are supporting adoption of new technology “better than BAT”. In these cases, an operator’s investments are subsidised (e.g. up to 50% in some cases in Germany). There is, however, a need to ensure that R&D tax support towards BAT is in line with the good practices of OECD member countries. According to the Polluter-Pays Principle, polluters should not receive subsidies to clean up pollution they would be required to manage anyway to comply with laws and regulations. Hence, Kazakhstan should be careful with what sort of subsidies are offered.

Better alignment is needed with other framework conditions to improve trade, investment and innovation policies. The challenges faced by Kazakhstani innovators in green technologies are similar to those of any other innovators, and have been extensively documented (OECD, 2017[24]; OECD, 2018[25]). They encompass the following: weak outcomes of R&D activities; limited co-operation between academia and business; a fragmented R&D policy and funding framework; high dependency on the activities of foreign-owned companies; inefficiency in the business environment and investment climate; weak public procurement practices; and an underdeveloped intellectual property rights system.

Most importantly, the level of overall funding of R&D activities remains low. R&D intensity (the ratio of gross expenditure on R&D to gross domestic product [GDP]) fell from a peak of 0.28% to 0.14% over 2005-16.19 These numbers are well below the ambitious targets set in various governmental strategies and programmes of reaching 3% of GDP by 2050 (Ministry of National Economy of Kazakhstan, 2017[26]). The number of firms with ecological innovation is still small (slightly above 310) and decreased by 7.7% in 2016.20 However, there are some encouraging trends. Privately funded R&D accounted for more than half of overall expenditures, for example in 2016.21 Moreover, following Expo 2017 on “Future Energy”, the Ministry of Education and Science signed nine memoranda of co-operation and Kazakh universities signed 20 bilateral memoranda of co-operation.

Kazakhstan should elicit and hasten development of new technologies and new techniques. To that end, it would be well-advised to continue developing a large-scale programme of publicly funded R&D. It could also explore the potential for additional, specialised partnerships with the private sector, while maintaining and strengthening incentives for privately funded R&D.22 Such an initiative would dovetail neatly with another major item in the larger agenda for reform, which the OECD has analysed previously (OECD, 2017[24]).

Specifically, Kazakhstan should take four key actions. First, it should implement a comprehensive and coherent framework for promoting eco-innovation by improving co-ordination of energy, innovation and environmental policies across the government. Second, it should streamline public support for R&D and ensure that it targets long-term priorities. Third, it should improve co-operation between academia and business, ensuring sound framework conditions for business innovation. Fourth, it should develop demand for environmental goods and services. These recommendations are very much relevant for green technologies and innovation.

Kazakhstan recognises that transformation of the whole innovation ecosystem in line with national development needs will take time. In the short term, setting up mechanisms to co-ordinate and disseminate new information on abatement techniques in Kazakhstan and internationally would be a good start. A knowledge hub such as the EU Observatory of New Techniques will be a good benchmark.23 The IGTIC is certainly a good vehicle to host such a platform, provided it is well co-ordinated. Other entities/projects could possibly compete for the same innovators, projects pipeline, funding mechanisms and, critically, most likely users. Such users include the Autonomous Cluster Fund in Almaty, the World Bank-Kazakhstan Fostering Productive Innovation Project or Energy Efficiency Project, NadLoc – the agency for local content.


[13] EEA (2011), Revealing the Costs of Air Pollution from Industrial Facilities in Europe, EEA Technical Report, No.15/2011, p.23, European Environment Agency, Copenhagen,

[11] European Commission (2018), Summary of Directive 2010/75/EU on Industrial Emission, European Commission, Brussels,

[9] European Commission (2012), Workshop on EU legislation, principles of EU Environmental Law, the Polluter Pays Principle, European Commission, Brussels, (accessed on 4 December 2018).

[17] European Commission (2008), Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on ambient air quality and cleaner air for Europe, European Commission, Brussels,

[18] European Commission (2004), Directive 2004/107/EC of the European Parliament and of the Council of 15 December 2004 relating to arsenic, cadmium, mercury, nickel and polycyclic aromatic hydrocarbons in ambient air, European Commission, Brussels,

[20] Ministry of Ecology and Environment of China (2018), Air Quality Standards,

[21] Ministry of Environment of Japan (2018), Environmental Quality Standards - Air Quality, Ministry of Environment of Japan, Tokyo,

[14] Ministry of Housing, Spatial Planning and the Environment of the Netherlands (2004), “Environmental Management Act”, No. section 15.5, pages 126-127,

[26] Ministry of National Economy of Kazakhstan (2017), Strategic Plan for Development of Kazakhstan until 2025, Technological Modernisation for Accelerated Growth and Better Quality of Life.

[12] OECD (2019), Database on Policy Instruments for the Environment, (accessed on 13 February 2019).

[23] OECD (2018), OECD Environmental Performance Reviews: Czech Republic 2018, OECD Publishing, Paris,

[25] OECD (2018), Reforming Kazakhstan: Progress, Challenges and Opportunities, OECD Publishing, Paris,

[2] OECD (2017), Environmental Fiscal Reform: Progress, Prospects and Pitfalls, OECD Report for the G7 Environment Ministers, OECD Publishing, Paris,

[3] OECD (2017), Multi-dimensional Review of Kazakhstan: Volume 2: In-depth Analysis and Recommendations, OECD Development Pathways, OECD Publishing, Paris,

[5] OECD (2017), OECD Investment Policy Reviews: Kazakhstan 2017, OECD Publishing, Paris,

[24] OECD (2017), OECD Reviews of Innovation Policy: Kazakhstan 2017, OECD Reviews of Innovation Policy, OECD Publishing, Paris,

[6] OECD (2014), Responsible Business Conduct in Kazakhstan, OECD Publishing, Paris,

[10] OECD (2013), “The Swedish tax on nitrogen oxide emissions: Lessons in environmental policy reform”, OECD Environment Policy Papers, No. 2, OECD Publishing, Paris,

[7] OECD (2012), Refocusing Economic and other Monetary Instruments for Greater Environmental Impact: How to Unblock Reform in Eastern Europe, Caucasus and Central Asia, OECD Publishing, Paris,

[1] OECD (2011), Environmental Taxation - A Guide for Policy Makers, OECD Publishing, Paris,

[15] OECD (1995), St. Petersburg Guidelines on Environmental Funds in the Transition to a Market Economy, OECD Publishing, Paris,

[8] OECD (1974), Recommendation of the Council on the Implementation of the Polluter-Pays Principle, 14 November 1974, C(74)23, OECD, Paris.

[16] UNECE (2019), Environmental Performance Reviews: Kazakhstan, Third Review, Environmental Performance Reviews Series, United Nations Economic Commission for Europe, Geneva.

[4] UNECE (2008), 2nd Environmental Performance Review of Kazakhstan, United Nations Economic Commission for Europe, Geneva,

[19] US EPA (2018), National Ambient Air Quality Standards, United States Environmental Protection Agency, Washington, DC,

[22] WHO (2006), WHO Air Quality Guidelines for Particulate Matter, Ozone, Nitrogen Dioxide and Sulfur Dioxide, Global update 2005, Summary of risk assessment, World Health Organization, Geneva,;jsessionid=E31B7B845A0498C471A1C5153E8ADC18?sequence=1.


← 1. See (OECD, 2013[10]): The flexibility of market-based instruments was needed. CO2 and SO2 emissions depend to a large extent on the carbon and sulphur content of the fuels combusted. Conversely, most NOx emissions are produced through reactions with nitrogen present in the air. It is possible to tax the carbon and sulphur content of fuels to limit CO2 and SO2 emissions. However, other means are needed to tackle NOx emissions. Emissions will vary significantly depending on the combustion technology employed and the maintenance of the combustion equipment. The costs of reducing NOx emissions vary significantly across producers, and economies of scale and rapid development.

← 2. The Dutch Air Pollution Fund offers an innovative solution in the event civil actions either fail or are, for certain reasons, rendered unavailable. Indemnification from the fund may be sought by, “anyone who has sustained loss due to sudden air pollution which should not reasonably be chargeable or wholly chargeable to him”: See Environmental Management Act section 15.25(1). The relevant minister determines the level of indemnification (s 15.26(1)), though it cannot be for a sum less than EUR 225: section 15.26(2)(a),

← 3. Effective rate of EUR 1 900 per tonne of NOx emitted to be compared to EUR 59 in Kazakhstan (or 10 MCI – the monthly calculation index – at 24 505 Tenge).

← 4. See

← 5. See EU BATC (07.2017),

← 6. In the EU BREF, there is a chapter on emerging techniques.

← 7. See for further details

← 8. See

← 9. In the European Union, where an activity involves the use, production or release of relevant hazardous substances and having regard to the possibility of soil and groundwater contamination, a baseline report is to be drawn up before starting the operation of the installation or before a permit for the installation is updated. See

← 10. See

← 11. Much more information is available on the Communication and Information Resource Centre for Administrations, Businesses and Citizens server, on the CIRCABC IED pages:

← 12. See

← 13. Ibid.

← 14. See

← 15. See

← 16. Co-ordination and strategic alignment will be essential with main stakeholders. These include the ministries of energy, of investment and infrastructure development, of national economy, Kazakh Invest at the Ministry of Foreign Affairs, clusters and innovation projects at national or oblast-levels, or the departments for economic and industrial development in the Akimats.

← 17. Subsoil users can fulfil their obligations amounting to 1% of their annual income in R&D either by investing R&D internally, for those who have an in-house R&D department, or contract R&D externally to a Kazakhstani organisation. See page 164, (OECD, 2017[24]).

← 18. See

← 19. See

← 20. See

← 21.

← 22. This includes the now familiar use of tax credits and other forms of tax preferences (OECD, 2017[24]). However, it also entails the specific obligation on subsoil users to “strengthen the national research and innovation capability” by investing 1% of their annual income in R&D. This could happen either by investing internally (for enterprises with an in-house R&D department) or contracting R&D externally.

← 23. See There was also a workshop with member states on emerging techniques in 2017 ( The Commission presented on the observatory (

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