Reference: SG/E/2017/29
Received Date: 04 July 2017
Subject: Membrane Technology Environmental Conversion
Complainant: IIDMA - International Institute for Law and the Environment
Allegations: Potential breach of EU environmental standards
Type: E - Environmental and social impacts of financed projects
Recommendations: no

* Admissibility date reflects the date the case was officially registered. All other dates pertain to the date in which a stage was completed.

Case Description


In July 2017, the Complaints Mechanism Division of the European Investment Bank (EIB-CM) received a complaint concerning an EIB financed project regarding chlor-alkali facilities in Torrelavega, Spain. The core of the complaint concerns the draft integrated environmental permit encompassing the industrial facilities. According to the complainant, the draft permit contravened EU environmental requirements in that it allowed mercury cell technique to continue to be used after December 2017. The complainant raised two allegations concerning the following:

  • Compliance of the project with the EU environmental requirements, i.e. EIB environmental standards and
  • EIB’s environmental assessment.

EIB-CM Action

In March 2018, the EIB-CM completed the Conclusions Report. In terms of compliance with the EIB environmental standards, the report states that the draft integrated environmental permit, which triggered the complaint, was not compliant with EU environmental requirements. However, the competent authority in Spain reviewed this draft and its final renewed integrated environmental permit complies with the relevant EU environmental requirements and, therefore, EIB environmental standards.

In terms of the EIB’s environmental assessment, the report states that the Bank’s services documented that they were aware of the applicable EU environmental requirements that all chlor-alkali facilities using mercury cell technique must be closed or converted to membrane cell technique by December 2017. Furthermore, when informed of the complaint and the content of the draft integrated environmental permit, the Bank’s services liaised with the promoter with the aim of obtaining relevant clarifications and documents and monitored the situation.


The EIB-CM concludes that its inquiry did not reveal any instances of non-compliance by the Bank’s services.