Updated environmental statement_2024_EN

Environmental statement 2024

Table of contents
This supplement is part of the consolidated Environmental Statement 2023 of Emil Frei GmbH & Co. KG (FreiLacke). It
provides information on current changes, which is why only the sections that have changed since the consolidated environmental
statement are listed in this table of contents.
1. Changes at the location 4
2. Implemented measures 5
3. Compliance with laws 6
4. Overview of absolute consumption data/core indicators 8
5. 2023 environmental programme (goals), Outlook & sustainability12
6. Dialogue and date for the next environmental statement 14
7. Declaration of the environmental expert 16
2

3

1. Changes at the location
In 2023, the existing occupational safety was reorganized in the HSE (Health, Safety & Environment) group.
This was necessary in order to meet the increased legal requirements. The organizational change included,
among other things, an increase in personnel resources.
In addition, various positions were filled within the company, such as the head of the QUS (Quality,
Environment, Safety) department. A new position for a sustainability manager was also created in this
department. There were no significant structural or technical changes with environmental relevance. The
number of employees has increased slightly.
Health, Safety &
Environment
Occupational
safety
Environment
Hazard prevention
& fire protection
Occupational
safety specialists
Incident
manager
Plant fire brigade
Environmental
protection officer
Fire protection
officer
Waste
4

2. Implemented measures
The existing PV system was extended by 165 kWp.
The WHG coating was renewed in selected areas
over an area of more than 500 m². By optimizing the
cooling of one system, it was possible to reduce its
energy requirements by around 30%. A new container
was purchased for the storage of hazardous
substances. The plant fire department's resources
were expanded to include a hazardous goods transfer
pump.
As part of a management resolution, it was determined
that FreiLacke would not place any “toxic” 1
substances on the market. The stricter classification
of ethylene glycol monobutyl ether (EGBE) as part of
the 18th ATP was therefore the reason for a complex
substitution project, as in addition to implementing
the management decision, conformity with the 4th
BImSchV and 12th BImSchV also had to be ensured.
1
In this context, substances with acute toxicity (categories
1, 2 and 3) are defined as toxic in accordance with the CLP
Regulation
5

3. Compliance with laws
Compliance with requirements and obligations mandated by environmental laws
In its environmental policy, FreiLacke has committed to meeting all applicable environmental requirements. In
part, this means complying with the provisions of the following laws and their relevant
provisions, subsequent regulations and official requirements:
Legal area
Example
Waste legislation
• KrWG (Waste Management and Product Recycling Act)
• VerpackG (Packaging Act)
Plant safety legislation
• ÜAnlG (Law on facilities requiring monitoring)
• Directive 2006/42/EC
Occupational safety law
• ASiG (Association for the integration of work/business and school)
• ArbSchG (Occupational Health and Safety Act)
Chemical law and
hazardous goods law
• VO 1272/2008/EC (CLP-VO)
• VO 1907/2006/EC (REACH)
• Agreement on the International Transportation of Dangerous Goods
by Road (ADR)
• ChemG (Chemicals Act)
Energy law
• EnEfG (Energy Efficiency law)
• GEG (German Energy Act for Buildings)
• GEIG (Building Electric Mobility Infrastructure Act)
Water protection law
• WHG (Regulation of the Water Household)
• WG Baden-Württemberg
Federal Immission Control
Act
• BImSchG (Federal Pollution Control Act)
The currently applicable environmental requirements are analysed on a regular basis. This includes the involvement
of the operations representatives, managed using databases and the delegation of duties to the
respective plant operators so that they can implement them. Furthermore, using audits and inspections, the
compliance with obligations arising from environmental laws is assessed on a regular basis and suitable corrective
measures are initiated in case of deviations
Applicable law is adhered to and any legal measures identified have been coordinated with the uthorities.
Identified vulnerabilities are dealt with in cooperation with the responsible authorities and measures determined.
6

7

4. Overview of absolute consumption data/core indicators
Key economic indicators
Employee indicators (as at: 12/31/2023)
Male employees Female employees Total
Döggingen location 489 136 625
Space used (m²)
Built-up area Traffic area Green spaces
Total** company premises: 118.000 m² 76100
**=Recalculation by architecture office Schmelzle+Partner (05/02/2019)
35390
(included in built-up area)
41900
Sold products (t)
2021 2022 2023
Sold products (total) (t) 29337 27784 26976
Powder coatings (t) 20208 19114 18382
Liquid coating materials (t) 9129 8670 8594
Water (m³) 2 2021 2022 2023
Wastewater (m³) 5255 6933 6170
Water for recipes (m³) 976 860 777
Total city water consumption (m³) 6231 7793 6947
Water ratio (m³/t)
Total water consumption (m³) /
products sold (t)
2021 2022 2023
0.212 0.280 0.258
8
2 Waste water from the production processes is properly disposed of as liquid waste

Energy consumption (MWh)
2021 2022 2023
Electricity (MWh) 12359 12114 11822
Gas (MWh) 2445 1939 1618
Total energy consumption (MWh) 14804 14053 13440
Total engergy consumption /solt products (MWh/t) 0.505 0.506 0.498
Total generation of renewable energy 3 (kWh) 251000 292000 266000
Material efficiency (input raw material) (t)
2021 2022 2023
Synthetic resins (t) 19415 16792 16229
Solvents (t) 1944 1946 2128
Other raw materials (t) 9388 8522 7887
Raw material, total (t) 4 30747 27260 26224
Raw material / quantity sold (t) 104.8 98.1 97.2
Total waste(kg)
2021 2022 2023
Total waste (kg) 5 1771236 1625481 2312264
Non-hazardous waste (kg) 1579268 1405913 2071929
Hazardous waste (kg) 191968 219568 240335
3 Electricity from our own photovoltaic systems
4 Shifts due to stock levels
5 From the 2nd quarter of 2023, some of the wastewater produced will be disposed of as waste.
9

Waste - Hazardous waste (kg)
Designation 2021 2022 2023
Paint and coating waste with organic solvents 6 139796 166099 186597
Paint and coating removers with organic solvents
32706 31819 30878
Solvents and solvent mixtures 11991 12845 13040
Other hazardous waste 7475 8805 9820
Total hazardous waste (kg) 191968 219568 240335
Waste - Non-Hazardous waste (kg)
Designation 2021 2022 2023
Coating powder 7 677590 573750 702370
Paper and cardboard packaging 244470 192310 252090
Mixed metals 147480 151270 150540
Mixed municipal waste/
(residual waste without recyclable materials)
163190 160620 161920
Aqueous suspensions liquid coating - - 187579
Aqueous suspensions powder coating - - 229720
Other non-hazardous waste 346538 327963 387710
Total non-hazardous waste (kg) 1579268 1405913 2071929
Sold products (t) 29337 27784 26976
Hazardous waste/
products sold (kg/t)
Non-hazardous waste/
products sold(kg/t)
6.54 7.90 8.91
53.83 50.60 76.81
10
6 Solvents
7 Modified requirements for reconditioning

Emissions greenhouse gases (t)
2021 2022 2023
CO 2
internal (heating) (t) 488 388 324
CO 2
external (electricity) (t) 8 6958 0 0
Total emissions (t) 7446 388 324
Emissions ratio greenhouse gases ( kg/t )
2021 2022 2023
CO 2
internal (heating)/ sold products 16.6 14.0 12.0
CO 2
external (electricity)/ sold products 237.2 0.0 0.0
CO 2
total/ sold products 253.8 14.0 12.0
Other emissions ( NOx, VOC,…) ( t )
2021 2022 2023
Sulphur dioxide SO2 (t) 0.099 0.079 0.066
Nitrogen oxides NOx (t) 0.562 0.447 0.373
Particulate matter PM (fine dust) (t) 9
from production processes
5.255 4.971 4.780
Organic solvents (VOC) (t) 17.32 44.00 10 43.24
Total other emissions (t) 23.24 49.50 48.46
Emission ratio other emissions ( NOx, VOC,…) (kg/t)
2021 2022 2023
Organic solvents (VOC)/ sold products (kg/t) 0.59 1.58 1.60
Total other emissions/ sold products 0.792 1.781 1.796
8 Conversion to 100% green electricity
9 Extrapolation of the results of emission measurements based on production quantities
10 Revised projection based on newly carried out measurements of captured exhaust gases
11

5. 2023 environmental programme (goals),
Outlook & sustainability
Nr. Ziele Einheit Basis (2022) 2023 Ziel (2025)
1
Sustainability to
become a CO 2
-neutral
company (target
by 2026)
Concept study
on a CO2 programme
leading
to a CO2-neutral
company
Sustainability
report in 2025
(for 2024)
1-1 Scope1* t CO 2
916.0 829 724
1-2 Scope2* t CO 2
0.0 0 0
1-3 Scope3
"Development
of road map"
2 Power consumption kWh/t 411.6 422.1 401.3
3
Compressed air
specific consumption
m³/t 267.5 280.4 260.9
4 Heating energy kWh/t 105.2 99.3 94.6
5
Waste
Liquid coating production
kg/t 21.1 46.3 20.0
6
Waste
Powder coating
kg/t 39.5** 57.0 37.0
7
Reduction
Total VOC emissions
from liquid coating
production
% 2.35 1.8 < 1.0
** Note on item 6 Waste powder coating production:
Base value was adjusted as 2022 value is not comparable for internal reasons
12

Maßnahmen
• Preparation of sustainability report in 2025 (for 2024)
* Basis of VEA CO2 calculations
Company goal:
Reduction of Scope 1 value from 2021 by 24 % by 2025 and by
30 % by 2026
• Purchase of "indirect CO2-neutral" gas for stationary combustion in heating
• Goal: No further measures as already achieved.
• Development of road map in 2023
• Implementation of roadmap by 2026
• Targeted energy monitoring with building management technology
• Further increases in efficiency through better control of machines and
systems
• Weekly recording and checking of meter readings.
In the event of deviations, measures can be taken.
• Greater use of electric drives instead of compressed air operation
• Permanent monitoring and elimination of leaks in the compressed air
network
• Improved control of temperatures and times in the heating circuit
• Retrofitting of high-speed doors on external doors
• Increasing the first hit rate and process capability
• Reducing production losses
• Improving the grinding process and increasing the efficiency of the set-up
and cleaning processes
• Increasing the first hit rate and process capability
• Reducing production losses
• Improving the grinding process and increasing the efficiency of the set-up
and cleaning processes
• Basis = solvent balance 2022 as a basis
• Reduction of diffuse solvent emissions through optimised methods, processes
and more environmentally friendly media.
• The reduction target should be achieved by 2024.
13

6. Dialogue and date for the next
environmental statement
The next FreiLacke environmental statement will be more comprehensive and is expected
to be released in 2026. Between them, the company will prepare an updated environmental
statement annually for internal purposes.
The environmental statement is meant to inform the public and employees who actively
participate in the improvement of the company's environmental performance. This environmental
statement was prepared with the assistance of dedicated employees from different
departments. We are always willing to talk about the steps we take to protect the
environment. Please contact info@freilacke.de.
Bräunlingen-Dögginen, 06/20/2024
Dr. Rainer Frei
Managing director,
Commercial director
Dipl.-Ing. Hans-Peter Frei
Managing director,
Technical director,
Environmental management
representative
Rosemarie Vasseur
Works council chairman
14

15

7. Declaration of the environmental expert
The signatory, Dipl. Biol. Lennart Schleicher, EMAS environmental expert (registration
number: DE-V-0404, accredited for the area C20.3 (NACE Code), affirms to have examined
that the site and/or the entire organisation
Emil Frei GmbH & Co. KG
Am Bahnhof 6
78199 Bräunlingen/Döggingen
(registration number: DE-169-00006) – has met all requirements of Regulation (EC) No
1221/2009 of the European Parliament and of the Council of 25 November 2009 and
the amending Commission Regulation (EC) 2017/1505 of 28 August 2017 on the voluntary
participation by organisations in a Community eco-management and audit scheme
(EMAS), as the organisation has stated in its updated environmental statement.
The signing of this declaration confirms that
n the assessment and validation were carried out in full compliance with the require
ments of Regulation (EC) No. 1221/2009, updated by Regulation (EU) 2017/1505 and
Regulation (EU) 2018/2026,
n the result of the assessment and validation confirms that there is no evidence of
non-compliance with the applicable environmental regulations,
n the data and information in the organisation's environmental statement provide a relia
ble, credible and truthful picture of all of the organisation's activities within the area
specified in the environmental statement.
This declaration cannot be equated with an EMAS registration. EMAS registration
can only be carried out by a competent body in accordance with
Regulation (EC No. 1221/2009. This declaration may not be used as a stand-alone basis
for informing the public.
Höchstadt, 06/20/2024
Dipl.-Biol. Lennart Schleicher
Umweltgutachter
16

„
WHAT WE DO TODAY,
D E T E R M I N E S ,
WHAT THE WORLD
LOOKS LIKE TOMORROW.
(Marie von Ebner-Eschenbach)
“
This environmental
statement was prepared with
the the help of dedicated employeesfrom
various departments.
Responsibility for the
content and design of the statement
lies with the management
and the environmental officer.
17

Räder
Wheels
Fahrzeugbau
Vehicle construction
Maschinen- und Apparatebau
Mechanical engineering
Lohnbeschichter
Job coaters
Funktionsmöbel und Lagertechnik
Functional furniture and storage technology
Bau und Sanitär
Construction and sanitary
FreiLacke | Emil Frei GmbH & Co. KG
Am Bahnhof 6
78199 Bräunlingen / Döggingen
Tel. +49 7707 151-0
info@freilacke.de
www.freilacke.de