Cement Europe welcomes the opportunity to provide feedback to the consultation on the draft EU ETS benchmark values for 2026-2030 and recognises the importance of a robust and effective benchmark framework in supporting both decarbonisation and industrial competitiveness.
Cement Europe queries the purpose and added value of changing the clinker benchmark, which has been applicable from 2013 to 2025 in the EU ETS and has effectively fulfilled its role and driven the ongoing investments. By putting a carbon cost on clinker, the EU ETS strongly encourages the efficient use of clinker in cement and supports the reduction of the clinker to cement ratio.
Regarding the inclusion of binders in the cement benchmarks under the FAR, Cement Europe has serious reservations. On the one hand, there are concerns as to whether this inclusion is consistent with the legal framework and should therefore be declared inapplicable for the benchmark in the EU ETS for grey and white cement. The concept of binders is not covered by the Annex I of the EU ETS directive. On the other hand, treating clinker and hydraulic binders as equivalent products may breach the principle of equal treatment, given their distinct production processes and characteristics. In addition, the definition of “alternative hydraulic binders” remains unclear. Apart from four examples, the European Commission does not define what ‘alternative hydraulic binders’ are. Two of the four mentioned examples (calcium aluminate cement and calcium sulfo aluminate cement) are completely different products than grey or white clinker cement and should not be considered equivalent to grey cement clinker. These concerns have been consistently raised during the process leading to the revision of the new benchmarks, and further clarification would be highly beneficial.
The inclusion of binders in the cement benchmark also creates significant uncertainty regarding the basis for the proposed benchmark values. The benchmark values proposed for grey cement clinker appear to include the inclusion of at least 2 installations not producing grey cement clinker. It is not clear what products these installations actually produced. This lack of transparency makes it difficult to assess their relevance as reference points for supporting decarbonisation in the sector(which is one of the core purposes of the benchmark system). Greater clarity on the underlying data and methodology would therefore be essential to ensure credibility and usability of the benchmarks
More broadly, Cement Europe would like to highlight concerns regarding the timing of the proposed benchmark decision The draft benchmark decision was published in May 2026, while the applicable emissions trading period began 1st January 2026. This timing has created legal uncertainty for operators, including on the definition of the products covered, unknown volumes of free allocations, and resulting in economical damage. For instance, cement prices for the current year 2026 needed to be determined already by the end of 2025, in order to support downstream construction planning and price forecasts.
This timing issue is particularly challenging in the current context where carbon costs are increasing due to tighter benchmarks and the progressive introduction of CBAM, alongside the reduction of free allocation, We therefore suggest to postpone the introduction of the proposed benchmark values with at least one year, preferably two, Such an approach would provide operators with the necessary time to adapt to the updated framework and help ensure a predictable and stable regulatory environment.
Cement Europe remains committed to continued engagement with the Commission to ensure that the benchmark framework effectively supports both the decarbonisation of the sector and its longterm competitiveness.