With a letter from BACI to the Ministry of economy, the following statement on the topic was raised.

Sub-priority 4.1.

Transition to Circular Economy

• The cement industry is a key player in the circular economy and this throughout its value chain.
• In its manufacturing business, the cement industry plays a central role in waste management policies as it sources different types of waste which it uses as alternative energy to heat the kilns and as alternative raw material. Already today, the cement sector in Europe substitutes an average 46% of its fuels with waste & biomass and its aim is to take that up to 60% (30% biomass) by 2030 and 90% (50% biomass) by 2050.
• There are no technical barriers to achieve these levels and some plants in Europe already do.

The barriers to uptake are rather regulatory in nature, both at EU and national level:

1. There should be a landfill ban across the EU.
2. Separate waste collection and sorting should be prioritised in Member States.
3. Co-processing should account for municipal waste recycling in EU waste legislation.
4. EU legislation should recognise co-processing as higher than incineration in the waste hierarchy since part of the material is recycled into clinker.
5. In its downstream business, concrete is 100% recyclable as recycled aggregate in construction (upcycling) or in road subbase (downcycling), both should be fully recognised for their contribution to the circular economy in terms of savings of primary materials.

The main barrier to achieve high waste utilization levels in Bulgaria (both for co-incineration and recycling) is the poor control over the implementation of the waste related legislation. Everybody can provide examples in the areas of illegal landfilling, lack of control over the landfilled materials in the regional depots, “evaporation” of some waste streams, burring of hazardous wastes, etc.

Government/ Ministry of Environment needs to implement effective system to stimulate all Municipalities to recycle and utilize the household wastes. Promotion and close cooperation with Bulgarian Municipalities for selection of proper installations will contribute to targets achievement and significant reduction of landfilled wastes. Cement industry in Bulgaria could be reliable partner in collaboration with local Municipalities to achieve the forthcoming years target having in place environment friendly technologies for waste utilization.

Sub-priority 4.2.

Transition to Low-carbon Economy

CEMBUREAU’s Carbon Neutrality Roadmap, which was launched on 12th May 2020, studies the pathways to reach the objective of carbon neutrality. It looks at how CO2 emissions can be reduced by acting at each stage of the value chain – clinker, cement, concrete, construction and (re)carbonation – to achieve zero net emissions by 2050. To get there, the sector will need decisive political action from the EU in some key areas identified in the roadmap, including:

1. The development of a pan-European CO2 transportation and storage network;
2. As noted above, decisive action on circular economy to support the use of non-recyclable waste and biomass waste in cement production and to foster the uptake of concrete recycling in policies around construction and demolition waste;
3. Ambitious policies to reduce European buildings’ CO2 footprint, based on a life-cycle approach that incentivises the market uptake of low-carbon cements;
4. A level playing field on carbon (for instance through carbon border mechanisms), regulatory certainty and an ambitious industrial transformation agenda.