Comments to the MOEW on the proposal for Taxonomy

In connection to the letter from MOEW, referring to the proposal for a Regulation of the European Parliament and of the Council establishing a framework to encourage investment in sustainable development – opinion on a consultation on the TEG report on EU taxonomy and the Technical Expert Reports that have already been published, BACI announces the following statement and comments, in accordance to the CEMBUREAU’s policy.

CEMBUREAU, the European Cement Association, of which BACI is a Member, represents cement companies in 26 of the 28 Member States of the European Union and covers 95% of the cement production in the EU 28. CEMBUREAU has been participating, along with selected cement companies, in the Technical Expert Group on Sustainable Financing – Manufacturing sub­group focusing on manufacturing of cement (the “TEG”). The Technical Expert Group feeds into the European Commission’s work on taxonomy which seeks to identify investments that can be considered « green investments » by private investors.

In response to consultation on the TEG report for proposed technical criteria published in June 2019, BACI as a part of CEMBUREAU, submits the following comments and statement:

  • For traditional cements the manufacture of clinker is the most CO2 intensive part. Therefore, CEMBUREAU considers that the specific emissions of CO2 per ton of clinker is a commonly accepted metric for the start of the assessment of technologies and products associated with the production of clinker.
  • The TEG also refers to a metric of CO2 per ton of cementitious materials. The value proposed by the TEG for the multiplication of the clinker threshold with the clinker substitution factor (65%) is based on non-European and non-verified information and therefore is not appropriate. There are long term uncertainties associated with the availability of these materials due to the closure of coal fired energy generation and blast furnaces, which issue is recognised by the IEA in its roadmap. Therefore, we suggest that a European differentiated metric on CO2 per ton cementitious materials with the corrected value on clinker substitution factor (70%) be used in the current TEG proposals as metric for 2050 referring Building Carbon Neutrality in Europe.
  • The use of clinker and cement substitutes in concrete is not taken into account in this approach, and therefore this simple approach misses part of the real benefits for climate change abatement. BACI through CEMBUREAU would welcome the possibility to work together with the TEG on this in the future.
  • In the longer term, taxonomy should not be limited to cement products (as intermediate product in the value chain) but should be based on the built environment with concrete as key and sustainable building material. At this moment we acknowledge that such an approach is too ambitious, but we would welcome the possibility to work together with the TEG on this in the future.

In the final TEG report on taxonomy it should be clarified that sustainable finance should be accessible to projects that improve environmental performance to reach the thresholds in the taxonomy criteria.