EU Emissions Trading Scheme

In brief

The EU Emissions Trading System (EU-ETS) is seen as a cornerstone of the European Union's policy to combat climate change. The EU ETS works on the 'cap and trade' principle. Within the cap, companies receive or buy emission allowances which they can trade with one another as needed. After each year a company must surrender enough allowances to cover its emissions. We are currently in Phase III of the EU-ETS, which runs from 2013-2020.  Phase IV of the EU-ETS, which will apply post-2020, is now being debated at EU level.

Our view

In a nutshell, the cement industry views on Phase IV of the EU-ETS are as follows:

  • EU-ETS sectors already contribute proportionately more to the overall EU reduction target than non-ETS sectors. Therefore, the 43% reduction objective and the 2.2% linear reduction factor for phase IV should not be further increased.
  • All energy-intensive industries must be on the carbon leakage list, with all installations receiving free allocation based on ambitious, but realistic, benchmarks.
  • Free allocation should be aligned with actual production, to avoid so-called windfall profits.
  • There should be no cross-sectoral correction factor as this would not respect the European Council Conclusions of October 2014 that require no undue costs for the best performer.
  • No differentiation should be made between sectors. CEMBUREAU is firmly opposed to both the tiering of free allowances and the cross-sectoral correction factor .
  • In order to allow for sufficient free allowances at the level of the best performer, the auctioning/free allowances share proposed by the European Commission (57/43% respectively) needs to be revised in favour of an increase in the free allowances available.
  • More support needs to be provided for innovation in energy-intensive industries. Furthermore, the focus should cover the whole range of low carbon technologies including industrial carbon capture and utilisation (CCU). The Innovation Fund should be fully financed from the auctioning share.

Circular Economy

In brief

On 2 December 2015, the European Commission adopted its ambitious Circular Economy package with four legislative proposals on waste, including a proposal to review the Waste Framework Directive. The Commission's aim is to reduce the amount of waste generated by encouraging improvements in the way waste is managed and recycled at Member State level. To do this, it has set several targets which include the recycling of municipal and packaging waste, and reducing the amount sent to landfill.

Our view

The European cement industry is continuously using waste as a resource, thanks to what we like to call "co-processing". Co-processing is the use of waste as raw material, or as a source of energy, or both to replace natural mineral resources (material recycling) and fossil fuels such as coal, petroleum and gas (energy recovery) in industrial processes. CEMBUREAU is very much in favour of legislation which recognises in addition to energy recovery this form of material recycling and its contribution towards achieving Europe's ambitious recycling targets. Several Member States (Belgium, Bulgaria and France, for example) already account for the recycling of the inorganic content of end-of-life tyres in cement manufacturing. CEMBUREAU’s aim is to get recognition at EU level. As a result, CEMBUREAU is actively advocating for its inclusion under the proposal to review the Waste Framework Directive, particularly under the proposals relating to municipal waste. Below are some key facts about how the cement industry contributes to resource efficiency:

  • About 5% of the raw materials used in the production of clinker in Europe consisted of recycled material and ashes from fuel, totalling about 8 million tonnes per year.
  • In 2014, the European cement industry used an energy equivalent of about 15.8Mt of coal (for the production of 172Mt of cement).
  • Alternative fuels, including waste biomass, constituted 41% of the fuel mix across Europe, saving about 6.5Mt of coal and resulted in 18Mt of avoided CO2 emissions each year. In 1990, the percentage of non-renewable energy gained by the use of waste as a fuel was 3%.
  • 14% of the alternative fuels used by the European cement industry consist of biomass from waste, such as meat & bone meal and sewage sludge.
  • The material recycling component of co-processing contributes towards Member States compliance with EU recycling targets.


Respirable Crystalline Silica

In brief

Crystalline silica is an essential component in a multitude of materials used in industrial production and life. Respirable crystalline silica (RCS) is the respirable dust fraction of crystalline silica which enters the body by inhalation. Although crystalline silica is ubiquitous in nature, the inhalation of RCS may constitute a hazard to workers.

In December 2017, the amended Carcinogens and Mutagens Directive (CMD) was published in the Official Journal. The reviewed directive sets a European Binding Occupational Exposure Limit (BOEL) for RCS generated by a work process at 0.1 mg/m³. From this date forth, the Member States have 2 years to transpose it into national legislation. Nevertheless, most European Member States have already set national RCS OEL values, some of which are stricter than the European value.

Article 18a of the CMD specifies that the European Commission will evaluate the need to modify this limit value as part of the next evaluation of the implementation of the Directive. Article 17a of the directive 89/391/EEC further specifies that “Member States have 5 years to submit an implementation report after CMD enters into force and that the Commission has to inform the results of their evaluation within 36 months”. As a result, the RCS BOELV will not be revised before 8 years.


Our view

CEMBUREAU is a NEPSI Social Dialogue Agreement (SDA) partner, and continues to advocate strongly in favour of formal recognition of the work undertaken by NEPSI under the CMD. The reason for this is that, through the NEPSI Social Dialogue Agreement (SDA), a comprehensive set of guidance and assessments that address the minimisation obligations have been developed, taking into account the wide diversity of industrial circumstances and the best ways to address them with specific sectoral expertise. As such, the SDA is complementary to the general requirements of the Directive and, by following the NEPSI Guidance, the signatories implement these requirements in an informed and tailored way.

NEPSI Social Partners are grateful for the positive recognition granted under Recital 6 of the COREPER agreement on the Directive which acknowledges the role of the Good Practices of the Social Dialogue "Agreement on Workers' Health Protection Through the Good Handling and Use of Crystalline Silica and Products Containing it" (the so-called NEPSI Agreement) as a valuable and necessary instrument to complement the regulatory requirements and to support their effective implementation.

The latest NEPSI reporting year was 2018. CEMBUREAU is proud to report that, thanks to the efforts of its members, 100% reporting of the identified sites has been achieved, and 98.93% of employees potentially exposed to Respirable Crystalline Silica (RCS) are covered by a risk assessment and an improvement was seen in relation to all Key Performance Indicators (KPI).


Energy efficient buildings

In brief

On 30 November 2016, the European Commission launched its “Clean Energy for All Europeans” package.  The package, contains important items relating to buildings, including proposed revisions of the Directives on Energy Performance of Buildings (EPBD), Energy Efficiency (EED) and Renewable Energy, and a new “Smart Finance for Smart Buildings” initiative.


Our view

Using concrete in buildings contributes to energy efficiency thanks to concrete’s high thermal mass. When it is warm, concrete elements absorb excess heat, slowing the rise in temperature in indoor rooms. When temperatures fall in the evening, the concrete releases this heat, keeping indoor rooms at a comfortable temperature. This leads to energy savings and produces a better indoor climate for building occupants. In modern buildings, “thermally activated” building systems, where hot or cold water or air flows through pipes embedded in the concrete, can further boost the effect.  Thanks to its energy-storage effect, thermal mass can also contribute to greater uptake of renewable energy in buildings. Furthermore, thanks to their air-tightness and durability, the energy consumption of concrete buildings is greatly reduced over their whole life.

Given this, CEMBUREAU fully supports the recognition, under the proposed revision of the EPBD, of the contribution of structural building materials with a high thermal mass as in the stipulation in the proposed revision of the EPBD that thermal capacity should be considered when calculating the energy performance of a building. Furthermore, the proposal to assess buildings’ readiness to store energy and respond to the needs of the electricity grid, as part of a proposed “smartness indicator”, is welcomed. As indicated in a recently published study by 3E, commissioned by the Concrete Initiative, thermal mass in heavyweight buildings can provide this flexibility by allowing for consumer energy demand to be shifted in time (“active demand response”) by using structural thermal energy storage.  This could result in up to a 25% CO2 reduction per dwelling, up to 50% reduction in the need for peak electricity supply capacity and savings of up to €300 per household per year.

From a social point of view, CEMBUREAU is pleased to note the importance attributed to indoor environments, and thus the health and wellbeing of occupants, as this must go hand in hand with environmental objectives.  It is also necessary to consider the benefits of making buildings more energy efficient to consumers, in particular those at risk of energy poverty. From a financial perspective, it is clear that the push towards more energy efficient buildings will require adequate financing.  As such, we welcome the Smart Finance for Smart Buildings initiative and its focus on improving access to public and private funds for energy efficiency investments.