BACI https://bacibg.org Българска асоциация на циментовата индустрия Thu, 16 Jul 2026 12:08:02 +0000 en-GB hourly 1 https://wordpress.org/?v=5.2.21 Ahead Of The EU Circular Economy Act Circularity Of Cement And Concrete https://bacibg.org/en/ahead-of-the-eu-circular-economy-act-circularity-of-cement-and-concrete/ Thu, 16 Jul 2026 12:08:02 +0000 https://bacibg.org/?p=1952 The ambition of increasing the EU’s strategic autonomy and transitioning towards a competitive and increasingly circular economy is one which Cement Europe actively supports. The European Commission’s 2026 Work Programme … Read More

The post Ahead Of The EU Circular Economy Act Circularity Of Cement And Concrete appeared first on BACI.

]]>
The ambition of increasing the EU’s strategic autonomy and transitioning towards a competitive and increasingly circular economy is one which Cement Europe actively supports. The European Commission’s 2026 Work Programme foresees in the publication of a Circular Economy Act in Q3 of this year. This initiative presents a unique opportunity to further elaborate and consolidate the EU’s regulatory framework with the objective of fostering industry’s competitiveness and bolstering its strategic independence. Below, we outline the three main areas along the cement-concrete value chain where the sector provides a unique circular economy contribution:

1. Co-processing: circularity of waste streams to reduce dependency on fossil fuels and primary raw materials

As a hard-to-abate sector with two thirds of the carbon emissions coming from the manufacturing process, electrification is not the key to decarbonise the cement industry. In co-processing, the combustible fraction of waste and biomass replaces fossil fuels for use in the cement kilns, while the mineral fraction can be incorporated into clinker and substitute virgin raw materials. the application of alternative fuels in the cement industry shall be considered as partial recycling (15%) of the material input and partial energy recovery. This leaves no waste residue, making it an inherently circular waste management solution. However, this is not accounted for in the current hierarchy.

As a hard-to-abate sector with two thirds of the carbon emissions coming from the manufacturing process, electrification is not the key to decarbonise the cement industry. In co-processing, the combustible fraction of waste and biomass replaces fossil fuels for use in the cement kilns, while the mineral fraction can be incorporated into clinker and substitute virgin raw materials. the application of alternative fuels in the cement industry shall be considered as partial recycling (15%) of the material input and partial energy recovery. This leaves no waste residue, making it an inherently circular waste management solution. However, this is not accounted for in the current hierarchy.

The cement sector currently utilises ~40 million tonnes of alternative fuels per year. The waste materials used in the cement industry come from a variety of streams and includes, for instance, the biogenic fraction in refuse derived fuels (RDF), end-of-life tyres, saw dust from related industries, animal meals, agricultural waste or wood waste (please see Cement Europe’s brochure for more information). These biogenic waste streams are unsuitable for other uses.

In 2023, cement plants in the EU substituted on average 56% of their fossil fuel consumption with nonrecyclable waste derived fuels, 22% of which was bio-waste. Cement Europe’s Net Zero Roadmap (2024) aims to reach 60% alternative fuels by 2030, and 95% by 2050, with more than half (50%) biomass waste. At current rates, the sector is avoiding >20 million tonnes of annual CO2 emissions, supporting our vision for a carbon neutral Europe for 2050 and contributing to a circular waste management strategy.

The forthcoming Circular Economy Action Plan provides an opportunity to acknowledge the central role of the cement sector in waste management by focusing on the following key measures:

  • Create a dedicated recovery option for co-processing under the Waste Framework Hierarchy, aligned to recovery operation as mentioned in ISO 4349:2024, Solid Recovered Fuels Determination of the Recycling Index for Co-Processing. the contribution of the cement sector to the waste management value chain through co-processing should be acknowledged in the Waste Framework Directive and taken into account in the recycling targets of the Member States. The current categorisation of co-processing under the WFD restricts the supply of fuels to plants. Co-processing is placed in the “other recovery” category of the waste hierarchy, thereby failing to recognise the dual effect of co-processing. This categorisation places co-processing on an equal footing with less efficient and less circular treatment methods, such as incinerators. Not only is there no recycling element involved in such other methods; but there are multiple, fully renewable alternatives for heat & electricity generation for such other sectors. Accounting for either energy recovery or recycling, the current waste hierarchy fails to acknowledge treatment methods whereby material is simultaneously recovered and recycled as raw material in addition to energy recovery – as in the case of co-processing and clinker.
  • Formally remove unintended Renewable Energy Directive (RED) certification requirements for the use of biomass in cement kilns (articles 29 (1) and 30(3)). The Renewable Energy Directive causes significant obstacles in accessing waste. The sustainability classification under the RED applies to the biogenic fraction of waste used as fuel in cement kilns, requiring it to comply with the greenhouse gas savings criteria and certification. Although biomass is a fundamental decarbonisation lever in cement production, there is now a high degree of regulatory uncertainty surrounding its use – therefore disincentivising procurement. Cement plants do not produce heat for the purposes in the scope of the RED. The biogenic content of waste, as well as for the secondary solid fuel used in kilns for the production of the clinker, are used exclusively as a heat input to the relevant production process. There is no direct electricity, heating or cooling production to be fed into the grid. Some Member States – such as Germany, Italy, and Bulgaria – have already set the precedent for providing explicit scope exclusion . In addition, the European Commission has suggested, in its EC Guidance document “Biomass and other zero-rating under the EU ETS” (version 3), to omit the GHG savings requirement when municipal or industrial waste is used directly for combustion. In order to adopt an EU-harmonized approach on this issue, Cement Europe suggests that the upcoming revision of Annexes V and VI of the Renewable Energy Directive (RED), expected in Q3 2026, formally remove the Renewable Energy Directive (RED) certification requirements for the use of biomass in cement kilns.
  • Divert waste away from landfilling and less circular treatment methods , and towards higher added value treatment options, such as co-processing in the cement industry.
  • Establish a level playing field among waste users: Waste incinerators are currently not covered by the ETS Directive. This disparity in treatment creates a major imbalance in Europe’s carbon accounting rules and leads to unfair competition in access to alternative, non-fossil, fuels that industry could use to support its competitiveness.

2. CO2 use as feedstock

Cement Europe Cement Action Plan points out that the cement sector is one of the hard-to-abate sectors with process emissions representing 2/3 of overall CO2 emissions. Reaching the net-zero ambition by 2050 requires a combined use of traditional levers (alternative fuel and raw material use, clinker substitution, energy efficiency, etc.) and breakthrough technologies such as carbon capture and storage with the latter representing about 43% of the sector’s overall emission reduction effort in 2050.

Captured carbon from cement kilns can either be permanently geologically stored or use in a variety of products and materials (CCU). Such carbon use options are vital for many EU cement kilns which are landlocked and not located next to CO2 storage sites. Through CCU, the cement sector can provide a significant stream of concentrated CO2 for use in various sectors of the economy, allowing to decarbonisation and cut the EU’s reliance on fossil fuels.

A study carried out by VITO for Cement Europe1 on the topic estimates that there will be a need for between 250 million tonnes and 450 million tonnes of CO2 by 2050 for a variety of industrial applications (transport fuels; chemicals; food and beverages; metal fabrication; others). CO2 sourced from accessible biogenic sources is estimated between 21 and 63 million tonnes by 2050. On its side, the EU Commission estimates CO2 from Direct Air Capture (DAC) to reach 5 million tonnes by 2030 and has no estimate for 2050.

In addition to the CO2 accounting issues and the permanent or non-permanent character of CO2 use, both issues that will be dealt with under the upcoming review of the EU ETS, the Circular Economy Action Plan offers the opportunity to lay out the level of demand for CO2, differentiated by source (industrial, biogenic, direct air capture) and clearly establish that CO2 from industrial sources as a key input into a circular economy value chain.

3. Concrete recycling

Cement is the essential intermediate to produce concrete, a material that is inherently local, durable, and 100% recyclable, qualities that make it a key enabler of circular construction across Europe.

Concrete is the largest material fraction in construction and demolition waste in every region in the EU, ranging between 38% in Northern Europe to ca. 61% in Western Europe2. On its turn, construction and demolition waste accounts for one third of all waste generated in the EU.

From this perspective, the recycling of concrete substantially contributes to Europe’s circular economy model. Concrete recycling is realized in various steps of the value chain, i.e., in concrete, in cement or in clinker production.

Various changes in practice at each point in the concrete life cycle, from design to end of life, will improve the availability of clean and high-quality recycled aggregates to be able to reach high recycling rates.

To further encourage the recycling of concrete while also ensuring the best environmental outcomes, Cement Europe calls for the Circular Economy Act to:

  • Encourage pre-demolition audits and sorting demolition waste, to ensure high-quality recyclable material can reach the market.
  • Phase out landfilling of construction and demolition waste. Diverting demolition waste from landfill keeps the material in the economy and encourages the market to find solutions for its use.
  • Avoid simple targets on recycled content of concrete. Recycled content targets for concrete are difficult to meet and do not necessarily lead to an overall reduction in the environmental impact. This is because supply of recycled materials may not always be available locally and may require transport; concrete made of recycled aggregates may not have the lowest environmental impact; and recycled aggregates are often technically more suitable for other applications. Instead, a circular economy approach needs to encourage all recycling that results in a reduced use of virgin materials & energy, be it “open loop” or “closed loop.
  • All (= 100%) concrete & demolition waste should be recycled.

Cement Europe looks forward to being an active part of the discussions on the EU Circular Economy Action Plan.

The post Ahead Of The EU Circular Economy Act Circularity Of Cement And Concrete appeared first on BACI.

]]>
Omnibus VIII: Industrial Emissions Directive https://bacibg.org/en/omnibus-viii-industrial-emissions-directive/ Mon, 06 Jul 2026 11:26:52 +0000 https://bacibg.org/?p=1948 Executive summary Cement Europe welcomes the simplification objectives of the Environmental Omnibus VIII package but considers that further targeted adjustments to the Industrial Emissions Directive (IED) are necessary to ensure … Read More

The post Omnibus VIII: Industrial Emissions Directive appeared first on BACI.

]]>
Executive summary

Cement Europe welcomes the simplification objectives of the Environmental Omnibus VIII package but considers that further targeted adjustments to the Industrial Emissions Directive (IED) are necessary to ensure proportionality, legal certainty and practical implementability for cement installations.

In particular, Cement Europe calls for greater flexibility in the setting of emission limit values within the full BAT range, for non-binding treatment of environmental performance indicators beyond emissions to air, and for the removal of disproportionate OTNOC monitoring requirements for waste co-incineration in cement kilns. Finally, Cement Europe urges the Commission to “stop the clock” on the implementation timeline to allow these adjustments to be agreed before transposition.

General assessment

Cement Europe welcomes the following simplification measures proposed by the Environmental Omnibus package (OMNIBUS VIII):

  • Increased automation, reduced reporting and the removal of duplications in environmental impact assessments
  • The possibility to implement Environmental Management Systems (EMS) at company level rather than installation level, together with extended implementation timelines
  • The removal of the obligation to include transformation plans in EMS

However, specifically on the proposal for a directive amending Directives 2008/98/EC, 2010/75/EU, (EU) 2015/2193 and (EU) 2024/1785 as regards simplification of certain requirements and the reduction of administrative burden, Cement Europe would like to propose several targeted improvements to the Industrial Emissions Directive (Directive 2010/75/EU):

  • allow the full BAT associated emission range to be taken into account rather than applying the strictest achievable emission limit value;
  • remove binding limit values for environmental performance indicators other than emissions to the air; or alternatively, make these limits indicative;
  • remove co-incineration in cement plants from the monitoring obligations during OTNOC.

  1. Allow use of the entire BAT range

The most recently revised version of the IED (Directive (EU) 2024/1785) emphasises that emission limit values should be set as strictly as possible (based on the applicable BAT reference document). Moreover, requiring emission limit values, taking into account “cross-media effects” and the “best possible overall performance of the plant”, means that emission limit values will need to be determined on a fully case by case basis for each installation during the permitting process. This will require extensive expert assessments, leading to more complex procedures and longer approval timelines Cement Europe therefore stresses the need to restore the flexibility to determine limit values based on feasibility and aligned with the specific conditions of the installation.

Beyond this, Cement Europe welcomes that fact that the directive allows deviations from conventional limit value setting. However, we see the need for an explicit reference to “freight-related terms” to ensure that load-related limit values, such as grams of pollutants per tonne of product, can be used. This would allow fair and transparent comparison between conventional and innovative processes of air pollutant emissions and fuels, especially where neither an established “state of the art” nor reliable emission data from existing installations are available for certain technologies.

  1. Environmental performance limit values

Cement Europe set out its decarbonisation trajectory in its Net Zero Roadmap, and its members continue their efforts to reduce emissions. Nonetheless, concerns remain, however, regarding potential conflicts of interest between the measures to tackle emission to air, (re) use of water, waste and energy. To effectively support the directive’s objective of preventing and controlling pollution from industrial activities, Cement Europe does not consider binding limits for resource efficiency, resource consumption and waste generation to be beneficial. It is also not clear how the associated limit values would be formulated and assessed in terms of their environmental relevance. Indeed, for rotary kiln plants the relevant parameters are highly site specific, making standardisation impossible. Resource consumption is influenced by a wide range of factors, such as local water availability or the specific characteristics of raw materials. Cement Europe therefore suggests either removing the reference to the binding nature of these limits or to change the word binding to “indicative”.

  1. Adjust “OTNOC” monitoring requirements

The monitoring obligations for waste co-incineration plants during start-up and shutdown operations introduced in Article 48(1) IED are impracticable and ultimately disproportionate for rotary kiln plants in the cement industry. Crucially, waste-based fuels are not used at all when starting up or shutting down kilns, which is why this requirement is completely irrelevant to the clinker burning process at this stage. What’s more, these changes are not aligned with the already published reference document for best available techniques (BREF/BAT) for the cement sector. The BREF already contains stringent provisions for the prevention of emissions and the limitation of PCDD/F emissions from the flue gases of kiln firing processes. Any corresponding changes in the handling of these compounds should only be addressed within the framework of the Seville Process, and only in the context of a BAT review. It should also be noted that Chapter IV of the IED, which includes Article 48(1), specifically regulates requirements related to waste incineration and waste co-incineration.

  1. Stop the clock

In view of the transposition deadline of 1 July 2026, Cement Europe calls on the European Commission to introduce a “stop the clock” measure to allow the co-legislators sufficient time amend the IED before Member States are required to implement the new obligations introduced by IED by Directive (EU) 2024/1785.

The post Omnibus VIII: Industrial Emissions Directive appeared first on BACI.

]]>
Key Requirements for an Effective and Predictable CBAM https://bacibg.org/en/key-requirements-for-an-effective-and-predictable-cbam/ Mon, 06 Jul 2026 11:23:47 +0000 https://bacibg.org/?p=1944 The undersigned CBAM sectors strongly support CBAM and its objective to create a level playing field with third countries on carbon costs by mirroring the requirements imposed by the ETS … Read More

The post Key Requirements for an Effective and Predictable CBAM appeared first on BACI.

]]>
The undersigned CBAM sectors strongly support CBAM and its objective to create a level playing field with third countries on carbon costs by mirroring the requirements imposed by the ETS on EU operators. It is an important piece of the wider puzzle to create the conditions for sustained investment in low-carbon technologies while supporting the EU’s broader climate objectives and maintaining the international competitiveness of EU Industry.

In this context, we welcome the European Commission’s (EC) proposal from December 2025 to strengthen CBAM by expanding anti-circumvention provisions, extending CBAM’s scope to selected downstream sectors and tightening traceability provisions. While we support the general direction, we believe that certain provisions could be further reinforced or clarified to ensure the mechanism’s effectiveness, predictability and coherence with the EU ETS.

More specifically:

Anti-circumvention. Ensuring that CBAM is protected against circumvention is essential to safeguard its environmental integrity and its role in maintaining a level playing field between EU production and imports.

Resource shuffling. While the Commission proposal introduces the concept of abusive practices, it does not explicitly cover resource shuffling, when cleaner production is channeled to the EU while more carbon-intensive production is redirected elsewhere or delivered for the national market. This practice must be explicitly addressed to prevent circumvention of CBAM obligations. Criteria for identifying it should be set, including where there is a demonstrable divergence of emission intensity between EU-bound goods with goods exported to non-EU markets or supplied domestically, to enable the subsequent inclusion of codes and origins in a dedicated Annex. The use of actual values for imports covered by the annex should be conditional upon an assessment that no resource shuffling has taken place.

Export solution. CBAM sectors call for a lasting solution covering exports to remedy the lack of equivalent carbon costs for foreign producers competing on foreign markets. This should be designed in a manner to ensure EU producers are not uncompetitive in non-EU markets due to the asymmetry in regulatory, carbon and energy costs, notably through a WTO-compatible continuation of free allocations for exports. It is a matter of survival within these export markets.

Removal of goods from CBAM. Ensuring that decarbonization investments of EU ETS sectors are not at a disadvantage from unfairly traded imports that do not bear a comparable carbon cost is essential. This is all the more critical given that CBAM sectors are progressively losing ETS free allowances, previously granted under ETS, in exchange for CBAM protection. Therefore, any mechanism allowing unexpected removal of goods from CBAM, whether to avoid short-term market or geopolitical disruptions, or to relieve political pressure from downstream sectors or users is counterproductive. Such measures would be detrimental to the proper functioning of the entire ETS system, and would undermine the predictability of decarbonization investments. While removal of goods from CBAM could, in principle, be envisioned, it should only be possible following a thorough, detailed analysis and consideration of all relevant factors and impacts. Such an assessment can only be credibly ensured through the full legislative procedure – with full involvement of both the Council and the European Parliament. For these reasons, proposed Article 27a should therefore be deleted in its entirety.

Removal of countries from CBAM. Similarly, any expedited exemption of countries from CBAM should be avoided for the reasons set out above. Also, considering that importers’ obligations are calculated and settled on an annual basis, a limited delay – as required by Council and EP scrutiny of EC delegated acts – cannot be considered a material obstacle to removal of countries in duly justified and exceptional circumstances. In light of persistent international pressure from trading partners opposed to CBAM, despite the absence of a genuinely comparable carbon pricing system, is likely to intensify. For this reason, the European Commission should be immune to such pressures and exemption decisions should not be taken on the basis of short-term political considerations. Accordingly, proposed art. 28a should be deleted in its entirety.

Traceability and composition. Increased traceability of imported goods is key to proper risk assessment and effectiveness of CBAM. For this reason, identification of material and chemical composition of imported goods in their customs declaration via detailed TARIC codes, as well as identification of the specific place of production of goods for which circumvention risk has been identified – as proposed by the European Commission in its December proposal – should be encouraged and – where possible – become the norm, rather than the exception.

International Credits. Given the increasing price and expected shortage of EU ETS allowances, alternative methods for payment for carbon should be encouraged. However, an equal playing field for EU producers and EU importers must be ensured. For this reason, CBAM sectors oppose any introduction for 3rd country carbon price payments via international art. 6 carbon credits within the CBAM until EU industry has the same possibility under the EU ETS.

We look forward to working with the legislators to ensure an efficient and robust CBAM mechanism that helps to create the right conditions for EU climate goals while safeguarding industrial competitiveness.

The post Key Requirements for an Effective and Predictable CBAM appeared first on BACI.

]]>
Input to EU ETS ben chmark consultation https://bacibg.org/en/input-to-eu-ets-ben-chmark-consultation/ Thu, 02 Jul 2026 16:24:23 +0000 https://bacibg.org/?p=1938 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 … Read More

The post Input to EU ETS ben chmark consultation appeared first on BACI.

]]>
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.

The post Input to EU ETS ben chmark consultation appeared first on BACI.

]]>
Cement Europe Position On The Eu Proposal For Industrial Accelerator Act https://bacibg.org/en/cement-europe-position-on-the-eu-proposal-for-industrial-accelerator-act/ Thu, 02 Jul 2026 16:12:13 +0000 https://bacibg.org/?p=1930 The IAA covers energy-intensive industries and refers to the cement industry as a high emission intensity sector with a strategic role for the clean transition. In this context, Cement Europe … Read More

The post Cement Europe Position On The Eu Proposal For Industrial Accelerator Act appeared first on BACI.

]]>
The IAA covers energy-intensive industries and refers to the cement industry as a high emission intensity sector with a strategic role for the clean transition. In this context, Cement Europe welcomes the IAA as it addresses the development of lead markets for low carbon products. Through its Net Zero Roadmap and the Cement Action Plan, the European cement industry has strongly emphasised the need for policy levers that facilitate the uptake of low carbon products as a necessary complement to the policy drivers that incentivise the decarbonisation of the manufacturing process.

Cement Europe would like to bring to the attention of the co-legislators two main issues to be addressed in the upcoming discussions on the IAA:

Lack of clarity on the scope and definition of low carbon products

Where cement is publicly procured, its place in Annex II IAA (low carbon and EU origin requirements) needs clarification. The scope should be “concrete, mortar and cement, including the clinker used to produce them, intended for use in buildings and infrastructure .”

The inclusion of cement within the scope is in line with the IAA’s objective to create lead markets for cement. In the IAA impact assessment, it is stated that the significant share (31%) of public procurement in the overall European cement market “underscores the public sector’s leverage in securing the offtake of low-carbon cement in construction and infrastructure, driving broader market transformation within the cement industry ”. It is exactly this link with the industry’s transformation that justifies the inclusion of cement within the scope and the setting of cement-specific thresholds. The threshold should be set at a level which allows the generation of financial leverage for capital intensive decarbonisation projects while at the same time, allowing a robust uptake level of low carbon products.

Starting from the assessment made in the Commission’s Impact Assessment which focuses on FID projects for low carbon cements by 2030 (Carbon Capture and Storge (CCS) (mainly) and Secondary Cementitious Materials (SCM) projects) representing 1% of EU overall production, Cement Europe considers the following threshold relevant for the upcoming discussions. The low carbon categories are based on the banding system set out in Annex.

  • 25% of cement used in public procurement shall be low carbon by 2029, ranging from Near Zero to band C (see table in annex) whereby the Near Zero products would count double towards that target. Member States have the flexibility to include band D under the conditions referred to in Article 11(3) IAA. Targets should be updated progressively, at least every five years, based on technological progress and product availability.

Where concrete is publicly procured or in cases where cement and SCMs are added separately by concrete manufacturers during production, Cement Europe supports a methodology that allows for a consistent approach between cement and concrete.

Definition of EU origin

The definition of EU origin as encompassing third countries with which the EU has free trade agreements or a customs union and countries that are partners to the “Agreement on Government Procurement”, extends the EU origin far beyond the EU 27. Such extensive definition is contrary to the IAA’s objective of boosting the EU’s industrial competitiveness. It also ignores the need to strengthen and reinforce the EU internal market which is the cornerstone of Europe’s economic and social prosperity.

Therefore, Cement Europe suggests limiting EU origin to clinker produced in EU ETS installations and countries with an ETS linked system (Norway, Switzerland and, subject to the ongoing linking negotiations, the UK).

As an overall remark and aware of the objective of the IAA, Cement Europe reiterates the importance of securing a competitive international level playing field and promoting the EU’s industrial base. In that regard, the IAA needs to be designed in complement to a fully effective and watertight CBAM and European Commission efforts to explore potential trade measures where necessary.

We trust that these preliminary comments are useful for the upcoming discussion in the Council and remain available for a more detailed exchange on this topic throughout the negotiations.

Annex – IEA low emission production intensity thresholds proposal from the report “Achieving Net Zero Heavy Industry Sectors in G7 Members” 1 adapted by Cement Europe to make the framework relevant for the European Union

Cement Europe has developed a definition of low carbon cement based on a banding system2. The scheme is implemented in Germany as the voluntary Cement Carbon Class (CCC) and can serve the Commission in developing an environmental sustainability labelling requirement for cement:

  • Cement types are plotted according to their Global Warming Potential (GWP) values against their clinker-to-cement ratios from national Environmental Product Declarations (EPDs) or, when available, from the environmental performance in DOPCs in accordance with EN 15804 and EN 16908 (Product Category Rules for cement).
  • The classes below are fixed to clinker to cement ratio of 0.70.
  • The Near Zero band defined by the IEA 3 has the lowest carbon footprint, based on full carbon capture projects.
Classes for cement   Requirement (GHG)
CO2 eq / ton of cement
Low carbon cements D 400 ≤ GHG < 500
C 300 ≤ GHG < 400
B 200 ≤ GHG < 300
A 100 ≤ GHG < 200
Near Zero < 100

The post Cement Europe Position On The Eu Proposal For Industrial Accelerator Act appeared first on BACI.

]]>
From CEMBUREAU To CEMENT EUROPE A New Identity For A Strategic Industry In Transition https://bacibg.org/en/from-cembureau-to-cement-europe-a-new-identity-for-a-strategic-industry-in-transition/ Tue, 02 Dec 2025 11:02:44 +0000 https://bacibg.org/?p=1824 15 October 2025 – Today, at its annual event in Brussels, the European cement association unveils its new identity — Cement Europe — marking a new chapter for a sector … Read More

The post From CEMBUREAU To CEMENT EUROPE A New Identity For A Strategic Industry In Transition appeared first on BACI.

]]>
15 October 2025 – Today, at its annual event in Brussels, the European cement association unveils its new identity — Cement Europe — marking a new chapter for a sector that is the backbone of Europe’s construction value chain; vital for housing, infrastructure, energy systems, defence and the digital economy. A cornerstone of Europe’s economy, it is also a driver for change in its industrial and clean transition.

This strategic rebrand reflects a clear evolution: building on a solid legacy to position Cement Europe as a partner driving Europe’s competitiveness and climate neutrality.

With more than 200 plants across Europe and 120+ innovation projects already under way, Cement Europe embodies an industry that is fully local, essential to Europe’s autonomy, and a frontrunner in decarbonisation. The new identity connects this legacy with the future; bold, purposeful, and aligned with Europe’s wider clean and digital transitions.

“Cement has always been the foundation on which Europe builds,” said Jon Morrish, President of Cement Europe. “Our new identity honours that reliability, while reflecting who we are today: a sector powering change through innovation, circularity and partnership. Cement Europe stands for strength with purpose, helping Europe build its competitive, sustainable future.”

It is no coincidence that the rebrand coincides with the launch of the Cement Action Plan , a strategic blueprint outlining the policies needed to unlock investment in industrial decarbonisation while maintaining Europe’s competitiveness. The plan highlights how cement — indispensable to housing, infrastructure, renewable energy systems and digital facilities — can continue to support Europe’s growth while cutting emissions in line with the sector’s Net Zero Roadmap .

“Europe’s industrial transition must go hand in hand with competitiveness,” said Koen Coppenholle, CEO of Cement Europe. “Our members are investing, innovating, and deploying low-carbon solutions at scale, but to reach our ambitions, we need the right enabling framework. Cement Europe symbolises that partnership: between industry, policymakers and society.”

Cement Europe’s new visual identity and brand narrative — Reliable. Driver for Change. Constant Ally. — capture the sector’s evolution: from a strong industrial base to a strategic ally in Europe’s green and resilient future.

Cement solutions to strengthen and shape society — for generations to come.

Link to the Official Press Release

Link to Broshure

The post From CEMBUREAU To CEMENT EUROPE A New Identity For A Strategic Industry In Transition appeared first on BACI.

]]>
CEMENT EUROPE Launches Cement Action Plan: Powering Competitiveness, Enabling Transition https://bacibg.org/en/cement-europe-launches-cement-action-plan-powering-competitiveness-enabling-transition/ Mon, 01 Dec 2025 23:15:06 +0000 https://bacibg.org/?p=1821 15 October 2025 – At its annual event in Brussels today, Cement Europe unveiled the Cement Action Plan, a strategic blueprint designed to secure Europe’s dual ambition: competitiveness and industrial … Read More

The post CEMENT EUROPE Launches Cement Action Plan: Powering Competitiveness, Enabling Transition appeared first on BACI.

]]>
15 October 2025 – At its annual event in Brussels today, Cement Europe unveiled the Cement Action Plan, a strategic blueprint designed to secure Europe’s dual ambition: competitiveness and industrial decarbonisation.

Building on the sector’s Net Zero Roadmap, the Cement Action Plan sets out the enabling conditions required for the European cement industry to remain competitive while delivering on its climate ambitions. The Plan responds to the growing dual challenge faced by industry: ensuring a level playing field and restoring the business case for decarbonisation investments.

“The Cement Action Plan sends a clear message. Competitiveness is paramount if we are to succeed in the clean transition,” said Jon Morrish, President of Cement Europe. “Our industry is ready to deliver low-carbon, circular materials, but we need the right regulatory, funding and infrastructure conditions to make it happen.”

Europe’s cement sector is already leading the race to decarbonisation, having launched more than 120 innovation projects across the continent. Yet without a competitive business model, these efforts are at risk. The Plan identifies clear actions to strengthen competitiveness:

  • A watertight CBAM by 2026, ensuring fair treatment for imports and exports.
  • Business planning security under the EU ETS, with regulatory consistency and long-term predictability.
  • Competitive access to energy, through electricity market reforms, tariff reductions, and strengthened interconnections.

To enable the transition, it calls for:

  • Robust funding and de-risking tools, including a dedicated Cement Decarbonisation Fund financed through ETS and CBAM revenues.
  • Accelerated CO2 infrastructure deployment, with EU-wide transport and storage capacity recognised as of overriding public interest.
  • Lead markets for low-carbon products, driven by GWP disclosure, CO2 labelling, and public procurement rules.
  • Investment in skills, through reskilling and upskilling programmes across the construction value chain.

“We have the ambition, the technology and the projects. But without the right enabling framework, the transition will stall,” added Koen Coppenholle, CEO of Cement Europe. “The Cement Action Plan is a call for a strong policy partnership to deliver Europe’s industrial decarbonisation while keeping production, jobs and investment in Europe.”

The launch of the Cement Action Plan coincides with the unveiling of Cement Europe’s new brand identity, reflecting the sector’s evolution as not only a reliable partner, but a driver for change and a constant ally in building Europe’s sustainable and competitive future.

Read the Official Press-Release here

Read the Cement Action Plan here.

Check out the Cement Action Plan brochure here.

The post CEMENT EUROPE Launches Cement Action Plan: Powering Competitiveness, Enabling Transition appeared first on BACI.

]]>
The EU Commission Sets 2040 Climate Target https://bacibg.org/en/the-eu-commission-sets-2040-climate-target/ Wed, 13 Aug 2025 14:29:07 +0000 https://bacibg.org/?p=1798 Flexibility and full implementation of Clean Industrial Deal are key conditions On 2nd July, the European Commission presented the intermediate GHG emissions reduction target for 2040 for the EU society. … Read More

The post The EU Commission Sets 2040 Climate Target appeared first on BACI.

]]>
Flexibility and full implementation of Clean Industrial Deal are key conditions

On 2nd July, the European Commission presented the intermediate GHG emissions reduction target for 2040 for the EU society. The target has been fixed at 90% compared to 1990 levels on the trajectory to the EU’s climate neutrality goal by 2050. In setting out its proposal, the Commission outlines several flexibilities, including across sectors, and refers to the full implementation of the Clean Industrial Deal as paramount to achieving the climate objectives.

Through the publication of the CEMBUREAU Roadmap, the European cement industry has come forward with its own ambition to reach zero emissions by 2050. The sector’s ambition level is based on the development of projects along all levers of the cement and concrete value chain and with a wide geographical spread across Europe. Our Roadmap includes an emission reduction ambition of 78% in 2040 compared to 1990 emissions but makes this ambition conditional on the adoption of the necessary competitiveness drivers and transition enablers.

CEMBUREAU shares the Commission’s focus on the need for a swift execution of the Clean Industrial Deal with proper attention for a targeted, measured and proportionate regulatory framework that enables the business case by addressing bottlenecks.

The Commission refers to sectorial strategic dialogues with industry. CEMBUREAU is in the process of developing a “Cement Action Plan” for the implementation of its Roadmap and stands ready to engage with the Commission on the key regulatory levers mentioned in yesterday’s announcement by the Commission and to be addressed in the Action Plan:

  • With electricity prices at levels 2-3 times as high as in competing economies and electricity demand increasing significantly when deploying breakthrough technologies, there is a strong sense of urgency in alleviating levies on electricity costs. Reviewing the market design and a critical assessment of the marginal pricing system should not be considered “untouchable”.
  • Europe needs to take a leap forward in developing the energy and CO2 networks both with a view to boosting the basic competitiveness as well as for facilitating the deployment of breakthrough technologies. This implies a joined-up approach to ensure a viable business case and fair access to infrastructure for each operator in these value chains.
  • The global level playing field and competitiveness for cement operators in Europe heavily depends on the effectiveness of CBAM. Faced with a 4-5-fold import increase over the past decade and a more than 50% decrease in exports over the same period, the implementation of tight anticircumvention measures, including safeguards against resource shuffling, should be a key priority. The cement sector has always pleaded in favour of continued free allowances upon exports in order to secure competitiveness on export markets. The return of CBAM revenues under conditions to be determined, as now proposed by the Commission, fails to respond into the plea for predictability and stability for investments.
  • The decarbonization of full value chains requires robust clarity on the availability of allowances under EU ETS post 2040. In this context, CEMBUREAU welcomes the use of international credits after 2036 for the allocation of emission rights to unavoidable process CO2 from energy intensive industries. The use of domestic permanent removals in the EU ETS for the achievement of climate change targets could solve the fundamental challenge of biogenic emissions permanently stored within the EU ETS and should be an opportunity to introduce the concept of negative emissions for installations reaching a compliance level below zero.
  • Financing the transition of the cement sector requires a combination of funding sources accompanied by a simplification of the access to funding. Positive steps have been taken through the publication of the CID State Aid Framework and the establishment of the Industrial Decarbonisation Bank, but these frameworks need to be shaped up by a robust level of direct grants, covering both CAPEX and OPEX, de-risking instruments (including Contracts for Difference) and government guarantees.
  • A revision of the public procurement framework to support the development of lead markets for low carbon products is mentioned as a core policy for the industry’s transition. The uptake of low carbon products requires a regulatory framework that provides consistency between rules embedded in ETS, product legislation, carbon removals and EPDs.
  • The cement industry’s dependence on imported fossil fuels is on a continuous downward path thanks to a steady increase of the use of alternative fuels, from 2% in 1990 to 58% today. With alternative fuels sourced from waste streams, including biowaste, access to (bio)waste materials without administrative complexity, is key to the supply independency of our sector.

Notes For Editors

The cement industry and its end-product, concrete, are part of a fully local value chain, spread over about 200 cement plants across Europe that support local communities with high-quality jobs and supply the European construction market with the material that will build the housing, infrastructure, low carbon energy assets and data centers of tomorrow.

The decarbonization of the built environment is an essential pillar for Europe’s transition to carbon neutrality by 2050. With cement and concrete as indispensable and durable building solution for the construction market, valued at about 10% of the EU’s GDP, achieving Europe’s climate goals hinge on a successful decarbonisation of the cement sector.

CEMBUREAU, the European Cement Association is based in Brussels and is the representative organisation of the cement industry in Europe. Currently, its Full Members are national cement industry associations and cement companies of the European Union (except for Malta) plus Norway, Switzerland, and the UK.

Serbia is Associate Member of CEMBUREAU. Cooperation agreements have been concluded with Vassiliko Cement in Cyprus and UKRCEMENT in Ukraine.

Please click here to view the CEMBUREAU updated Net Zero Roadmap and here to access CEMBUREAU’s map of ongoing innovation projects.

The post The EU Commission Sets 2040 Climate Target appeared first on BACI.

]]>
Future EU ETS: CEMBUREAU Assessment and Strategic Proposals https://bacibg.org/en/future-eu-ets-cembureau-assessment-and-strategic-proposals/ Wed, 13 Aug 2025 14:22:21 +0000 https://bacibg.org/?p=1794 CEMBUREAU and the cement industry CEMBUREAU (www.cembureau.eu), the European Cement Association, is the representative organisation of the cement industry in Europe. Our 2050 Net Zero Roadmap published in May 2020, … Read More

The post Future EU ETS: CEMBUREAU Assessment and Strategic Proposals appeared first on BACI.

]]>
CEMBUREAU and the cement industry

CEMBUREAU (www.cembureau.eu), the European Cement Association, is the representative organisation of the cement industry in Europe. Our 2050 Net Zero Roadmap published in May 2020, and revised in 2024, aligns the cement industry’s decarbonisation pathway with the EU Green Deal and Clean Industrial Deal objectives and spans the full value chain, from production of clinker and cement to the use of concrete in the built environment.

The cement industry and its end-product, concrete, are part of a fully local value chain, which includes over 200 cement plants and 3500 concrete plants across Europe that support local communities with high-quality jobs and supply the European construction market with the essential material to build the housing, critical infrastructure, low carbon energy assets and data centers required today and for the future. The construction market is valued a 10% of the EU’s GDP. Therefore, Europe’ transition to carbon neutrality by 2050 depends on a competitive decarbonization of the cement sector.

The cement industry is a capital-intensive industry, with investment payback periods of over 25 years and investment cycles of 50 years and beyond. Cement industry and concrete as its value chain products are essential for Europe. The fundamental role of cement for the security and defense of Europe is easily overseen.

Despite its strategic role for the European continent, the cement industry has experienced a rapid erosion of its competitiveness since 2016 and is facing a surge in imports from non-European countries, with an increase of more than 450% between 2016 and 2024, while local production capacities remain largely underutilized. The future of the EU ETS and changes to the European regulatory framework have a direct impact on the competitiveness of this industry.

In 2024, CEMBUREAU updated the key indicators and ambitions of its 2050 Net Zero Roadmap, highlighting the efforts made by the industry since 1990 and its ambitions for 2040 and 2050. The Roadmap includes an intermediate ambition level of 78% CO2 reduction by 2040 (vs 1990). That ambition level is dependent on a pipeline of projects under development to deploy all decarbonization technology levers across the cementconcrete value chain. The Roadmap makes it clear that a 78% reduction is a stretch ambition, that is conditional on appropriate and supportive regulatory measures, finance, CO2 transport and storage infrastructure, and energy infrastructure requirements. On its path to decarbonisation, the cement industry will still contribute substantially to the ETS revenues. A return of 75% of these revenues for the decarbonization of the sector is a necessary complement to the sector’s own investments to secure a successful transition towards 2050.

Future of EU ETS

The EU Emissions Trading System (EU ETS) is the cornerstone of the European Union’s climate change policy and an essential tool to enable large-scale investment in industrial decarbonisation. The EU ETS does not, on its own, provide a policy environment that is sufficient to incentivize investments in Europe. The EU needs to address underlying competitiveness issues to make Europe an attractive place to invest in cement manufacturing. Alongside the EU ETS, the EU needs to introduce other policy and finance measures to create a business case for deep decarbonization in the cement sector. The Commission should note that such measures can only support the business case for the deep decarbonization if urgent measures are also taken to ensure the availability of essential CO2 transport and storage infrastructure and access to sufficient, affordable [clean] energy connected to cement manufacturing locations. Such measures need to be enabled by a fast and efficient permitting process.

CEMBUREAU has identified the following critical issues that urgently need to be addressed:

  1. The EU ETS suffers from frequent adjustments to scheme rules, some of which are not yet fully implemented (changes to the clinker benchmark, bonus malus system, cap reduction trajectory to 2040, CBAM implementation, etc.). For sectors like cement, in which decarbonization necessitates investments with long payback periods, such frequent rule changes, alongside the wider competitiveness challenges that European manufacturers face (e.g. high energy costs), significantly undermines the necessary regulatory predictability that companies need to confidently invest in Europe. One such example is the introduction of a new benchmark, which although it will have significant impacts on the sector’s CO2 costs, the sector will not be informed about the level of the benchmark until after the commencement of the period to which it applies (2026-2030). Hence, businesses and customers cannot prepare for the impact. While adaptive measures may be necessary from time to time, they must be sufficiently defined and signaled in advance, allowing industry enough time to adjust their investment plans accordingly. A minimum of 18-24 months between a change being made and its implementation is essential for manufacturers.
  2. The current EU ETS legislation results in the cap reaching zero by 2039 or 2040 and consequently an end to issuing/auctioning of new allowances. The scale, cost and logistics involved in decarbonization of the European cement sector, as highlighted in the CEMBUREAU Net Zero Roadmap, mean that some cement installations, for reasons outside of their control (e.g. availability of CO2 transport and storage infrastructure), will be emitting CO2 beyond 2039 / 2040
  3. The benchmark must be representative of industry practices and performance in order to be truly effective as an incentive: “Alternative hydraulic binders” (such as calcium aluminate cement and other materials) are different products to clinker (chemistry, production methods, norms & standards) and it is entirely inappropriate for them to be included in the grey clinker benchmark. They must be treated separately. The grey cement clinker benchmark must be calculated using the methodology that has been in place before the 2024 amendments which has been used as the basis for investment decisions.
  4. As the EU ETS benchmarks are used in many other legislative processes at EU and national (and even international) level, it is important that these benchmarks express the average of the10% best performing installations within reasonable and equally available boundaries. First-of-a-kind deep decarbonization technologies, such as CCUS projects co-financed by the EU Innovation Fund, will result in emission profiles that do not reflect the 10% best performance across the sector in the sense that this is not readily available technology. The data consequently be statistical outliers and its use would result in severely distorted picture. For that reason, emissions reductions achieved by such first-of-a-kind projects should not be considered as comparage and equally avaiable. Emissions reductions from carbon capture projects must be excluded from the EU ETS benchmark, until a significant proportion of the sector is able to install it.
  5. Key regulatory facilitators must include a seamless fungibility between permanent carbon removals (covered by the EU CRCF) and EU ETS allowances.
  6. The current regulatory framework should be simplified by adopting a single regulatory act that incorporates the provisions of the EU ETS, CBAM, CRCF, the Decarbonisation Accelerator Act and thereby avoid inconsistencies:
    1. Key mirroring provisions between EU ETS and CBAM are needed, which must include provisions on exemptions from CBAM only for ETS-linked systems, countries with similar / equal ETS systems based on equivalence in carbon accounting, requirements related to biomass regulations (RED), CO2 storage directives, etc. , solutions for export of materials from the EU to countries without similar obligations and CO2 costs, and a common system provision to address indirect emissions from electrical energy consumption.
    2. Maintain and reinforce the Innovation Fund as earmarked for the purposes currently mentioned in Article 10(a)(8) ETS, boost of funding, broadening of scope from innovation to deployment projects for technologies such as CCUS or renewables, and complement with national state aid financing (through the Sovereignty Seal procedure), contracts for difference (for de-risking purposes). Clarify accounting rules for CO2 use: there is no business case for capturing CO2 when captured emissions remain subject to a surrendering obligation even when transferred to a third party. The ETS needs to recognize that, in case of transfer, there is no emission into the atmosphere and therefore no surrendering obligation at the point of capture. CEMBUREAU requests to reintroduce the release into the atmosphere as a constituent element in the definition of what is an emission.
    3. A similar clarification is required to allow for the recognition of negative emissions from Carbon Removals certificates. A cement plant equipped with carbon capture technology followed by geological storage could capture CO2 from fossil energy sources, CO2 from cement process emissions (of mineral / geogenic origin), and neutral CO2 from biogenic content of fuels such as biomass content (or mixed) waste materials. A business case for the investment can only be made if negative emissions can be accounted for.
    4. The cement industry’s dependence on fossil fuels has been reduced gradually through the use of alternative fuels from waste from municipal and industrial sources, including waste with biogenic content. In addition to securing independence of supply, the use of alternative fuels also reduces the industry’s carbon footprint. The waste is not used for the production of biomass nor is it obtained from agricultural or forestry sources. This said, the use of alternative waste sources in the cement industry has been subject to compliance with the sustainability requiements under the RED legislation. In CEMBUREAU’s view, such approach is not warranted in light of the objective pursued by the RED legislation and triggers unnecessary reporting complexity. Therefore, CEMBUREAU suggests a revision of the GHG savings rules under the EU ETS Monitoring and Compliance Regulation in combination with an exemption from the sustainability criteria requirements under RED III.
    5. Waste incinerators should be included in the EU ETS, along with other final waste treatment operators.

Conclusion

In conclusion, CEMBUREAU is keen to continue engaging on how to decarbonize the industry but pleads for a strong sense of realism in bringing competitiveness and decarbonization efforts under a single growth strategy as was presented in the Clean Industrial deal.

The post Future EU ETS: CEMBUREAU Assessment and Strategic Proposals appeared first on BACI.

]]>
EC consultations on the revision of the State aid guidelines for indirect costs: position of BACI https://bacibg.org/en/ec-consultations-on-the-revision-of-the-state-aid-guidelines-for-indirect-costs-position-of-baci/ Thu, 27 Mar 2025 13:23:32 +0000 https://bacibg.org/?p=1780 European policies and practices for their implementation provide for energy-intensive industries in the Member States to receive state aid to compensate for indirect carbon costs. This financial scheme has been … Read More

The post EC consultations on the revision of the State aid guidelines for indirect costs: position of BACI appeared first on BACI.

]]>
European policies and practices for their implementation provide for energy-intensive industries in the Member States to receive state aid to compensate for indirect carbon costs. This financial scheme has been applied since 2012 in countries that have production from sectors eligible under the EC list. Despite the significant risk of “carbon leakage” and the high carbon intensity of our products, the cement sector was excluded from the list of eligible sectors for state aid under the current State Aid Guidelines for indirect costs due to the level of trade intensity, which was below the threshold set by the Commission. The trade intensity index is determined on the basis of average European statistical data and while the average level for the European Union is below the threshold set, this is not the case for border countries. The high transport costs of cement limit its distribution within the EU mainly to the country through which the import is made. According to NSI data, the trade intensity of cement in Bulgaria is significantly above the average European level and cement imports reach nearly 20% of the domestic cement market.

We have been informed of a questionnaire sent by the European Commission to national authorities on a possible revision of the indirect state aid guidelines with a deadline of 5 February for Member States to respond to the Commission and we would like to summarise again the position of the cement industry on the subject:

  • The cement sector has an indirect emissions intensity (1330 kg.CO2/€ GVA), which is higher than 1 kg.CO2/€ GVAand thus ranks 8th in the overall list of 246 industrial sectors assessed by the European Commission in its 2020 impact assessment. This means that the cement industry bears an exceptionally high-cost burden caused by indirect emissions.
  • It is not plausible that a sector that is among the top 10 sectors in terms of indirect emissions intensity and is clearly exposed to a significant risk of carbon leakage should not be explicitly included in the list of targeted sectors.
  • Emissions intensity is a key indicator that allows assessing the risks of carbon leakage, as it provides a “business case” for imports to replace European production, due to the lack of carbon restrictions abroad. CEMBUREAU’s analysis of carbon costs, based on publicly available data, for example, showed that at an ETS price of €55, carbon costs already represent 8-10% of total cement production costs, even when the sector receives free allocation at the current level. At an ETS price of €90, this rises to 12-15% of production costs – even with free allocation.
  • EU cement imports have quadrupled in recent years, jumping from 2 million tonnes per year in 2016 to just under 10 million tonnes today, while EU exports have more than halved over the same period. 
  • The intensity of trade at EU level does not sufficiently reflect the significant differences in national situations. This is particularly true for cement, a heavy product by nature, with countries close to the EU’s external land borders or with large port facilities being particularly at risk. For example, a moderate intensity of trade at EU level (below 10% in the case of cement) translates into very different situations at national level: in fact, some countries have high trade intensities in both exports and imports, reaching figures of 40% for some.
  • In assessing the risk of carbon leakage under CBAM, a report commissioned by DG CLIMA from Ricardo consultants distinguishes the intensity of cement trade (which is 8%) from the intensity of clinker trade, which is 46%.
  • The cement sector was declared eligible for state aid under the European Commission’s Temporary Framework for State Aid in Crisis and Transition, which bases the eligibility of the carbon leakage list under the EU ETS, as well as under section 4.11 of the State Aid Guidelines for Environmental and Energy Protection – a combination of trade intensity and electro-intensity, which qualified the cement sector as being at “significant risk” of carbon leakage. 
  • The use of qualitative criteria in addition to purely quantitative ones should be assessed. For example, when assessing the risk of carbon leakage in imports or exports in relation to a specific third country, it may be useful to consider developments in taxation of production in exporting countries (e.g. carbon offsets). Similarly, overcapacity in non-EU countries also plays an important role.

Compensation of indirect costs is of paramount importance for the cement sector in Bulgaria and we kindly ask you to take the necessary steps so that the cement sector can be included in the list of sectors that can receive compensation due to high electricity prices.

The cement industry in Bulgaria also expects initiatives from our government based on the country’s CO2 roadmap strategy (which needs to be developed) to co-finance all existing and future CCUS projects in Bulgaria, to bring our Bulgarian legislation in line with best practice countries, and to publicly announce and establish a Strategic Decarbonization Fund.

The post EC consultations on the revision of the State aid guidelines for indirect costs: position of BACI appeared first on BACI.

]]>