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.

2. 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”.

3. 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.

4. 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.