Alliance for Low-Carbon Cement and Concrete
ALCCC
The ALCCC was created to steer the sector towards viable decarbonisation pathways.
ID: 723842295447-39
Lobbying Activity
Response to Evaluation on the operation of the Innovation Fund - 2025
8 Jul 2025
We welcome the opportunity provided by the European Commission to give feedback on the evaluation of the innovation fund. In doing so, we would like to highlight the following points: 1) Level-up investments to the full spectrum of clean cement and concrete technologies. To date the innovation fund (IF) has almost exclusively supported the deployment of CCS technologies in cement . While important, we believe there is at present no balance in EU funding between support for CCS deployment and support for clinker substitution solutions. To date, 14 out of 15 Innovation Fund projects in cement have been awarded to cement. These represent a portfolio of 2,3 billion, standing in sharp contrast to only 1 small-scale SCM project of 4,5 million. This is a ratio of about 1 to 500 which is not at all aligned with the significant potential for clinker substitution in Europe, to be achieved through a combination of proven, mature and scalable technologies (i.e. SCMs, alternative and novel cement types, clinker recycling) . This also reflects from the EU Horizon DETOCS project according to which Europe has the potential to drastically reduce its need for cement clinker, going down from a clinker-to-cement ratio well above 70% at present to 40% by 2030 and 35% by 2035. This showcases once again the strong need to level-up investments in clean cement and concrete technologies that can (drastically) reduce the overall need for expensive and energy-intensive end-of-pipe solutions. 2) Need for better supporting cost-effective decarbonisation technologies. At present, the IF project award criteria have a bias towards supporting technologies with a green premium, partly explaining the strong focus on CCS deployment given that these substantially increase the cost of cement . In sharp contrast, however, clinker substitution technologies have in common that they are cost-neutral or even cost-effective. Therefore, it is crucial for the IF to revise its award criteria to better support the deployment of innovative cost-effective decarbonisation technologies. For cement and concrete, this is especially relevant to safeguard the affordability of housing across Europe. 3) Fair access to all technologies and market actors. The IF (and the forthcoming Industrial Decarbonisation Bank) needs to ensure at all times that access to funding is not restricted to ETS installations only, amongst others because of the shortcomings of the ETS (i.e. benchmark only covers clinker production). A level-playing field for all market actors is essential to ensure that the full spectrum of clean tech cement and concrete solutions have access to funding. Please find attached our full contribution, including with relevant background materials and references.
Read full response8 Jul 2025
We welcome the opportunity provided by the European Commission to give feedback on the EU ETS call for evidence. To further improve its effectiveness and impact, we would like to highlight the following points: 1) We strongly believe in the added value of the EU ETS and MSR. The regulatory framework is essential for Europe to deliver on its climate objectives, as well as foster and promote to transition to a clean and competitive industry. A strong and stable carbon price serve as a key driver for investments in the many proven, scalable and cost-effective solutions that can drastically accelerate cement and concrete decarbonisation in the years ahead. 2) To date, the EU ETS has underdelivered on sectors like cement. This can directly be attributed to the high levels of free allocation in the market, often even surpassing actual emissions. Furthermore, for cement, free allocation is based on a clinker-based benchmark, as such disincentivising clinker substitution. This is hugely problematic as the latter is the most impactful and cost-effective decarbonisation lever for our sector. Furthermore, it creates a lack of level-playing-field towards the wide range of technologies that reduce the need for traditional Portland clinker. 3) We consider the MSR fit for purpose. So far, the MSR has guaranteed a stable and strong carbon price. This is crucial for the functioning of the EU ETS and should be preserved at all costs. 4) Level-up investments to the full spectrum of clean cement and concrete technologies. To date the innovation fund (IF) has exclusively supported the deployment of CCS technologies in cement. While important, we believe a more diversified approach is urgently needed in response to the wide range of other cost-effective cleantech solutions on the market. Moving forward, it is key for the IF and the forthcoming industrial decarbonisation bank (IDB) to level-up investments to the full spectrum of clean cement and concrete technologies. Under no circumstance, access to the IF and IDB should be restricted to incumbent ETS installations only.
Read full responseResponse to Industrial Decarbonisation Accelerator Act
4 Jul 2025
We welcome the opportunity provided by the European Commission to give feedback on the forthcoming Industrial Decarbonisation Accelerator Act (IDAA). In our view, the IDAA offers a welcome and timely opportunity to steer the cement and concrete industry towards proven, scalable and cost-effective low-carbon solutions in the following way: Unlock the potential of green public procurement (GPP) in creating demand for low-carbon products. Public projects are responsible for around 40% of cement and concrete procurement. A mandatory and unified approach to GPP for construction products would ensure that cement and concrete meet ambitious environmental requirements. Carbon footprint calculation and labelling on the basis of sectorial legislation. The new Construction Products Regulation (CPR) mandates the disclosure of environmental performance, based on Environmental Products Declarations (EPDs) that follow internationally recognised LCA methodologies. No other methodologies should be used, including sliding scale methodologies, as they are redundant and will introduce additional complexity to the value chain. Ensure a level-playing field for all low-carbon technologies. Priority should be given to policy interventions at the level of concrete, stemming from the fact that this is the product purchased on the (public) market ; as well as the complex interplay between different cement technologies, aggregates, additives and reinforcements which all influence the footprint of the product. From this perspective, the use of cement labels should be assessed with the necessary caution. Prioritisation of removal of composition restriction in product standards. For the IDAA and CPR to deliver on lead markets for cement and concrete, it is imperative that product standards (cement and concrete) move from a composition-based to a performance-based approach. The composition-based framework was introduced long time ago for cement quality purpose in a context of limited technical and scientific knowledge. Today, knowledge on cement and concrete has progressed, the composition-based logic is outdated and became a market-entrance barrier. It is therefore timely to now move towards a full performance-based approach. A devoted cement and concrete action plan under the IDAA, including on these points, is key to send a strong signal to the market, derisking investments for scaling-up innovations. Level-up investments to the full spectrum of clean cement and concrete technologies. Hereby priority should be given to those technologies with the potential to achieve significant emission reductions well ahead of 2030. Key in this regard is the need for funding mechanism for demonstration and upscaling projects, stemming from shortcomings in the EU innovation fund. Finally, under no circumstances, funding to cement and concrete decarbonisation should be restricted to ETS installations only, given the sever shortcomings to the ETS benchmarks, not covering a wide range of cleantech cement and concrete solutions. Our full assessment and position can be found in attach.
Read full responseMeeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Environmental Coalition on Standards
16 Apr 2025 · Lead markets for cement and concrete products in CID and IDAA
Meeting with Aleksandra Baranska (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)
5 Mar 2025 · Exchange of views on the current challenges of the European industry producing clean cement and how policy initiatives such as the Clean Industrial Deal could help address them.
Response to Single Market Strategy 2025
31 Jan 2025
The Alliance for Low-Carbon Cement and Concrete (ALCCC) welcomes the European Commission's upcoming Communication on a Single Market Strategy and opportunity provided to give feedback. Please find attached the ALCCC's feedback to the public consultation.
Read full response