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Asociación Nacional de Empresarios Fabricantes de Áridos

ANEFA

ANEFA, created in 1977, represents companies from the aggregates sector in Spain.

Lobbying Activity

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

31 Oct 2023

Por la presente, incluimos los comentarios de la Asociación Nacional de Empresarios Fabricantes de Áridos-ANEFA, a la Propuesta de Directiva del Parlamento Europeo y del Consejo relativa a la vigilancia y la resiliencia del suelo.
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Response to Net Zero Industry Act

20 Jun 2023

The National Association of Aggregates Manufacturers-ANEFA welcomes the initiative of the European Commission to support the technologies which will be necessary for the decarbonisation. This is an important first step, which should be followed up with a broader prioritisation of competitiveness in European policymaking, to stimulate the investments required to transition the entire economy towards net zero. Together with the Critical Raw Materials Act (CRMA), this proposal constitutes a first step towards recognizing the need for a European industrial policy that helps secure access to the raw materials needed to underpin the twin transition and increase the Unions strategic autonomy. The Acts objective to create a business case for net-zero technologies in Europe and to boost their expansion in all sectors is welcomed. Simpler and faster permit-granting processes are a basis to attract more investments in Europe in key technologies for a successful decarbonisation. Europe is often too slow and too bureaucratic on all levels of planning, expanding, building, and implementing projects. Every production conversion and every infrastructure renewal require permits. These procedures must run faster, including the environmental impact assessments, and not be undermined by other EU legislations. Coherence of the overall framework should be guaranteed. Also, the proposal of applying regulatory sandboxes has the potential to speed-up the testing in real-world environment of less mature net-zero technologies. The EU should reduce regulatory barriers by making procedures more transparent, unbureaucratic and less time-consuming. It is also important to avoid financial pressure and new taxes in the current crisis, while providing a level playing field in the access to the funding. However, the limited scope of the Act risks to become a handicap for Europes net-zero transformation. Policymakers must acknowledge that the successful decarbonisation of Europe cannot be achieved without a recognition of interdependencies between value chains and the need to decarbonise the entire industry. In our view, the proposal focuses primarily on "net-zero technologies manufacturing". It fails to recognize that extractive industry sectors provide essential primary products and raw materials for the manufacturing of the addressed strategic climate-neutral technologies. Not only the scope of strategic and net-zero technologies must be sufficiently broad and remain flexible to reflect technological developments, but entire value chains of raw materials, processed materials, equipment, parts, components and intermediate products must be fully in scope as well. Additionally, it is important to consider the existing upstream chains for primary raw materials. It is essential that this Act is developed in a coordinated manner with the Critical Raw Materials, since the contribution of raw materials to the development of net zero technologies is essential, establishing a coherent regulatory framework that provides legal certainty and ensures the achievement of the climate objectives and strategic autonomy pursued by both regulations. The NZIA and the CRMA need to work in parallel by means of a full value chain approach. Production of raw materials needs to be increased in Europe. If not well calibrated, the NZIA will only benefit imports and not local production of strategic raw materials. ANEFA calls for complementarity between the CRMA and NZIA to secure a sustainable supply of Raw materials to Net Zero Technologies in Annex I of the Regulation by preserving production of raw materials in Europe across the full value chain. The attached document, submitted by the Confederation of Mineral Raw Materials Industries - PRIMIGEA, the content of which ANEFA fully supports, includes a number of amendments and comments to the proposed text.
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Response to European Critical Raw Materials Act

29 May 2023

The National Association of Aggregate Manufacturers-ANEFA, in defense of the legitimate collective interests of its members, welcomes the European Commission's initiative to address the overriding issue of securing the supply of Raw Materials necessary for a green and digital transition. We welcome the proposed Critical Raw Materials Regulation as excellent news, as it is a breakthrough, breaking an insurmountable legislative barrier for MPs and is in line with the fundamental principles of access to resources. Furthermore, we support the European Commission's intention to focus on critical and strategic raw materials. Europe's dependence on an increasingly entrenched and disruptive international supply chain of imports for most critical raw materials, combined with the exponential increase in demand for these raw materials for the double transition, are threatening the performance and integrity of industry in the European Union. Europe needs to do more at home, while diversifying its import flows. However, the European Commission's decision to devote the proposed Regulation only to critical and strategic raw materials ignores the essential role and need for all other MPs, which represent 99% of those needed for the above-mentioned objectives. The precarious position in which Europe currently finds itself is the result of an incomplete and not very holistic design of its industrial policy and a lack of attention to the need for PM. Filling the gaps in Europe's strategic supply chains requires a comprehensive PM policy. Therefore ANEFA strongly recommends adding "essential raw materials", as a complementary set of remaining Raw Materials, to the proposed existing categories (i.e. "strategic and critical raw materials"), without competing with these in the framework of benefits. Furthermore, additional measures should be included to help the supply of essential raw materials to be planned and rationalised in a similar way as for critical and strategic raw materials, through a framework including administrative streamlining measures, such as a one-stop shop or limiting the length of processing procedures to a maximum of 18 or 36 months, and other benefits adapted to their specific circumstances. ANEFA wishes to show its unconditional support for the document "PRIMIGEA COMMENTS ON PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ESTABLISHING A FRAMEWORK FOR ENSURING A SECURE AND SUSTAINABLE SUPPLY OF CRITICAL RAW MATERIALS AND AMENDING REGULATIONS", the content of which is attached hereto and which it subscribes to in its entirety.
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Response to Initiative on EU taxonomy - environmental objective

3 May 2023

The Asociación Nacional de Empresarios Fabricantes de Áridos-ANEFA is a national business association that represents the interests of companies dedicated to the extraction of aggregates in Spain. ANEFA was created with the objective, among others, of defending the necessary legal certainty for companies in the sector; Boost the competitiveness of the aggregate production industry; Promote strategic planning of the aggregates sector; Promote the consideration of environmental aspects in the production processes of aggregates; Promote the quality and proper use of aggregates, promoting the improvement of applicable technical regulations and sustainable construction. Since its constitution, ANEFA has introduced advanced professional criteria in all the processes of the aggregate production activity, opening new paths in essential matters that constitute the basis of sustainable development for companies and for the sector. Our sector across Europe has embraced the EUs Action Plan on Circular Economy, while we have a track record when it comes to extracting, producing, and using natural resources in the most efficient and environmentally sustainable way. As such, access to affordable finance will determine our ability to continue to invest in circular projects and in nature conservation and restoration activities. The sector fully shares the objectives of European circular economy policies, based on the optimised use of resources, granting them the best quality, thus increasing the durability of infrastructures, and of course, reintroducing into the chain those wastes that, due to their intrinsic characteristics, comply with the technical and environmental requirements of those uses for which they are intended, as a substitute for natural resources. However, these actions, as it cannot be otherwise, must be supported by knowledge, technique, and regulations, otherwise the efforts used by all agents to implement Circular Economy policies in the construction sector could be seriously challenged. The European ecosystem of construction, and the supplier of primary and secondary construction raw materials, are already contributing to the twin green and digital transition, not least by the development of the EU Renovation Wave, the building of critical infrastructure on sustainable mobility/energy, enhancing biodiversity and restoring nature, and the prevention of natural disasters. In line with the European Commissions draft Delegated Acts, and supporting Annexes on technical screening criteria for construction activities, we welcome the decision to readjust targets of minimum recycled content in concrete and other construction products from previously unfeasible rates, such as 60% proposed by the Technical Working Group of the Platform on Sustainable Finance, to significantly more realistic ones, e.g., 30% of secondary raw materials back into concrete in civil engineering. However, the proposed draft Delegated Act, as per Annex II, sets targets of minimum recycled content for a variety of concrete products or products using large amounts of construction raw materials. To ensure the transition to a circular economy, a series of observations and considerations will be made to this normative proposal, to highlight the problem of the practical application of these provisions.
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