ASOCIACION NACIONAL DE FABRICANTES DE CALES Y DERIVADOS DE ESPAÑA
ANCADE
"ANCADE" se constituye con la finalidad de representar y gestionar los intereses de la industria española de la CAL y en general, desarrollar toda clase de actividades, para el fomento y la defensa de los intereses comunes de los asociados.
ID: 022504216411-22
Lobbying Activity
Response to Permanent storage of EU ETS emissions through carbon capture and utilisation
15 Jul 2024
1) ANCADE advocates for the principle that emissions pricing should be applied at the point where emissions are released into the atmosphere. 2) ANCADE emphasizes the necessity for operators to have the ability to demonstrate that captured CO2 will remain permanently sequestered in products throughout the entire value chain, including at the end-of-life stage. 3) Precipitated Calcium Carbonate (PCC), like any form of calcium carbonate, should be subject to an equitable treatment. Incinerators processing calcium carbonates must report their "process emissions" in the same manner as any cement or lime producer and be held accountable for these emissions. ANCADE therefore calls for an initial list of applications considered as "permanent storage" and the development of methodologies allowing operators to apply for recognition of specific or innovative equivalent permanent sequestration in a product. By extending the initial list and defining these methodologies, the regulation can better reflect the true potential of various products to sequester carbon. Moreover, ANCADE suggests the following addition to the Annex: a) carbonated aggregates used unbound or bound in mineral based construction products; b) carbonated cement constituents used in concrete or other cement-based products; c) carbonated concrete, including blocks, pavers or aerated concrete; d) carbonated bricks or tiles e) Carbonates in doors, windows shutters, gates and related building hardware. f) Carbonates in paints, adhesives and sealants. g) PCC for paper (as a percentage of the national recycling rate)
Read full responseResponse to European Critical Raw Materials Act
24 May 2023
ANCADE 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 ANCADE 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. ANCADE 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.
Read full responseResponse to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals
27 May 2021
The current procedures for registration & authorisation are a heavy burden for EU competitiveness. The current procedures for evaluation of registration dossiers and substances are complex, costly and take too long. The authorisation procedure is too heavy and inflexible. The authorisation process has imposed a heavy burden on both companies and authorities. This has placed EU-based companies at a competitive disadvantage compared to their non-EU competitors.
Administrative simplification and less bureaucratic burdens are a must. The current procedures are far from “smart regulation” and extremely costly for EU companies.
Read full responseResponse to Agriculture - List of products and substances authorised in organic production
23 Apr 2021
ANCADE thanks the European Commission for the opportunity to contribute to this consultation process and comment the draft proposal of Implementing regulation lays down a list of products and substances including fertilisers, pesticides and cleaning and disinfecting products authorised for use in organic production.
We request to EXPAND the use of Calcium Hydroxide in organic products, with the additional inclusion of calcium hydroxide in ANNEX III, AUTHORISED PRODUCTS AND SUBSTANCES FOR USE AS FEED OR IN FEED PRODUCTION. (page 16 of the document) PART B AUTHORIZED FEED ADDITIVES AND PROCESSING AIDS USED IN ANIMAL NUTRITION REFERRED TO IN POINT (D) OF ARTICLE 24 (1) OF REGULATION (EU) 2018/848 The incorporation of Calcium Hydroxide as a needed in Annex VI of Rº 889/2008, was requested to the commission on March 23, 2021.
The reasons for incorporation into annex VI of Rº 889/2008 are the following:
*Calcium Hydroxide is already authorized in the EU as an aid in organic food for humans (Rº 889/2008 annex VIII B) and is widely used in the organic and conventional food industry. It has been used for years for the production of conventional calcium salts for animal feed.
*Calcium hydroxide can be used as an adjuvant in organic products.
*Calcium Hydroxide has an obligatory and irreplaceable use as an aid in the formation of calcium salts of fatty acids from different oils (Raw material with number 13.6.4 in Commission Regulation 68/2013).
*The inclusion of Calcium Hydroxide would allow the manufacture of ecological calcium salts
*Calcium Hydroxide is authorized as an adjuvant in the USA (USA Code of Federal Regulations Title 21 Chapter I FDA) for its use in human and animal production and can be imported.
Read full responseResponse to Amendment of the EU ETS Monitoring and Reporting Regulation (MRR)
26 Nov 2018
The issue is as follows: the regulation 601/2012, stablishes in its Annex VII that test frequencies for coke should be "every 20,000 t AND at least 6 times a year".
If a company yearly consumption does not reach 20,000 t, should they still make 6 tests? No matter the amount? Some Competent Authorities are asking them to do 6 analysis a year even if they only receive 3-4 boats a year that doesn’t add up 20.000t; It does not make sense not to have a minimum amount but the verifiers keep telling them to hire an accredited laboratory to reach the 6 bulletins / year, to meet this frequency, no matter the amount.
What should be consistent would be to ask for a number of test from a determined amount of coke, let’s say every 20.000tons, no less: This might be what the regulation wants to say but with the current wording it depends on the verification criteria, and that shouldn’t be. It’s needs clarification.
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