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Bundesverband der Deutschen Ziegelindustrie e.V.

ZIEGEL

Der Bundesverband hat als Zusammenschluss von Fach-/ Landesverbänden sowie von Unternehmen der Ziegel- und der Baukeramikindustrie im Gebiet der Bundesrepublik Deutschland die Aufgabe, die gemeinsamen Interessen der Gesamtheit seiner Mitglieder auf nationaler und internationaler Ebene zu wahren und zu fördern.

Lobbying Activity

Meeting with Jens Geier (Member of the European Parliament)

3 Dec 2025 · Exchange on the Industrial Accelerator Act

Meeting with Jens Gieseke (Member of the European Parliament)

3 Dec 2025 · Austausch zu EU-Politik

Meeting with Stefan Köhler (Member of the European Parliament)

2 Dec 2025 · Politischer Austausch über aktuelle Herausforderungen der Baubranche

Meeting with Oliver Schenk (Member of the European Parliament)

2 Dec 2025 · SME Policy Priorities

Meeting with Dennis Radtke (Member of the European Parliament)

25 Mar 2025 · Wirtschaftslage

Meeting with Christine Schneider (Member of the European Parliament)

4 Dec 2024 · Environment topics

Meeting with Ismail Ertug (Member of the European Parliament)

29 Nov 2022 · Energieintensive Produktion von Ziegeln

Meeting with Christian Doleschal (Member of the European Parliament, Rapporteur)

22 Nov 2022 · Revision of the construction products regulation

Response to Carbon Border Adjustment Mechanism

1 Apr 2020

In the context of the Covid-19 breakout where European democracies are experiencing situations and measures that had not been seen since World War II, any forthcoming EU policy will need to be adapted to the new societal and economic challenges which will arise in the aftermath of this crisis. Independently from the future impact of this crisis which cannot yet be anticipated, the impact assessment by the Commission of the proposed Carbon Border Adjustments (CBAs) mechanism should primarily try to understand if, when and how can CBAs strengthen existing carbon leakage measures. The impact assessment should also assess how the mechanism can preserve the competitiveness of EU products on export markets. The impact assessment should also address the fact that for sectors with similar characteristics as in the ceramic industry, CBAs do not appear to be neither feasible nor efficient in strengthening carbon leakage measures. Consequently, it will be even more important for these sectors to maintain the existing system of free allocations for best performers, potentially combined with other complementary policy instruments. In particular: Carbon Border Adjustments should be designed to strengthen carbon leakage protection in the long term Depending on the outcome of the ongoing decision making process on ETS benchmark updates and on the fluctuations of the carbon price (from 30€ to 50 €/tCO2), the European ceramic industry anticipates an ETS cost under Phase IV ranging from € 1 Billion to € 3 Billion, assuming that carbon leakage measures and the 2030 targets for the ETS sector remain unchanged. In the absence of any carbon leakage measure, the cost for the sector would range from € 3.8 Billion to € 6.3 Billion. Over the last years the European ceramic industry has done great investments to maintain its competitiveness in a globalised economy and reduce the carbon content of its products. Any decrease of the carbon leakage protection foreseen until 2030 would significantly jeopardise the ability of the sector to further invest in new and breakthrough technologies or to develop key technologies further to bring them to the market (marketability). Policies merely increasing carbon costs on EU manufacturing without duly considering the carbon leakage risk will reduce EU carbon emissions from manufacturing as a result of relocation but will increase the EU’s consumed carbon due to imports from countries with lower or non-existing carbon costs on manufacturing. That is why the main objective of CBAs should be to strengthen existing carbon leakage measures.
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Response to Amendment of the EU ETS Monitoring and Reporting Regulation (MRR)

26 Nov 2018

Comment on Amendment of the EU ETS Monitoring and Reporting Regulation (MRR) Subsection 5 “Definition of tiers for calculation for CO2 process emissions from other materials than carbonates” was included in Annex II of the MRR. Brick and tile making installations are often category A installations. In clay block production, residues form paper production is used as pore forming agents. They are introduced in the clay in order to create micro pores in the clay block to increase thermal insulation. The paper residues are not used as fuels. They contain three types of carbon: carbonates, fossil carbon (printing ink) and biogenic carbon (from the paper). In Phase III the fossil carbon content of the residues is determined using the Total Carbon content (TC) minus the biogenic Carbon (determined with the C 14 method). Normally, four analyses are carried out per annum. The new subsection 5 does not reflect that all materials considered in this section are not used as fuels. Because the materials are not used as fuels, the net calorific value and the corresponding emission factor are not determined and are useless for the installation. In Phase III, the carbon content is used to determine the CO2 emissions and if necessary, the biogenic carbon. Please change the whole section accordingly to reflect current practise and reflect industries data needs. Please refer to the TC and if necessary, the C14 method. There is no Standard value for this material.
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Response to Revising the rules for free allocation in the EU Emissions Trading System

16 Apr 2018

The German Brick and Tile Association welcomes the European Commission’s publication of the Roadmap on Revising the rules for free allocation in the ETS (Ref.: Ares (2018)1523713) and wishes to express its interest in being involved as a key stakeholder during the entire process. The German Brick and Tile Associtation is member of Cerame Unie. Cerame-Unie, the European Ceramic Industry Association, is an umbrella organisation representing the European ceramic industry structured in ten ceramic sectors and present in 30 European countries, including 26 EU Member States. The ceramic industry encompasses about 2,000 companies in the EU, comprising a large proportion of SMEs (80%) as well as international groups. In total the sector represents ca. 200,000 direct jobs across Europe and an annual production value of around € 28 billion. The German Brick and Tile industry is directly impacted by the EU ETS scheme. In the EU ETS phase 3 there are over 1200 ceramic installations in scope of the EU ETS Directive. These are mainly manufacturers of: bricks, clay roof tiles and clay drainage pipes, wall and floor tiles, refractories, sanitaryware and expanded clay. In total, the ceramic sectors represent around 10% of all installations in the EU ETS, but less than 1% of the total industrial emissions. In common with other industrial participants, the impact of the EU ETS system on ceramic manufacturers is significant. The costs of EU climate regulation, which represent some of the main EU regulatory cost drivers, as identified in the EC Cumulative Cost Assessment on the EU ceramic industry, have been steadily increasing for a number of years and now constitute a significant net cost burden. Particular attention must be given to the growing impacts associated with indirect carbon costs, which are currently uncompensated for ceramic installations. It is crucial to have an uncomplicated procedural process of allowances allocation under the phase 4 of EU ETS. It is essential to avoid creating additional administrative burden for the industrial operators when defining the implementation details for establishing the allocation rules and rules for adjusting free allocation to production changes. Moreover, where possible, simplification shall be granted (or maintained) for the small emitters below 25.000 t CO2 per year (for example in monitoring and reporting and surrender obligations). The rules on free allocation adjustments due to production changes must reflect the different industrial installations characteristics, in particular for the application principles and use of the 15% threshold defined in the reviewed ETS Directive. Other elements that have to be well addressed in the implementation of rules for free allocation in the EU ETS include: • The rules on free allocation have to include the methodology to update fall-back benchmarks (heat, fuel and process emissions benchmarks). This methodology must consider two important aspects: on one hand the process emissions are unavoidable and on the other, natural gas must remain the reference fuel for fuel benchmark sub-installations. • An improvement on energy efficiency should not be, in any case, a reduction of free allocation to fuel benchmark sub-installations. • A cease in operation for 6 months must not be considered a cessation of operations of an installation; six months of cease operations is common when industrial activity falls down. To consider a cessation of operations of an installation a period of, at least, 2 years of cease operations must occur. Cerame-Unie welcomes the European Commission’s intention to consult stakeholders to ensure better rules on free allocation and for adjustments to free allocation due to production level changes. Cerame-Unie and its member associations such as the German Brick and Tile Association would like to express our interest in participating in future consultation activities on this matter.
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