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CARMEUSE EUROPE SA

CARMEUSE EUROPE

Carmeuse is a worldwide leading producer of high calcium and dolomitic lime, limestone and derived products, providing solutions for many different industries

Lobbying Activity

Response to Commission Decision determining the benchmarks values for free allocation in the period 2021-2025

4 Jan 2021

Carmeuse Europe is active in the lime sector. Determining the benchmark on biomass is artificial to a certain extend due to lack of availability and future conflict on biomass preservation. The main long-term source of biomass will be biomass waste and the capacity will never exist to cover all industries’ needs. The artificial extension of the improvement factor is inappropriate in a sector with very high proportion of process & irreducible emissions. As a dramatic consequence, the level of free allowances determined by this methodology will not be sufficient even for the 10% best sub-installation. The provision of art 16 2e of the Free Allowances regulation to the process emission’s share could be a fair way to address this very particular case. The proposal of the Commission is disproportionate as in the case of lime, the benchmark value will not be sufficient to cover the emissions of the best in class while in other sectors the proposed benchmarks values are much higher than the actual 10% best emitters. We would also like to point out that the reference installations burning biomass are not the most energy efficient ones which conflicts with the EU's policy regarding maximisation of energy efficiency.
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Response to Revising the rules for free allocation in the EU Emissions Trading System

9 Jul 2019

Carmeuse would like address following points for consideration to determine the best way to dispose of a cost competitive mechanism to reach GHG reductions at EU level: - A full linear approach is the only way to ensure that there is not over or under allocation of free allowances. - Annual reports on the activity level of each sub-installation in the preceding calendar year starting in 2021, for both new entrants and incumbents. - In line with setting a correct alignment of the emissions-activity level report, the time-lag between measuring activity levels and receiving an updated allocation following an activity level change should be as short as possible. - Equivalent treatment between investments at incumbent sites (resulting on a new sub-installation or remaining on the same sub-installation). - The two years rolling average should be considered as the main triggering a potential allocation change (in all cases).
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