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CEMBUREAU - The European Cement Association

CEMBUREAU

CEMBUREAU is the representative organization of the European cement industry and its national associations.

Lobbying Activity

Meeting with Kurt Vandenberghe (Director-General Climate Action)

16 Jan 2026 · Follow-up exchange on competitiveness and decarbonisation of the EU cement industry.

Meeting with Alexandr Hobza (Cabinet of Executive Vice-President Stéphane Séjourné)

14 Jan 2026 · Discussion about the Commission’s proposal for the 2028–2034 Multiannual Financial Framework (MFF), particularly in relation to industrial decarbonisation and clean technology deployment

Meeting with Kurt Vandenberghe (Director-General Climate Action)

7 Jan 2026 · Exchange on competitiveness and decarbonisation of the EU cement industry.

Cembureau urges stable taxonomy criteria to protect green investments

5 Dec 2025
Topic — This consultation reviews the EU taxonomy to update and simplify technical screening criteria.
Message — Cembureau opposes shifting to EU ETS benchmarks and lowering clinker-to-cement ratios. They demand stable, technologically neutral criteria to ensure long-term investment certainty.12
Why — This would prevent sudden drops in alignment levels and reduce administrative complexity.34
Impact — Environmental objectives suffer if technical thresholds are not tightened to reflect technological progress.56
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Meeting with Maria Elena Scoppio (Director Taxation and Customs Union) and

14 Nov 2025 · Discussions on technical issues concerning the design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM.

Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

Meeting with Heiko Kunst (Head of Unit Climate Action)

2 Oct 2025 · Product benchmark update for the cement sector

CEMBUREAU warns nature credits roadmap lacks market clarity and timelines

30 Sept 2025
Topic — EU roadmap for developing voluntary nature credits to support biodiversity restoration.
Message — The cement industry requests clearer market guarantees and a more realistic timeline. They oppose mandatory credit requirements for projects already meeting environmental standards, arguing this would undermine the voluntary nature of the system.123
Why — This would prevent additional compliance costs for cement projects already meeting environmental requirements.45
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

26 Sept 2025 · Exchange of views on the EU climate policies for the cement sector

European Cement Industry Seeks Alignment of CBAM with ETS Binder Benchmark

25 Sept 2025
Topic — Rules for adjusting CBAM certificates based on free EU ETS allowances.
Message — The industry requests that CBAM benchmark calculations align with the EU ETS binder benchmark introduced in 2026. They propose a formula multiplying the ETS benchmark by CBAM and correction factors, then by clinker-to-cement ratio. They highlight the complexity of accounting for alternative hydraulic binders in imported cement.12
Why — This would ensure their CBAM obligations match the benchmark used for their free ETS allocations.34
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European Cement Industry Seeks Stricter CBAM Rules for Non-EU Imports

25 Sept 2025
Topic — Methodology for calculating embedded emissions under the Carbon Border Adjustment Mechanism.
Message — CEMBUREAU requests that non-EU cement imports follow the same monitoring rules as EU producers, including biomass sustainability criteria. They want significantly higher default emission values (30% markup) applied when importers cannot provide actual data, and national averages used to combat resource shuffling.123
Why — This would protect EU cement producers from cheaper imports with lower reported emissions.45
Impact — Non-EU cement producers face higher carbon costs if unable to provide detailed emissions data.67
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Cement industry seeks clarity on biogenic CO2 capture under carbon removal rules

22 Sept 2025
Topic — EU regulation establishing certification methodologies for permanent carbon removal activities including DACCS and BioCCS.
Message — The association requests clearer definitions for capture facilities to include industrial installations under the EU ETS. They want clarification on biomass supplier emissions accountability and recognition that biogenic CO2 from industrial processes should count toward carbon removal credits.123
Why — This would allow cement plants capturing biogenic CO2 to qualify for carbon removal certification and credits.45
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Meeting with Vicente Hurtado Roa (Head of Unit Taxation and Customs Union) and European Chemical Industry Council and

19 Sept 2025 · Discussions on technical issues concerning the design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Cement industry demands fair access to EU CO2 infrastructure

11 Sept 2025
Topic — A legislative initiative to develop competitive markets and transportation infrastructure for carbon dioxide.
Message — CEMBUREAU calls for an EU-wide CO2 transport network that ensures all cement plants have non-discriminatory access at fair prices. They request faster permitting by designating carbon capture projects as being of overriding public interest while seeking more government funding to support high operational costs.123
Why — These measures would lower financial barriers and provide regulatory certainty for expensive industrial decarbonization projects.4
Impact — Local communities and environmental groups may have less influence over projects fast-tracked under overriding public interest rules.5
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Cement industry demands ETS indirect compensation eligibility amid soaring electricity costs

5 Sept 2025
Topic — ETS guidelines update on indirect cost compensation for electro-intensive sectors facing carbon leakage risks.
Message — CEMBUREAU requests inclusion in the ETS indirect compensation guidelines, arguing the sector faces carbon leakage risk from high electricity costs and import competition. They want assessment based on clinker not just cement, and insist indirect emissions remain in CBAM scope even if eligible for compensation.123
Why — This would offset rising electricity costs that tripled between 2021 and 2022 to EUR 3.51 billion.45
Impact — European consumers face higher costs if imports increase from countries with lower electricity prices and weaker climate standards.67
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Meeting with Patrice Pillet (Cabinet of Commissioner Wopke Hoekstra)

28 Jul 2025 · CBAM

Response to Revision of the Standardisation Regulation

18 Jul 2025

Tackling the objectives of accelerating the development of harmonised standards. Case of Construction Products. The overall process is based on two pillars, conducted successively: - legal process with CPR Acquis to prepare a Standardisation Request (SReq) - technical process with the European Standardisation Organisations (ESOs), including legal control (HAS consultant), to prepare product standards 1. Priority is to tackle the legal process which is not swift. Once a Standardisation Request (SReq) has been adopted, a simplified procedure should be officially implemented (which is not the case today) to amend the SReq, in particular if the request, supported by a complete technical dossier, comes from ESOs experts. More flexibility at this level would significantly enhance the uptake of new construction products since a preliminary consensus would have been achieved among experts in ESOs Technical Committees. 2. ESOs processes, and CEN process in particular, are not the main problems to tackle, and potential improvements are of secondary order.
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Meeting with Radan Kanev (Member of the European Parliament)

14 Jul 2025 · Clean Industrial Deal

European Cement Industry Urges EU ETS Stability and Support for Decarbonization

8 Jul 2025
Topic — Review of EU Emissions Trading System rules affecting cement manufacturing and climate targets.
Message — The industry requests regulatory stability with 18-24 months notice for rule changes, exclusion of carbon capture projects from benchmarks, and seamless fungibility between carbon removals and ETS allowances. They argue frequent adjustments undermine investment confidence and current rules don't support the business case for deep decarbonization.1234
Why — This would give them more time to adjust investment plans and reduce compliance costs from benchmark changes.567
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Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

3 Jul 2025 · Discuss decarbonisation of the cement industry.

Meeting with Johannes Ten Broeke (Cabinet of Commissioner Wopke Hoekstra), Patrice Pillet (Cabinet of Commissioner Wopke Hoekstra)

24 Jun 2025 · CBAM

Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen) and Concrete Europe

12 Jun 2025 · Housing

Meeting with Koen Van De Casteele (Director Competition)

20 May 2025 · Exchange of views on the new State aid rules being developed to accompany the Clean Industrial Deal

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)

11 Apr 2025 · Financing decarbonisation and competitiveness challenges of EU cement industry. Potential impact of US reciprocal tariffs.

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

10 Apr 2025 · Specific issues related to the decarbonation of the cement sector within the perspective of the CID

Meeting with Maria Elena Scoppio (Director Taxation and Customs Union) and European Chemical Industry Council and

14 Mar 2025 · Discussions on technical issues concerning the design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

12 Mar 2025 · Listening to CEMBUREAU’s views on their sector’s path towards decarbonisation

Meeting with Johannes Ten Broeke (Cabinet of Commissioner Wopke Hoekstra), Patrice Pillet (Cabinet of Commissioner Wopke Hoekstra)

10 Mar 2025 · Exchange of views on the Carbon Border Adjustment Mechanism and decarbonisation of the cement sector in the context of the Clean Industrial Deal

Meeting with Radan Kanev (Member of the European Parliament) and EUROMETAUX and

6 Mar 2025 · European Energy Forum- Energy intensive industries

Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

Thank you for the opportunity to give our views on the documents. Energy intensive decarbonisation projects are mentioned in Article 3(16) NZIA with special reference to "net-zero strategic projects" which include CCS projects in Article 3(18) NZIA. The recognition as a net zero strategic project is relevant for faster permitting and coordination of financing. What is a major concern in the document is the reference to innovation capability. It is limiting the support to the first of its kind installations. Innovation is also the major criteria for the EU ETS innovation fund. And for sure decarbonisation of energy intensive industries will need innovation, but not only. Deployment of already existing technologies is becoming even more important. The first of its kind in cement industry for decarbonization in the cement industry might apply technology A, while that same technology will be applied by at least 10 or even 50 other installations. Limiting to innovation is limiting the huge challenges in the cement industry (and any other energy intenstive industrial sector) to one installation, while perhaps thousands installations have to converted. Even more challenging is the short list of technologies being considered. That short list is not taking into account the technologies being applied in eligible large scale projects under the EU ETS innovation fund. We consider that other technologies, like amine absorption, hot potassium carbonate, oxyfuel, calcium looping and indirect calcination should be included too. Just as an example, in one of the cement projects under the Innovation Fund a switchable air-oxyfuel dry kiln is coupled with a cryogenic purification unit. The CO2 is enriched by recirculation in the sintering system, with a special design for the kiln and its peripheral equipment. We have added our list of technologies again. Furthermore challenging is the combination to environmental sustainability requirements. New technologies, especially break through technologies in the cement industry, will result in a complete different environmental impact. Challenging is that the current framework, but also the framework pictured in the documents, do not open the closed perspective on the new environmental impacts. What about changes from impact to the air to waste water? Equally important are projects that might have a lower, but equal challenging climate change result. Perhaps not reaching net-zero, but for sure contributing positively to both the reduction of the climate change impact and the development of technology and essential for reaching net-zero by the sector in the future. We miss this in the documents too.
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Meeting with Katharina Knapton-Vierlich (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Verein Deutscher Zementwerke e.V. and

20 Feb 2025 · Discuss the CPR Acquis process and the next steps for the drafting of standardisation request for ready-mix concrete and its links with the standardisation request for cement, precast concrete and aggregates

Meeting with Jeannette Baljeu (Member of the European Parliament)

20 Feb 2025 · Industrial policies

Meeting with Christian Ehler (Member of the European Parliament)

14 Feb 2025 · Antwerp Declaration, Competitiveness

Meeting with Jeannette Baljeu (Member of the European Parliament)

6 Feb 2025 · Cement sector challenges

Meeting with Lucia Granelli (Head of Unit Taxation and Customs Union), Vicente Hurtado Roa (Head of Unit Taxation and Customs Union)

3 Feb 2025 · Exchange of views on enforcement of the Carbon Border Adjustment Mechanism (CBAM) for cement imports

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs) and

28 Jan 2025 · Exchange of views on policies for the construction industry including the Implementation of the Construction Product Regulation, the Affordable Housing Plan, the Clean Industrial Deal, and the Circular Economy Act.

Meeting with Maria Elena Scoppio (Director Taxation and Customs Union) and

17 Jan 2025 · Discussions on technical issues concerning the design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Meeting with Eero Heinäluoma (Member of the European Parliament)

16 Jan 2025 · Breakfast event

CEMBUREAU urges reforms to EU ETS allocation rules penalizing decarbonization investments

9 Jan 2025
Topic — EU ETS implementation rules for adjustments to free allocation due to activity level changes.
Message — The organization requests changes to Dynamic Allocation Rules that currently penalize decarbonization investments with delayed allocation. They oppose extensive reporting requirements like Climate Neutrality Plans and Reports, arguing these formalities divert resources from actual climate action.123
Why — This would eliminate additional ETS compliance costs from decarbonization investments and reduce bureaucratic burdens.45
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Cement industry urges stricter data requirements for CBAM importers

27 Nov 2024
Topic — Rules for authorising declarants under the EU Carbon Border Adjustment Mechanism.
Message — The association wants importers to use data from third-country installations registered in the CBAM registry. They propose adding a criterion requiring applicants to import only from operators registered in the CBAM Registry.12
Why — This would ensure competing imports face the same carbon pricing as European cement producers.3
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Response to Establishment of the CBAM Registry

27 Nov 2024

Please find attached a statement co-signed by CEMBUREAU on the transparency of the CBAM registry.
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Meeting with Pascal Canfin (Member of the European Parliament)

13 Nov 2024 · Clean Industrial Deal

Meeting with Pascal Canfin (Member of the European Parliament) and ClientEarth AISBL

29 Oct 2024 · Clean Industrial Deal

Cement industry urges EU to allow industrial CO2 until 2050

25 Oct 2024
Topic — This consultation defines the methodology for calculating greenhouse gas emission savings from low-carbon fuels.
Message — The association requests extending the use of industrial CO2 for fuel production until 2050. They argue that landlocked plants need carbon recycling as an alternative to storage.12
Why — This would protect the profitability of carbon capture projects requiring decades to recoup costs.3
Impact — Environmental goals may be compromised by delaying the phase-out of industrial carbon emissions.4
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Meeting with Dimitris Tsiodras (Member of the European Parliament) and European Environmental Bureau and ClientEarth AISBL

2 Oct 2024 · Environmental policies

Meeting with Yannis Maniatis (Member of the European Parliament)

2 Oct 2024 · Introductory Meeting

Meeting with Pascal Canfin (Member of the European Parliament)

19 Sept 2024 · climate action

Meeting with Radan Kanev (Member of the European Parliament)

12 Sept 2024 · Industrial decarbonization

CEMBUREAU urges more flexible rules for carbon accounting

26 Jul 2024
Topic — This consultation updates rules for monitoring and reporting industrial greenhouse gas emissions.
Message — The association requests flexibility in accounting for carbon capture and negative emissions. They propose adjusting rules to avoid mandatory production of negative greenhouse gases.12
Why — Greater flexibility would help companies avoid extreme investment and operating costs.3
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CEMBUREAU Urges Broader Recognition of Permanent CO2 Storage in Products

15 Jul 2024
Topic — EU regulation on conditions for greenhouse gases permanently bound in products under ETS.
Message — The cement industry requests recognition that CO2 storage in recycled chemical products like plastics should count as permanent if properly recycled. They also want CO2 allowances surrendered by emitters rather than capturing installations for non-permanent uses.12
Why — This would enable carbon capture investments at landlocked cement kilns without geological storage access.34
Impact — Environmental groups lose stricter controls ensuring CO2 remains permanently removed from atmosphere.5
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

14 Jun 2024 · Physical meeting - Annual General Assembly of all cement industries CEOs

Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

Please find enclosed CEMBUREAU, the European Cement Association, feedback to the call for evidence on Social Climate Fund guidance on applying the do no significant harm principle.
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

8 Feb 2024 · Videoconference - Exchange on CBAM

Meeting with Maroš Šefčovič (Executive Vice-President) and

2 Feb 2024 · Roundtable with associations of industrial users

Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)

29 Jan 2024 · Decarbonisation in the cement industry

Meeting with Adam Romanowski (Cabinet of Vice-President Maroš Šefčovič)

26 Jan 2024 · Decarbonisation of energy intensive industries

Meeting with Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

15 Jan 2024 · Presentation of the company and of the cement sector's issues related to CCUS and how to incentivise CO2 use, incl. revising the ETS legislation.

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

15 Jan 2024 · Exchanges on the upcoming industrial carbon management strategy, the role of CCS and CCU to decarbonise the EU cement sector. Vision on the forthcoming EU cement industry roadmap.

CEMBUREAU opposes EU cement benchmark changes and publication requirements

2 Jan 2024
Topic — EU regulation updating free allocation rules for emission allowances under ETS.
Message — CEMBUREAU opposes changing the clinker benchmark, requesting clarity on energy audit requirements and climate neutrality plan submission dates. They urge excluding COVID-affected years from production calculations and oppose publishing climate neutrality plans.1234
Why — This would preserve existing incentive structures while avoiding legal uncertainty around investments.56
Impact — Climate advocates lose potential acceleration of cement chemistry innovation and transparency.7
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

14 Dec 2023 · Physical meeting with CEMBUREAU CEOs on CBAM

CEMBUREAU urges standardized reporting to reduce administrative burdens

30 Nov 2023
Topic — The Commission initiative aims to reduce company reporting requirements by twenty-five percent.
Message — CEMBUREAU proposes adopting a standardized framework like the Sustainability Accounting Standards Board to improve consistency. They suggest reporting significant emissions rather than maintaining extreme granularity for every filter. A single integrated system for government reporting would eliminate overlaps between national and EU laws.123
Why — Standardization would lower costs by reducing the high number of staff dedicated to reporting.4
Impact — Regulators and communities would lose access to highly granular data on specific industrial emissions.5
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

24 Oct 2023 · Conference : Cementing Europe’s Future: Buildings for a Net Zero Age

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

16 Oct 2023 · on Clean Transition Dialogues

Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

28 Sept 2023

CEMBUREAU recognises the value of the EU standardisation system for the well-functioning of the EU single market, which has the market-driven Construction Products Regulation for CE Marking as the main pillar for the construction sector. The European standardisation system has proven a catalyst for competitiveness, innovation, and consumer safety in Europe, making European standards a global benchmark. CEMBUREAU has always praised the fact that the European cement standard EN 197-1 was the first harmonised standard in Europe. EN 197-1 has clearly supported the competitiveness of the EU cement industry both across the EU and internationally, as the technical specifications have been used not only in Europe but also across the world for 30 years. The system has thus proven to work. We believe that the evaluation should tackle the standardisation issues intrinsic to the EU internal market, including procedural aspects and the mechanisms to ensure speed and quality, finding ways to incentivise coordination, efficiency, and flexibility in the timely delivery of standards. Attention should be given to the relation between horizontal and vertical standards. For the sake of coherence and transparency between sectors and product categories, horizontal standards developed by dedicated technical committees should precede vertical standards from product technical committees. We need state-of-the-art standards to facilitate innovation to respond to the challenges addressed in the European Green Deal and deliver on its goals. The European cement sector has been negatively affected by the blockage of the revision process of EN 197-1. This has resulted in a delay in placing new lower carbon cements into the single market and we were regrettably compelled to explore the non-harmonised route for developing the new standards EN 197-5 and EN 197-6. The gradual penetration of these lower carbon cements in the market will contribute to the decarbonisation of the construction value chain through 2050. Additionally, CEMBUREAU supports keeping the current two-track harmonisation system (the main standardisation route complemented by the EOTA route). The European Technical Assessment (ETA) route represents an alternative for innovative and niche products to have quick access to the internal market and help the European construction sector compete on the international scene. To get the European standardisation system running, CEMBUREAU strongly supports CEN in the driving seat in developing harmonised standards. What grants harmonised standards the reflection of the state of the art is the full representation of all stakeholders both at European and national level in the standardisation process, which is guaranteed by CEN. Grants to support ESOs activities is fundamental to provide sustainable solutions to the climate change issues through standardisation. CEMBUREAU believes more must be done on financing European standardisation as it requires, in our case, for instance, investigating materials coming from construction and demolition waste to be used as new constituents; identifying promising new constituents for cements, facilitating the introduction of new or revised products standards in application standards (like concrete) across Europe; supporting development and validation of test methods. CEMBUREAU will engage in the consultation activities foreseen in Q3-Q4 2023 and would be pleased to have the opportunity to have bilateral meetings with the Commission to express our views.
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European Cement Industry Seeks Flexibility in Climate Neutrality Plans

1 Sept 2023
Topic — EU rules on climate-neutrality plans for industrial sites receiving free emission allowances.
Message — CEMBUREAU wants exemptions from climate-neutrality plans for installations performing below the 80th percentile benchmark. They request making justifications for chosen decarbonisation measures optional rather than mandatory. They also demand confidentiality protections to prevent publication of climate plans.123
Why — This would reduce reporting burdens and protect commercially sensitive decarbonisation strategies from disclosure.45
Impact — Transparency advocates lose public oversight of industrial climate commitments and emissions performance.6
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CEMBUREAU urges fair carbon accounting for recycled concrete materials

23 Aug 2023
Topic — Update of EU ETS rules for monitoring and reporting greenhouse gas emissions.
Message — The association requests that CO2 captured through concrete carbonation not be counted under ETS. They want equal treatment of biomass between ETS and non-ETS installations. They also ask for Article 49 to accommodate all CO2 transport modes beyond pipelines.123
Why — This would reduce their reported emissions when using recycled concrete and biomass fuels.45
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Cement industry warns new Innovation Fund criteria increase project risks

7 Aug 2023
Topic — Changes to EU ETS Innovation Fund introducing competitive bidding for climate projects.
Message — The association opposes the proposed efficiency criterion that divides grant amount by emissions avoided over 10 years. They argue this competitive bidding approach forces companies to reduce requested grants, increasing financial risks. For carbon capture, the most cost-effective solution is not always the best technical solution.12
Why — This would allow them to secure larger grants with less financial risk.3
Impact — Taxpayers lose as projects may choose cheaper but less effective carbon capture technologies.4
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European cement industry urges stricter CBAM fraud prevention measures

3 Jul 2023
Topic — EU carbon border adjustment mechanism implementation rules for transitional reporting period.
Message — The association requests stricter fraud prevention measures, including mandatory sampling of imported cement products and verification of clinker-to-cement ratios. They want limited flexibilities in reporting methods and stronger penalty systems during the transition period.123
Why — This would protect them from competing against fraudulently declared low-carbon imports.45
Impact — Third-country cement producers lose flexibility in reporting and face stricter verification requirements.6
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Meeting with Tsvetelina Penkova (Member of the European Parliament, Shadow rapporteur)

1 Jun 2023 · Meeting with Cembureau on NZIA

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

24 May 2023 · Net Zero Industry Act

Meeting with Tiemo Wölken (Member of the European Parliament, Rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment) and

22 May 2023 · Net-Zero Industry Act Stakeholder Hearing

Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

Please find attached CEMBUREAU - the European Cement Association's feedback to the call for evidence. Thanks.
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

25 Apr 2023 · Delegated Act RFNBO/RCF

Response to Guidelines on exclusionary abuses of dominance

24 Apr 2023

Dear Madam, Dear Sir, Please find attached the contribution by the European Cement Association CEMBUREAU. Best regards, Koen Coppenholle Chief Executive
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Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager), Thomas Woolfson (Cabinet of Executive Vice-President Margrethe Vestager)

24 Apr 2023 · existing policies for support of carbon capture projects and the Net Zero Industry Act.

European Cement Association urges pragmatic chemical labelling rules

29 Mar 2023
Topic — This consultation concerns revising rules for the classification, labelling, and packaging of chemicals.
Message — CEMBUREAU requests that labelling requirements consider physical constraints like cement bag durability. They advocate for practical update timeframes and voluntary, pragmatic digital labelling rules.123
Why — This approach would lower operational costs by avoiding impractical packaging requirements.45
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CEMBUREAU demands EU recognition for concrete carbon removal potential

21 Mar 2023
Topic — The Commission aims to create a certification system for industrial and natural carbon removals.
Message — The association wants the EU to certify biogenic CO2 capture and concrete carbonation as permanent carbon removals. They also propose making these certificates tradable within the existing EU emissions trading system.123
Why — This would allow cement companies to generate tradable credits and offset their industrial emissions.4
Impact — The timber sector is disadvantaged by recommendations to exclude wood products from carbon removal certification.5
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Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson)

9 Mar 2023 · Presentation of CEMBUREAU's views on the Net Zero Industry Act and the CCUS value chain and cement contribution

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

16 Feb 2023 · Preparation of net zero industry and critical raw materials acts

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Aluminium AISBL and

20 Oct 2022 · circular economy and construction sector

Meeting with Michal Wiezik (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

11 Oct 2022 · Industrial Emissions Directive

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

7 Oct 2022 · Carbon Capture Storage and Use

Meeting with Radan Kanev (Member of the European Parliament, Rapporteur)

27 Sept 2022 · IED

Cement industry seeks broader scope for EU co-processing rules

20 Jul 2022
Topic — This consultation defines how to calculate renewable energy shares during co-processing.
Message — The association asks to expand the definition of co-processing to include waste used in cement kilns. They also want these rules to apply to other sectors.12
Why — This would help the industry reduce emissions and lower reliance on imported fuels.34
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Response to Review of the Construction Products Regulation

12 Jul 2022

The European cement industry is committed to achieve carbon neutrality by 2050 as set out in CEMBUREAU Carbon Neutrality Roadmap outlining the CO2 reduction pathways in clinker/cement manufacturing and in production/use/end-of-life of its end-product, concrete. Concrete is a key building material for tomorrow’s sustainable built environment thanks to its durability, strength, recyclability and carbonation potential. CEMBUREAU is a supporter of the common technical language established by the CPR for CE Marking. The European cement standard EN 197-1 was the 1st harmonised standard in Europe and it has been used across the world for 30 years. CEMBUREAU thus welcomes the European Commission new CPR proposal although the European cement industry would have preferred limited changes to the CPR (option A). The CPR has a crucial role to play in supporting the delivery of low-carbon construction materials if it enables a timely and flexible standardisation process, meeting the needs of the market. CEMBUREAU agrees with the aim to achieve a well-functioning single market for construction products and contribute to the objectives of the green and digital transition, thus welcomes the strengthening of the market surveillance and the use of digitalisation to provide information across the value chain. We raise 6 key points for the co-decision process: 1. When it comes to the standardisation process: - A swift solution to the backlog of citation of harmonised standards in the OJEU should be found to introduce new lower-carbon cements in the EU market and facilitate the transition to a climate neutral society. - CEMBUREAU supports the CPR Acquis process to deal with old mandates and new standardisation requests to get back rapidly to a well-functioning system. - CEN should lead the development of standards and identify the technical (CEN) and legal (Commission) boundaries in the standardisation process. On these, CEMBUREAU welcomes the outline of the harmonised zone and CEN’s role of drafting standards. - Durability & safety of construction products should be top priorities for the construction ecosystem. The new CPR should provide for compliance with both the legal zone and for the fulfilment of the technical requirements of construction codes. 2. CEMBUREAU supports the broader coverage of sustainability aspects of construction products. We insist that the declaration of environmental and climate data should provide information to the value chain with a view to their use at the construction work (infrastructure, building) level, where full life cycle assessments should be carried out. CEMBUREAU thus expresses concerns about the "traffic light labelling" at product level. 3. CEMBUREAU emphasises the need for a stable regulatory framework. To avoid uncertainties and ever-changing rules, delegated acts should remain exceptional and follow clear established criteria, and the empowerment to the Commission to adopt them should be limited. Nonetheless all involved stakeholders should be included in the elaboration of delegated acts. 4. CEMBUREAU raises attention to additional efforts, costs, administrative burden of the proposal. There are no guarantees of the proposal’s claimed cost reduction through a well-performing standardisation process. 5. The European cement industry welcomes the Digital Product Passports. However, there are uncertainties related to confidentiality and ownership of sensitive data to be stored, shared and accessed in a Union construction products database/system. 6. CEMBUREAU expresses concerns on the zero tolerance for non-conformities in the Assessment and Verification System which is not executable in common production processes. Penalties and consequences as well as a complaint portal would raise legal concerns. For a better understanding of the complexities of the Commission proposal for a new CPR, a clarification on how it will work for cement standards and the future of standardisation of cement is fundamental.
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European cement industry fights 2035 limit on industrial CO2

17 Jun 2022
Topic — EU rules for measuring greenhouse gas savings from recycled and renewable transport fuels.
Message — The association suggests removing the 2035 limit on using industrial CO2 for fuel production. They argue these proposals are premature without an impact assessment or political discussion. They also request that carbon pricing be decided by market participants rather than fixed upstream.123
Why — This would preserve the economic viability of the industry's ongoing carbon capture projects.4
Impact — Transport sectors lose access to affordable synthetic fuels due to restricted carbon sources.5
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

5 May 2022 · REPowerEU; fit for 55 package

Meeting with Malin Björk (Member of the European Parliament, Shadow rapporteur)

5 Apr 2022 · CBAM

Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur for opinion)

11 Jan 2022 · EU ETS

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

25 Nov 2021 · Energy state aid guidelines

Response to Revision of the Energy Tax Directive

18 Nov 2021

Please find in attachment CEMBUREAU's position on the Commission's proposal.
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European cement industry urges CBAM strengthening before free allocation phase-out

18 Oct 2021
Topic — EU Emissions Trading System review to align with 55% emission reduction target by 2030.
Message — The organization requests that Carbon Border Adjustment Mechanism be fully operational and effective before phasing out free allocation of emission allowances. They want CBAM to include indirect emissions, export solutions, and watertight monitoring. They also request clear carbon accounting rules to incentivize CO2 reuse and inclusion of waste incinerators in the ETS.123
Why — This would protect them from carbon leakage and maintain their competitiveness against imports.456
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European Cement Industry Demands Stronger CBAM Before Phasing Out Free Allocation

18 Oct 2021
Topic — EU proposal to establish carbon border adjustment mechanism for imported products.
Message — CEMBUREAU requests that CBAM fully equalise CO2 costs between EU and non-EU suppliers before any phase-out of free allocation begins. They want indirect emissions included, a solution for exports, and faster implementation to prevent carbon leakage from rising imports.123
Why — This would protect cement producers from competitive disadvantage as CO2 costs rise to 8-10% of total production costs.45
Impact — Non-EU cement producers lose competitive advantage from avoiding carbon costs faced by European competitors.67
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Meeting with Kadri Simson (Commissioner) and

14 Oct 2021 · High energy prices and how this is affecting the competitiveness of European companies in the energy intensive sectors.

Response to Restoring sustainable carbon cycles

7 Oct 2021

The European Cement Association, CEMBUREAU, hereby submits its comments on the European Commission’s “Roadmap on restoring sustainable carbon cycles” and is looking forward to a continued interaction on the topics set out below with all relevant stakeholders in the debate. The reflections in this note are provided in the context of CEMBUREAU’s 2050 Carbon Neutrality Roadmap “Cementing the Green Deal” in which the cement industry sets out the technological and innovation pathways to achieve carbon neutrality by 2050. These pathways span the full value chain and assess the CO2 reduction potential in both the manufacturing part of the business (clinker and cement manufacturing) as in the production, use and end-of-life of the end product, concrete, which is a key enabling building material for tomorrow’s sustainable built environment thanks to its durability, strength, recyclability and its recarbonation potential. The CEMBUREAU Roadmap puts forward intermediate CO2 reduction targets of 30% (cement) and 40% (over the value chain) by 2030. Achieving the CO2 reduction targets requires significant investments that, on their turn, are preconditioned by a stable and facilitating regulatory framework that guarantees viable investment projects with proper returns on investment. The Roadmap published by the European Commission addresses a number of these key regulatory issues CEMBUREAU would like to provide its views on: 1. Lack of sustainable framework for carbon use 2. Recarbonation / Buildings as a carbon sink 3. Replacement of virgin carbon fuels by sustainable streams of waste and biomass waste Please find our detailed feedback in the position paper attached.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

28 Sept 2021 · Fit for 55, energy prices

Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager)

21 Sept 2021 · Draft State aid Guidelines on Climate, environmental protection and Energy

Response to Standardisation Strategy

9 Aug 2021

CEMBUREAU welcomes the opportunity to provide feedback on the Commission Standardisation Strategy Roadmap. CEMBUREAU recognises the value of the EU standardisation system for the well-functioning of the EU single market. The harmonised cement standard EN 197-1 has clearly supported the competitiveness of the EU cement industry both across the EU and internationally. While setting international standards is critical for the EU’s competitiveness, we believe that standardisation issues intrinsic to the functioning of the EU internal market should be prioritised and tackled first, like e.g., addressing bottlenecks within the standardisation system, including procedural aspects and working on the delivery mechanisms to ensure speed and quality, and finding ways to incentivise coordination, efficiency and flexibility in the timely delivery of European standards. As per the roadmap, the European Commission seeks feedback particularly on: 1) whether the current European standardisation system is fit for purpose to support European strategic interests: As the non-paper of Member States referenced in the Commission’s roadmap states, the European standardisation system has proven a catalyst for competitiveness, innovation, and consumer safety in Europe, making European standards a global benchmark. The moment is crucial for the challenges the EU is facing with the recovery post-Covid and climate urgency. We need state-of-the-art standards to facilitate innovation to respond to those challenges addressed in the European Green Deal and deliver on its goals. The European cement sector is among the stakeholders that have been amongst those negatively affected by the blockage of the revision process of the cement standard EN 197-1 and, more largely, by the larger governance challenges in the standardisation process. For our sector, this has resulted in a delay in placing new lower carbon cements into the single market and we were regrettably compelled to explore an alternative route for developing the new standard, which has recently been published as the non-harmonised standard EN 197-5. The EU cement industry trusts that the gradual penetration of these lower carbon cements in the market will contribute to the decarbonisation of the construction value chain through 2050 and thereby deliver on the European Green Deal goals. Notwithstanding the backlog of the revised harmonized European standards, CEMBUREAU remains a strong supporter of the standardisation system as it is, which has the market-driven Construction Products Regulation for CE Marking as the main pillar for the construction sector. CEMBUREAU calls on:  Solutions in the short term to get the current system working again.  Flexibility in the creation/revision of standards enabling the introduction of innovations.  Accelerated time for implementation of new products  Clarification between legal aspects and technical specifications.  Reinforced measures against unilateral actions by any Member State that run against the concept of an integrated internal market. 2) how the EU can leverage and promote global leadership in standards-setting: CEMBUREAU has always praised the fact that the European cement standard EN 197-1 was the first harmonised standard in Europe. The technical specifications in EN 197-1 have been used not only in Europe but across the world in many cases for 30 years. The system as it is has thus proven to work, so CEMBUREAU is of the opinion that improvement in the system could be achieved by adopting adjustments rather than by radical changes. Additionally, CEMBUREAU would like to stress its support to keeping the current two-track harmonisation system (the main standardisation route complemented by the EOTA route). Rather than industry experts opting out the European standardisation system in favour of international standards, as the 17-MS non-paper claims, the European Technical Assessment (ETA) route represents an alternative for innovative and n
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union) and TITAN CEMENT INTERNATIONAL SA

23 Jul 2021 · Videoconference - Follow-up meeting to the COM proposal for a CBAM

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

2 Jul 2021 · Carbon Border Adjustment Mechanism; EU ETS

Meeting with Valdis Dombrovskis (Executive Vice-President) and CRH plc and TITAN CEMENT INTERNATIONAL SA

29 Jun 2021 · - EU cement industry's decarbonisation efforts - Fit for 55, trade and carbon leakage - CBAM

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

15 Jun 2021 · Videoconference - Exchange of views on practical implementation of a CBAM

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis)

3 Jun 2021 · Carbon Border Adjustment Mechanism (CBAM)

Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

31 Mar 2021

Please find attached the comments from CEMBUREAU, the European Cement Association.
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Meeting with Thierry Breton (Commissioner) and

24 Mar 2021 · Commissioner Breton meeting with CEOs from Energy Intensive Industries on Industrial strategy & fit for 55.

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

CEMBUREAU, the association of the European cement industry, welcomes the opportunity to provide feedback on the Commission’s inception impact assessment on the revision of the Energy Performance of Buildings Directive. CEMBUREAU’s 2050 Carbon Neutrality Roadmap, which was published in May 2020, sets out the cement industry’s ambition to reach net zero emissions along the cement and concrete value chain by 2050. Ambitious policies will be essential to achieve this objective and decarbonise the European building stock. As highlighted in the Green Deal, the annual renovation rate of the building stock varies from 0.4% to 1.2%. As a result, many buildings are simply not energy-efficient and bring about 50 million people in Europe in energy poverty. CEMBUREAU therefore supports a review of the EPBD to foster the rate of renovation and further incentivise deep renovation and reduce the energy consumption of the European building stock, in line with the Renovation Wave initiative. In this context, we submit our attached position paper with some comments on the inception impact assessment under the two headlines below: - The EPBD should acknowledge activation of thermal energy as a complement to passive thermal inertia / Buildings as actors in the energy system - The review of the EPBD needs to carefully consider the interaction with other sustainable construction policies, and material neutrality is key to efficiently decarbonise European buildings
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Meeting with Florika Fink-Hooijer (Director-General Environment)

4 Mar 2021 · points of discussion: circular economy sustainable built environment Biodiversity Air quality

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

23 Feb 2021 · Videoconference - Exchange on CBAM

CEMBUREAU challenges EU cement emissions benchmark calculation methodology

4 Jan 2021
Topic — Revised benchmark values for free allocation of emission allowances 2021-2025.
Message — The organization requests exclusion of by-pass dust from activity levels when determining the grey clinker benchmark. They argue the proposed 692 kgCO2/tCl benchmark incorrectly includes by-pass dust, violating existing ETS rules and ignoring chemical differences between clinker and by-pass dust.123
Why — This would increase their free emission allowances by excluding by-pass dust from production calculations.45
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Response to Revision of the Communication on important projects of common European interest

21 Dec 2020

Please find CEMBUREAU's position in attachment.
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

16 Dec 2020 · Carbon Border Adjustment Mechanism

Response to Climate change mitigation and adaptation taxonomy

11 Dec 2020

CEMBUREAU, the European Cement Association, welcomes the opportunity to provide feedback on the draft Delegated Act setting the technical criteria for climate change mitigation and adaptation. CEMBUREAU’s commitment to Climate Change Mitigation is strong and our 2050 Climate Neutrality Roadmap (https://cembureau.eu/news-views/publications/2050-carbon-neutrality-roadmap), which was published in May 2020, sets out the cement industry’s ambition to reach net zero emissions along the cement and concrete value chain by 2050. The roadmap looks at how CO2 emissions can be reduced by acting at each stage of the value chain: clinker, cement, concrete, construction and (re)carbonation. It identifies the key pathways to decarbonise the industry, and its key findings are as follows: • Carbon Capture, Use and Storage (CCUS) will account for 42% of the CO2 emissions reduction in the sector. • The replacement of fossil fuels by non-recyclable waste and biomass waste, and the use of alternative raw materials, will deliver another 15% of the emissions reduction in the cement industry. • Bringing low carbon-cements products to the market will deliver an additional 13% emissions reduction. • A level playing field on carbon, regulatory certainty as well as an ambitious industrial transformation agenda, will be pivotal to deliver the investments needed to achieve carbon neutrality. Public and private investments will be key to allow the European cement industry to deploy a wide range of technologies and innovation projects at every step of the cement production process. Sustainable finance, the EU Taxonomy Regulation and the Delegated Act setting the technical criteria for climate change mitigation and adaptation will play a key role to support cement industry in accessing to finance throughout this process. CEMBUREAU broadly welcomes the draft Delegated Act, but would like to offer the following comments: 1. The utilisation of CO2 should be recognized in the Delegated Act 2. The particularity of white cement should be recognized through a dedicated metric and threshold 3. The timing of implementation of the EU Taxonomy non-financial disclosure requirements should be more realistic A more detailed explanation of our comments is available in our position paper attached to our contribution. CEMBUREAU keeps itself at the disposition of the European Commission and the Sustainable Finance Platform for any inquiry on cement production they have which will feed into the delegated acts on non-financial information and on the other environmental objectives they will develop in 2021.
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Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

8 Dec 2020 · PWC study of CEBAM

Cement industry urges carbon border tax and free permits

20 Nov 2020
Topic — The European Commission is revising the Emissions Trading System to meet higher climate targets.
Message — CEMBUREAU argues a carbon border tax should co-exist with free permits to address relocation risks. They request buildings and transport are placed in a separate market to prevent pass-through issues.12
Why — Maintaining free allocation alongside new border measures would lower their direct costs and protect market share.3
Impact — Waste management companies would face new carbon costs and administrative burdens under this proposal.4
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Response to Sustainable Products Initiative

16 Nov 2020

CEMBUREAU, the European Cement Association, welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment (IIA) on the Sustainable Products Initiative. The European Green Deal explicitly recognises the cement industry as essential to the EU economy as it supplies several key value chains. The European cement industry, on its side, is mindful of its environmental footprint, and our 2050 Climate Neutrality Roadmap, which was published in May 2020, sets out the cement industry’s ambition to reach net zero emissions along the cement and concrete value chain by 2050. The development of sustainable products in the cement and concrete sector is an important part of this effort. The industry is also at the heart of the EU’s circular economy through the use of non-recyclable waste and biomass waste in cement production, and through its final product, concrete, which is fully recyclable. Please find attached CEMBUREAU's detailed position. We remain at your disposal for any further discussion.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

CEMBUREAU, the European Cement Association (www.cembureau.eu), welcomes the opportunity to comment on the EU initiative to establish an Action Plan towards a Zero Pollution Ambition for air, water and soil. CEMBUREAU firmly supports the objectives of the European Green Deal and is determined to contribute strongly to the EU’s vision for a carbon neutral society by 2050. On 12th May 2020, CEMBUREAU published its new Carbon Neutrality Roadmap setting out its ambition to reach net zero Greenhouse Gas (GHG) emissions along the cement and concrete value chain by 2050, in line with the European Green Deal. Already today, the European cement industry is reducing its impact on the air pollution through the deployment of a wide range of abatement emissions technologies such as modern dust filtering devices, closed systems for storing, transporting and dosing the raw materials and fuels, on-line emissions analyzers and process control optimization, selective non-catalytic reduction (SNCR) or selective catalytic reduction (SCR) for abatement of NOx emissions, wet scrubbers or lime injection systems in case of high SO2 emissions, chlorine by-pass systems, etc. In addition to the above, a positive impact on air pollution results from other technologies supporting the decarbonization of the sector, from the development of alternative fuels to replace fossil fuels in heating processes, improved energy efficiency of kilns, low-clinker cements, innovative binders, innovative concrete solutions, up to the development of carbon capture and storage/use technologies where the industry is leading the way through several pilot programmes in Europe. Each and every cement plant in the EU operates in accordance with a permit granted by the authorities in the Member States following the principles and provisions of the Industrial Emissions Directive (IED). This Directive specifies how to control emissions from industrial sources other than CO2, through the application of Best Available Techniques (BAT) which are defined in BAT Reference Documents (BREFs). CEMBUREAU believes that the IED and the BREFs are delivering environmental performance across Europe because their approach is flexible, focuses on continuous improvements and addresses local environmental issues holistically. CEMBUREAU firmly believes that the Action plan on Zero Pollution should be focused on measures to strengthen enforcement and implementation of the existing legislation, as mentioned in the inception impact assessment. Such swift implementation of the existing legislation should be prioritized. As regards the existing acquis, CEMBUREAU is of the opinion that the IED and the BREF’s that look into which best available techniques can be implemented at economically acceptable conditions and which is the result of a broad consultation with a variety of stakeholders, still provides a correct regulatory framework. We therefore do not see an immediate need to update this legislation. Finally, CEMBUREAU underlines the recognition in the European Green Deal that the cement industry is indispensable to Europe’s economy, as it supplies several key value chains. As key construction materials for renewable energy equipment, sustainable buildings and mass transit transport, cement and concrete indeed offer the opportunity to accelerate the creation of a carbon-neutral Europe. With the above in mind, we find it is essential that the post-COVID-19 recovery legislative actions create a regulatory environment which incentivizes investment towards supporting the Zero Pollution, taking into account the whole life cycle of the application that manufactured products provide, and provides long-term legal certainty and fosters the industry’s global competitiveness. CEMBUREAU looks forward to being part of the discussions on the EU Action Plan towards a Zero Pollution Ambition to air, water and soil.
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Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius)

27 Oct 2020 · the carbon neutrality and the EU policies in relation to waste

Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

26 Oct 2020

CEMBUREAU, the European Cement Association (www.cembureau.eu), takes note of the Inception Impact Assessment and the opportunity to provide feedback to the European Pollutant Release and Transfer Register (E-PRTR) rules update. CEMBUREAU firmly supports the objectives of the European Green Deal and is determined to contribute strongly to the EU’s vision for a carbon neutral society by 2050. With that in view, CEMBUREAU has recently updated its Carbon Neutrality Roadmap, with the objective of reaching carbon neutrality down the cement and concrete value chain by 2050. Already today, the European cement industry deploys a wide range of technologies and innovation projects at every step of the cement production process, from the development of alternative fuels to replace fossil fuels in heating processes, improved energy efficiency of kilns, low-clinker cements, innovative binders, innovative concrete solutions, up to the development of carbon capture and storage/use technologies where the industry is leading the way through several pilot programmes in Europe. Each and every cement plant in the EU operates in accordance with a permit granted by the authorities in the Member States following the principles and provisions of the Industrial Emissions Directive (IED). CEMBUREAU acknowledges the importance of European Pollutant Release and Transfer Register (E-PRTR), but highlights how crucial it is to have a reliable dataset which is publicly available. We are aware that Governments provide input to E-PRTR with data they received from industry. However, serious inconsistencies are found in the dataset and in many cases the reported figures do not match industry’s own figures, which should in principle be the source for E-PRTR. Several issues have been appointed with the E-PRTR reporting, e.g. on small emitters and thresholds setting; on how to report emissions below detection limits; on emissions from regulatory tests being reported as actual data, on not all Member States reporting all pollutants. With regards to the aspect 3 related to the inclusion of additional pollutants, our view is that the environmental benefits of such decision shall be carefully assessed in order to avoid the reporting of pollutants which may not be relevant for the process of a specific sector. With regards to the aspect 4 related to the access to information, we would like to express our strong concerns for the possibility of collecting contextual fields such as the production volumes of individual operators, having in mind that the disclosure of such information would create market distortions. In view of the E-PRTR relevance, data quality assurance is thus adamant. CEMBUREAU would therefore welcome an improvement in the E-PRTR reporting system which would help to make the E-PRTR data more accurate and reliable. CEMBUREAU looks forward to being part of the discussions on the E-PRTR rules update.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

With regard to the Commission’s IIA, CEMBUREAU has the following comments: • Regardless of the level of ambition for 2030, it is absolutely essential that a thorough impact assessment is conducted by the European Commission to determine the different policy options to reach these targets and their consequences. • Achieving climate neutrality by 2050 will require all sectors of industry and civil society to contribute to greenhouse gas (GHG) emission reductions. This will necessitate the continued program of replacing the generation of electricity by fossil fuels with renewable sources, as well as the reduction of GHG emissions from all forms of buildings and from all forms of transport. • The objective of deeper CO2 cuts at a 2030 horizon – and of carbon neutrality by 2050 – necessitates considerable investments, and will not be met without appropriate political support. CEMBUREAU’s Carbon Neutrality Roadmap makes several recommendations in terms of regulatory frameworks and concrete support measures. Furthermore, the Masterplan for a Competitive Transformation of EU Energy-intensive Industries Enabling a Climate-neutral, Circular Economy by 2050 also contains key recommendations in this respect. Decarbonisation policies based on life-cycle analysis and full value chain approaches, as outlined in the European Green Deal, will be key. • Referring to energy savings in buildings, much of the European building stock will require significant refurbishment to ensure buildings will meet the future needs of society and not just the application of insulation of changing of heating systems. Deep renovation of buildings can be achieved through the re-use of the building structure and the incorporation of thermal mass which allows maximise the use of renewable energy in building (see E3G study). This will reduce both the heating and more important cooling requirement, and hence GHG emissions in the future. It will enable buildings to be designed for multi-use making them more adaptable and to meet the increased demand for comfort required by society. • Reducing GHG emissions will require changes to policy through increasing the options of smart energy integration (refer to CEMBUREAU’s feedback on Preparing a future EU strategy on energy sector integration). • In addition to hydrogen, the important role that Carbon Capture and Use (CCU) needs to planned for, which will provide a renewable source of carbon for chemical and refining industries for the future, replacing the current dependency of fossil-based feedstocks. Mineralisation and Carbon Capture and Storage (CCS) will also play major roles in reducing GHG emissions in industry (please CEMBUREAU’s position paper on TEN-E revision). • To ensure GHG reductions are made in all sectors of society, Option 5 would be the best approach adopting targets for reductions in GHG emissions for buildings and transport, providing non regulatory measures to improve awareness, introducing policies to encourage the switch to low carbon or low energy products and for buildings to take a full life cycle approach to ensure energy usage within the working life of the building is taken into account together with the working life and the end of life treatment. CEMBUREAU stands ready to engage with policy-makers throughout the Directive (EU) 2018/2001 revision process.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

21 Sept 2020 · Discuss their issues on construction and CO2 neutrality

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

CEMBUREAU welcomes the opportunity to provide feedback on the Commission Delegated Regulation on taxonomy-related disclosures by undertakings reporting non-financial information. CEMBUREAU’s 2050 Carbon Neutrality Roadmap, which was published in May 2020, sets out the cement industry’s ambition to reach net zero emissions along the cement and concrete value chain by 2050. Public and private investments will be key to allow the European cement industry to deploy a wide range of technologies and innovation projects at every step of the cement production process. When it comes to the Commission’s IIA on taxonomy-related disclosures by undertakings reporting non-financial information, CEMBUREAU has the following comments: • The deadlines to set up reporting systems that fulfil the requirements of the taxonomy regulation are challenging, and the industry urgently needs guidance as to how to organise this. Many of the criterions set up by the taxonomy regulation are qualitative and will require guidance in their implementation. In view of the ambitious timeframe for implementation of the taxonomy regulation, and the fact that some key Delegated Acts are awaiting publication (e.g. delegated act on EU Taxonomy Climate Mitigation and Adaptation technical criteria foreseen by 31st December 2020), it is nearly impossible to implement an efficient, compliant and externally-verified reporting system in time for the business year 2021. • The qualitative “do no harm criteria” published in the Technical Expert Group report in May 2020, that define activities that are compliant with the taxonomy, are contradictory for the cement industry, preventing the use of alternative fuels (RDF). As per CEMBUREAU’s response to the Commission IAA on the Taxonomy Climate Mitigation and Adaptation technical criteria delegated act, it is essential that this is corrected in the final delegated act, making it otherwise impossible for the cement industry to comply with the taxonomy rules. • The idea of a mandatory disclosure concerning turnover, CapEx and OpEX are sensitive information. This mandatory reporting can lead to competitive distortions, as competitors from non-EU countries are not obliged to disclose this information. • Further clarity on disclosures can only be obtained when it becomes clearer, through delegated acts, which type of activities and products will be covered by the taxonomy. So far, key elements to be reported on are only defined for certain industries or products in the TEG report, for instance grey cement and grey clinker benchmarks. The TEG report does not include a reference and corresponding benchmarks for white cement and white clinker, which is a specialty product produced at a limited number of installations and traded widely across borders in and out of the EU as well as internally in Europe. As explained in CEMBUREAU’s response to the IIA on the Taxonomy Climate Mitigation and Adaptation technical criteria delegated act, the upcoming delegated act should recognise the particularity of white cement by dedicated metrics and thresholds. • The implementation of the Taxonomy Regulation will involve significant costs for businesses and these should be minimised through the providing of timely guidance and the use of simple, efficient reporting systems. For instance, some European cement companies currently publish non-financial information according to GRI Standards and/or are part of initiatives such as CDP, SBTi, ACT. It is important that the Delegated Act seeks to facilitate the implementation of the Taxonomy Regulation and is aligned with the existing accounting norms and initiatives. More generally, the Delegated Act should also be aligned with the EU’s “better regulation” principle and offer a predictable framework for investors. Furthermore, CEMBUREAU makes itself available to the Commission for further input during the development of the delegated act.
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Response to Empowering the consumer for the green transition

1 Sept 2020

The European Cement Association CEMBUREAU welcomes the opportunity to provide feedback on the Commission inception impact assessment on empowering the consumer for the green transition. CEMBUREAU agrees with the consumer law initiative announced in the Green Deal to provide consumers the ability to make sustainable choices based on trustful environmental information and green claims. We endorse the Commission’s view that the consumer is best protected through a harmonised approach at EU level and that individual consumer protection initiatives at national level can affect the internal market. In designing such consumer protection policy, it is important, however, not to proceed to a “one-size-fits-all” approach for all products and materials without due consideration for their place in the supply chain and for the function fulfilled by different types of products. Applied to construction products, for instance, it is important to note that the purchasing process in the construction industry is in general different from that of other goods and occurs more often on a B2B platform. The selection of materials or products is made by a designer (architect or specifier), and the actual purchase is made by a builder or a contractor. As the building material will achieve its functionality in the final product, i.e. the building or construction work, these professionals need data to assess the environmental performance of this final product. For that reason, CEMBUREAU would like to highlight that, in our view, construction products would require a dedicated approach when it comes to empowering consumers for the green transition. We believe that for the construction market’s specialised consumers Environmental Product Declarations (EPDs) are the best source of information for purchase decisions as EPDs use verifiable and accurate information about the life-cycle environmental impact of construction products to encourage the demand for, and supply of products that have a lower negative impact on the environment for the building or construction works. CEMBUREAU has always felt that it is the cement sector’s responsibility to provide interested parties with environmental information about cement. The EU cement sector responds to the increased awareness and the requests of professional users and consumers for environmental information through the development of cement EPDs, especially for B2B communication. For instance, cement EPDs were fundamental for the environmental input to CEMBUREAU’s Level(s) building sustainability assessment framework pilot projects. While we acknowledge that there are information asymmetries in the way low carbon products and materials are brought to the market and that market uptake needs specific attention, we believe that a construction specific approach taking into account the particularities of the supply chain and the place of the product or material in the final construction deserves appropriate attention. *****
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Response to Environmental claims based on environmental footprint methods

28 Aug 2020

CEMBUREAU, the European Cement Association, welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment on a legislative proposal on substantiating green claims. Please find attached a position paper which sets out our views. We hope this can serve as a basis for future exchanges and will be very happy to engage.
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Response to Offshore renewable energy strategy

13 Aug 2020

CEMBUREAU, the European Cement Association, welcomes the opportunity to provide feedback to the Offshore renewable energy strategy Roadmap. In summary, CEMBUREAU considers that increasing offshore renewable energy supply will be one of the key measures to increase the supply of the renewable electricity needed to move towards a climate neutral society by 2050. The strategy focus should not be just on the use of renewable electricity to create hydrogen, but on the increased needs of industry and society as it puts in place technologies to decarbonise through the increased use of electrical energy. As mentioned in the roadmap, the revision of TEN-E will also be key in ensuring that the infrastructure for the increased use of electricity and also for hydrogen and CO2 transport (the new feedstock for the chemical and petrochemical industries) is in place. On 12th May 2020, CEMBUREAU published its new Carbon Neutrality Roadmap setting out its ambition to reach net zero Greenhouse Gas (GHG) emissions along the cement and concrete value chain by 2050, in line with the European Green Deal. Our roadmap identifies the deployment of Carbon Capture, Utilisation and Storage (CCUS) as absolutely central to achieve carbon neutrality in the sector. CCUS will indeed account for 42% of the CO2 emissions reduction in the cement industry by 2050. This alone will result in the electrical demand doubling for our sector. Other technologies to decarbonise which require increased electricity demand include the use of plasma and hydrogen in firing the clinkering process and electrical heating in the calcination process. Concrete plays a major role in the construction of foundations and bodies for wind turbines, providing the necessary resistance against the impacts from wave damage and salt water corrosion. Recent developments using 3 D printing have seen advances in the construction wind turbine bodies. In light of the above, CEMBUREAU believes that the Offshore Renewable Energy Strategy should take into account the increased electrical needs of industry and society to move to a climate neutral society by 2050. This should be done in close coordination with the revision of TEN-E. • The future demand for renewable electrical by industry and society should be fully assessed to determine the level of offshore renewables needed; • From this, the increased electricity infrastructure need should be identified and planned implementation should be put in place; • CCS/CCUS is one of the 12 strategic trans-European energy infrastructure priorities and sufficient renewable energy supply will be needed for this; • The next list of EU Projects of Common Interest (PCI) that will be developed through the TEN-E Regulation should be compliant with the objective of carbon neutrality by 2050 and therefore allow for the scaling up of CO2 and hydrogen transport infrastructure.
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Response to Review of the Construction Products Regulation

12 Aug 2020

The European Cement Association CEMBUREAU welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment on the review of the CPR. CEMBUREAU ranks the revision of the Construction Products Regulation (CPR) high on its priorities, given the importance of this file for our sector. We strongly rely on the harmonised conditions for CE marking for the cross-border trade of cement across the EU thanks to the historic and consistent harmonised standard EN 197-1. CEMBUREAU also shares the view that the revision of the CPR will have links with the European Green Deal, the new Circular Economy Action Plan, and the announced Strategy for a Sustainable Built Environment. The inception impact assessment provides for a good summary of the issues with the CPR the European Commission has identified and aims to tackle in the initiative. The slowness of the overall process has been the key issue for us. After 6 years since the start of the review of EN 197-1, the draft revised standard is still not published in the official journal of the EU. Regrettably, this is delaying the EU cement sector in putting low carbon products on the market and thus to deliver CO2 reductions. Not surprisingly, Member States have recently identified cement as one of the product families to target as a priority by future technical specifications. However, apart from the delay, the CPR system has proved to work for our sector, so CEMBUREAU believes that adjustments and improvements to the system could be achieved by adopting a “soft-law approach” through a limited change to the present CPR. Our sector strongly supports the promotion of re-use and recycling. Nevertheless, we believe that the CPR should be focused on the structural safety of construction products and on the delivery of relevant information to be used along the value chain, but should not cover circular provisions as circularity is way too complex to create common rules across all construction products. Please find attached a position paper which sets out our views with more nuance and detail. We hope this can serve as a basis for future exchanges and will be very happy to engage.
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Response to Update of concentration limit values of persistent organic pollutants in waste

4 Aug 2020

CEMBUREAU POSITION PAPER ON INCEPTION IMPACT ASSESSMENT ON POP LIMIT VALUES IN WASTE Brussels,04/08/2020 The European cement industry is a large user of waste and by-products utilizing approximately 35 million tonnes per year to replace fuels and raw materials. In the EU, the sector substitutes on average 46% of its fossil fuel consumption with secondary materials such as non-recyclable waste or biomass waste. Our industry has high ambitions to increase this number in the coming years, and several cement plants across Europe already run on 90-100% alternative fuel share. In addition to providing sound solutions for the waste streams and strengthening the circular economy, this use of waste fuels and raw materials is also key for the cement industry to reduce its CO2 emissions and support our vision for a carbon neutral Europe for 2050 (https://cembureau.eu/news-views/publications/2050-carbon-neutrality-roadmap/). When waste is introduced into the cement kiln to produce clinker (the intermediate product of cement), its organic component provides heat inside the kiln whereas the mineral, non-combustible elements are recycled and become part of the clinker, thanks to what is called “co-processing”. Co-processing is therefore an absolutely sustainable ecological solution for the treatment of waste, as it uses waste both as a way to provide energy and as secondary raw material. The high temperatures and long residence time of the gases in the cement kiln process, ensure complete destruction of any Persistent Organic Pollutants (POPs) in the waste streams. The use of the waste contaminated with POPs can be done without the need to increase the energy demand required for the process, will also result in lower CO2 emissions (the emission factor of waste is lower than fossil fuels) and a complete recycling of the mineral fraction ensuring no by-products or ash residues are formed which is a significant advantage compared to other types of treatment. The use of waste in cement plants is done in full compliance with the EU air pollution legislation (Directive 2010/75/EC on industrial emissions) ensuring a high level of protection of human health and the environment. Each and every cement plant in the EU operates in accordance with a permit granted by the authorities in the Member States following the principles and provisions of the IED.
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CEMBUREAU urges broader carbon capture and biomass waste recognition

22 Jul 2020
Topic — The consultation updates greenhouse gas monitoring and reporting rules for the EU ETS.
Message — The group requests exemptions from sustainability criteria for fuels derived from biomass waste. They also want carbon stored through mineralisation to be counted as not emitted.123
Why — These changes would significantly reduce the industry's reported carbon emissions and compliance costs.45
Impact — Environmental advocates lose the ability to verify the sustainable origin of industrial fuels.6
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Response to EU rules on transboundary waste shipments – update concerning plastic wastes

20 Jul 2020

The European cement industry is a large user of waste and by-products utilizing approximately 35 million tonnes per year. In the EU, the sector substitutes on average 46% of its fossil fuel consumption with secondary raw materials such as non-recyclable waste or biomass waste. Our industry has high ambitions to increase this number in the coming years, and several cement plants across Europe already run on 90-100% alternative fuel share. In addition to providing sound solutions for the waste streams and strengthening the circular economy, this use of alternative fuels is also key for the cement industry to reduce its CO2 emissions and support our vision for a carbon neutral Europe for 2050 (https://cembureau.eu/news-views/publications/2050-carbon-neutrality-roadmap/). When waste is introduced into the cement kiln to produce clinker (the intermediate product of cement), its organic component provides heat inside the kiln whereas the mineral, non-combustible elements are recycled and become part of the clinker, thanks to what is called “co-processing”. Co-processing is therefore an absolutely sustainable ecological solution for the treatment of waste, as it uses waste both as a way to provide energy and as secondary raw material. That is why, having access to sufficiently available local pre-treated waste is crucial for the operation of cement facilities in all member states. However, import of pre-treated waste becomes necessary when local supply does match quality and quantity requirements. That is why CEMBUREAU support the draft Commission delegated act which maintains the current simplified procedure for shipments of non-hazardous plastic waste between Member States. Thus, CEMBUREAU would like to highlight tree positive consequences of the draft delegated act: 1. It avoids internal barriers in the EU internal market when these waste streams are destined to industrial applications; 2. It does not add administrative burdens neither to Member States and not to companies; 3. It prevents the development of illegal waste transfers. Finally, CEMBUREAU wishes to underline that the use of waste in cement plants is done in full compliance with the EU air pollution legislation (Directive 2010/75/EC on industrial emissions) ensuring a high level of protection of human health and the environment. Each and every cement plant in the EU operates in accordance with a permit granted by the authorities in the Member States following the principles and provisions of the IED.
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Response to EU Strategy on Adaptation to Climate Change

30 Jun 2020

CEMBUREAU welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment of the Communication “European Green Deal Strategy for Adaptation to Climate Change” to be adopted at the end of the year. The cement and concrete sector can offer great contribution to Climate Change adaptation. CEMBUREAU’s commitment to Climate Change Mitigation is strong and our 2050 Climate Neutrality Roadmap (https://cembureau.eu/news-views/publications/2050-carbon-neutrality-roadmap), which was published in May 2020, sets out the cement industry’s ambition to reach net zero emissions along the cement and concrete value chain by 2050. at the roadmap looks at how CO2 emissions can be reduced by acting at each stage of the value chain: clinker, cement, concrete, construction and (re)carbonation. According to CEMBUREAU, the new EU Climate Adaptation Strategy should promote and develop: • Investment in resilient infrastructure and building structures, with increased durability and extended useful life; • Investment in structural defences to combat climate change (ie flood defences); • Innovative adaptation solutions. Indeed, our sector, thanks to qualities of concrete (durability, resilience, thermal mass, fire resistance and low maintenance costs) and additional features such as those of pervious concrete and high reflectance (SRI) concrete, already provides solutions to Climate Change adaptation, making it a strategic material for the EU economy. That is why we support the uptake and development of climate change adaptation policies and practices at all levels (EU, Member States, Local) in order to protect: • Communities (development and renovation of sea defences, dykes, riverbank protection and flood barriers, stormwater run-off management systems, strengthening and repurposing of structures, expanding structure service life); • Health and safety (development and renovation of water storage and/ or treatment systems, improved sanitation, new hospitals); • Public and private assets (climate adaptation proofing of buildings and infrastructures). In addition, the resilience of urban areas should be promoted by: • Densifying cities and avoiding urban sprawl; • Developing shared and mass transport infrastructures; • Managing urban heat island effects through SRI requirements for both vertical and horizontal hardscape areas; • Promote urban drainage and infiltration; and • Decreasing heating and cooling demand notably through the use of thermal mass in construction and building renovation. Ensuring the resilience of the built environment and infrastructure to more frequent extreme events should be a key pillar of adaptation to climate change as it has the potential of protecting people’s health and access to basic resources in some regions, as well as minimizing the overall economic and financial impact in the EU.
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Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

16 Jun 2020 · CBAM

Response to A EU hydrogen strategy

8 Jun 2020

"CEMBUREAU welcomes the opportunity to provide comments on the hydrogen roadmap. CEMBUREAU has published its own carbon neutrality roadmap, which looks at achieving net zero emissions down the cement and concrete value chain. Amongst other issues, the roadmap looks at which technologies – such as hydrogen or carbon capture and storage – will play a role to achieve this objective. CEMBUREAU acknowledges that hydrogen will play an important role together with carbon capture use and storage in the move towards a climate neutral society by 2050. It is therefore important that in the hydrogen roadmap we consider the future needs of both industry and society in planning this strategy. Hydrogen will be needed in the cement industry as a partial replacement of fossil fuels but will also be needed in the conversion of captured CO2 to other products such as a feedstock for the chemical industry and refinery products. Several pilots projects are planned in this respect, such as the Tarmac/Hanson Cement project to use hydrogen as fuel in the UK and the LafargeHolcim Westkuste 100 project in Germany, where the CO2 captured in the cement plant will be processed with hydrogen to produce methanol. Access to infrastructure will become a key lever for avoiding process related CO2 emissions in European Industry. This requires a strategy for early and integrated development of both the hydrogen and CO2 infrastructure. It is important that both hydrogen and CO2 are considered when determining the future use of existing natural gas pipelines to ensure that both hydrogen and CO2 can be transported to their intended end use. For cement together with some other energy intensive industries such as lime, pulp and paper etc, the operations are widely distributed throughout Europe linked to the source of their raw materials. These operations are key employers and create the need for many local support industries, therefore finding a solution for both hydrogen and CO2 infrastructure will be crucial to stimulate and increase the potential for the development of industrial symbiosis. Significant research is needed in the use of hydrogen both as a fuel but also in the conversion of CO2 to other products and this will need to be funded. It is good to see in the EU Recovery Plan and in research funding mechanisms such as Horizon Europe and the Innovation Fund, that there is a strong focus on research and innovation in these areas. Going forward there will be the need for significant public and private funding towards pipeline transport infrastructure for both hydrogen and CO2."
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Response to Commission Communication – "Renovation wave" initiative for the building sector

5 Jun 2020

CEMBUREAU, the European cement industry association, welcomes the consultation on the Renovation Wave initiative for public and private buildings. CEMBUREAU has published its own carbon neutrality roadmap, which looks at achieving net zero emissions down the cement and concrete value chain. Amongst other issues, the roadmap looks at how carbon emissions savings can be made through a better use of concrete, and highlights the decisive role it can play as a sustainable construction material. The renovation wave is a major opportunity for the EU to decarbonise its building stock and help reaching carbon neutrality by 2050, whilst bringing concrete benefits to EU citizens. The European cement and concrete industry will contribute to this objective with solutions to renovation projects, as well to alternatives when renovation is not the most sustainable option to existing buildings. CEMBUREAU would like to highlight three areas that deserve attention when considering the Renovation Wave Initiative. Please see the attached document that support our ideas.
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Meeting with Pascal Canfin (Member of the European Parliament)

27 May 2020 · Green Deal/Green recovery/CBAM

Meeting with Linsey Mccallum (Cabinet of Executive Vice-President Margrethe Vestager)

15 May 2020 · ETS and EEAG guidelines concerning Cement; digitalization of the construction sector

Meeting with Frans Timmermans (Executive Vice-President)

12 May 2020 · Recovery, climate neutrality, carbon border adjustment

Response to EU rules on industrial emissions - revision

20 Apr 2020

Please find attached the feedback by CEMBUREAU, the European Cement Association.
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Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

CEMBUREAU, the European Cement Association (www.cembureau.eu), welcomes the opportunity to provide feedback on the roadmap on EU Taxonomy Climate Mitigation and Adaptation delegated act. CEMBUREAU firmly supports the objectives of the European Green Deal and is determined to contribute strongly to the EU’s vision for a carbon neutral society by 2050. CEMBUREAU is currently revising its low-carbon roadmap setting out the key role of cement and concrete in the circular economy and a path to achieving carbon neutrality along its value chain in Europe by 2050 (please see our press release: https://cembureau.eu/media/1907/cembureau-press-release-carbon-neutrality-allong-the-value-chain-by-2050.pdf). Public and private investments will be key to allow the European cement industry to deploy a wide range of technologies and innovation projects at every step of the cement production process and uses of cement, from the development of alternative fuels, many of them biomass, to replace fossil fuels in heating processes, improved energy efficiency of kilns, low-clinker cements, innovative binders and concrete solutions, enhancement of permanent carbon capture in concrete, up to the development of carbon capture and storage/use technologies where the industry is leading the way through several pilot programmes in Europe. For this reason, CEMBUREAU welcomes the agreement reached between the European Parliament and the Council on the Regulation, as well as the Technical Expert Group (TEG) final report on EU Taxonomy. We would however like to express three significant and important concerns on the TEG final report that should not be carried in the upcoming delegated act. 1. While the final report lists cement as a sustainable activity eligible for green funding, it considers Refuse Derived Fuels (RDF) for cement production as an activity harming the pollution prevention and control objective in the Do Not Significant Harm (DNSH) criteria for our sector (pages 171 and 431 of the final report Annexes). The delegated act should not include that exclusion. Such requirement would, in practice, prevent virtually all European cement plants from meeting the taxonomy criteria thus jeopardising the overall decarbonisation efforts and environmental improvement of the cement sector and being highly detrimental to achieving the Taxonomy’s objectives. 2. Furthermore, it is crucial that the upcoming delegated act recognises the particularity of white cement, whether by dedicated metrics and thresholds or by noting that the grey clinker metrics and thresholds do not apply to white cement installations, to allow white cement producers access to green funding. 3. On construction activities, CEMBUREAU wants the Platform in its future activities to ensure a material neutral approach, without promoting any material solution. A more detailed position can be found in the paper enclosed. CEMBUREAU stands ready to engage with policy-makers throughout the implementation of the EU Taxonomy Regulation.
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Meeting with Thierry Breton (Commissioner) and

20 Apr 2020 · COVID 19 economic impact on Energy intensive industries

Response to 2030 Climate Target Plan

15 Apr 2020

CEMBUREAU, the European Cement Association, welcomes the opportunity to comment on the draft 2030 Climate Target Plan. CEMBUREAU's full contribution is available in the attached document. A shorter version is displayed below. CEMBUREAU, the European Cement Association, is determined to contribute strongly to the EU’s vision for a carbon neutral society by 2050 and supports the objectives of the European Green Deal. The association is already advanced in the process of updating its low-carbon roadmap into a Carbon Neutrality Roadmap, with a view to reaching carbon neutrality down the cement and concrete value chain by 2050. The cement industry has reduced its emissions by 15% since 1990 and the new Roadmap will include an aspirational objective for CO2 emissions reduction at a 2030 horizon. When it comes to the Commission’s inception impact assessment, CEMBUREAU has the following comments: • Regardless of the level of ambition for 2030, it is absolutely essential that a thorough impact assessment is conducted by the European Commission to determine the different policy options to reach these targets and their consequences. • When it comes to effort sharing, it will be particularly important to strike the right balance between ETS sectors on the one hand, where emissions have significantly reduced (and which already carry the biggest share of the effort for the current 2030 target), and non-ETS sectors on the other hand, which in many cases have seen a stagnation or increase of their emissions. • Investments in low-carbon technologies require regulatory certainty from now until 2030 and beyond. Higher EU climate change targets need to be achieved with proper respect for the current legal framework against which companies are currently making their investment decisions, and should take due consideration of the investment cycles in the industry. • The objective of deeper CO2 cuts at a 2030 horizon – and of carbon neutrality by 2050 – necessitates considerable investments, and will not be met without appropriate political support. CEMBUREAU’s Carbon Neutrality Roadmap will make several recommendations in terms of regulatory frameworks and concrete support measures. Furthermore, the Masterplan for a Competitive Transformation of EU Energy-intensive Industries Enabling a Climate-neutral, Circular Economy by 2050 also contains key recommendations in this respect. Decarbonisation policies based on life-cycle analysis and full value chain approaches, as outlined in the European Green Deal, will be key. Investments in emission reduction technologies will also require a business case and a level-playing field. • As recognised in the inception impact assessment, a higher ambition on 2030 carbon emissions’ reduction will imply higher risks of carbon leakage. It is absolutely critical that carbon leakage measures are commensurate to the EU’s climate ambitions. Creating a level-playing field on carbon will be indispensable, and supplementary measures like carbon border adjustment mechanisms will play a key role, as explained in CEMBUREAU’s position paper on this issue (https://cembureau.eu/media/1922/17542-cembureau-position-paper-carbon-border-mechanisms-2020-02-11-025.pdf). • We also note that the inception impact assessment suggests that the Commission will assess the impact of an ETS revision on carbon leakage “looking at historical empirical evidence and what the techno-economic potential is to achieve further GHG reductions in industrial sectors”. CEMBUREAU does not believe that such historical evidence is sufficient in itself: a higher carbon ambition will for instance imply higher carbon prices than those observed historically. CEMBUREAU stands ready to engage with policy-makers throughout the 2030 climate target revision process. We also support the joint submission from the Alliance of Energy-Intensive Industries which is available here: https://cefic.org/app/uploads/2020/04/Joint-Alliance-submission15-04-20.pdf
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Response to Carbon Border Adjustment Mechanism

31 Mar 2020

CEMBUREAU, the European Cement Association (www.cembureau.eu), welcomes the idea of a carbon border mechanism as a key opportunity to enable the industry to help deliver the EU’s carbon neutrality objectives, and drive deeper CO2 emissions’ cut in the EU and beyond: • The European cement industry already faces a strong risk of carbon leakage despite the partial free allocation provided under the EU Emission Trading Scheme (ETS). This risk is increasing at a very fast pace, as third countries which are not subject to the same CO2 constraints build up their export capacity to the EU. • A carbon border mechanism could create the level playing field the industry needs to deliver low-carbon investments and move towards carbon neutrality along the value chain. It could also incentivise third countries to step up their efforts on climate change, and ensure that the EU does not “outsource” its CO2 emissions through the import of more CO2-intensive products. • However, carbon border mechanisms are by nature complex tools and it is essential to get their design right. A poorly-designed mechanism could indeed have dramatic consequences for the industry. • In particular, it is imperative that any carbon border mechanism co-exists with free allocation under the EU ETS, at least until the end of Phase IV. The replacement of the existing carbon leakage measures by an untested mechanism would create considerable uncertainty and risks for investments in the EU, at a time the industry needs a predictable framework to deliver low-carbon investments. • The core objective of a carbon border mechanism should be that producers outside the EU compete on the same CO2 cost basis as EU domestic producers. With this in mind, CEMBUREAU suggests some design principles which are fair and transparent for both EU and non-EU producers, will have a positive impact on climate worldwide, and will avoid carbon leakage and imported CO2 emissions. These 5 design principles are as follows: 1. In an initial phase, an EU carbon border mechanism must be complementary to the EU ETS free allowances 2. A carbon border mechanism must be based on verified emissions from importers to the EU. It should include indirect emissions. 3. A carbon border mechanism must follow a very transparent methodology and be fully WTO-compatible 4. An EU carbon border mechanism must be applicable to all ETS sectors alike 5. A carbon border mechanism should provide for an CO2 charge exemption for EU exporters CEMBUREAU stands ready to work closely with decision-makers and stakeholders on an appropriate design for carbon border mechanisms. The full version of the CEMBUREAU position paper is available at the following link: https://cembureau.eu/media/1922/17542-cembureau-position-paper-carbon-border-mechanisms-2020-02-11-025.pdf A copy is also attached.
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

5 Mar 2020 · To address the Green Deal and its relevance for the cement industry. The overall discussion focused on the ambition of the industry to become carbon neutral along the cement and concrete value chain by 2050.

Meeting with Dara Murphy (Cabinet of Commissioner Mariya Gabriel)

7 Feb 2020 · how cement can be a part of a sustainable and innovative EU

Response to Climate Law

6 Feb 2020

CEMBUREAU’S RESPONSE TO THE ROADMAP ON THE “EUROPEAN CLIMATE LAW – ACHIEVING CLIMATE NEUTRALITY BY 2050” CEMBUREAU, the European Cement Association, is determined to contribute strongly to the EU’s vision for a carbon neutral society by 2050 and supports the objectives of the European Green Deal. The European cement industry is currently reviewing its 2050 low-carbon roadmap, with the intention to strive for carbon neutrality along the cement and concrete value chain by 2050 (please see our press release). In terms of the upcoming European Climate Law, we offer the following comments: • The draft law should be simple in scope, and be technology neutral. It should not enter into specific sector consideration, but rather set the objective of 2050 carbon neutrality for the European society as a whole. The development of individual decarbonisation policies, including the review of intermediary climate change targets (e.g. 2030 targets) which is to be consulted on later this year, should only come in a second stage. • The climate law should foster decarbonisation policies based on life-cycle analysis and full value chain approaches, as outlined in the European Green Deal. As recycling and circular economy become critical parts of industrial decarbonisation, having a “full value chain approach” is critical to reach carbon neutrality. • The objective of carbon neutrality necessitates considerable investments, and will not be met without appropriate political support and an ambitious industrial policy. In this respect, the Masterplan for a Competitive Transformation of EU Energy-intensive Industries Enabling a Climate-neutral, Circular Economy by 2050 contains clear recommendations on how energy-intensive industries can contribute constructively to the development of policies enabling the transition to a climate-neutral economy by 2050. • Regarding policies which will be developed in the coming years to reach the EU 2050 carbon neutrality objective (e.g. review of 2030 targets), it is critical that these are subject to comprehensive impact assessments. These should include the impact on carbon leakage and the development of policy tools to prevent this. • The climate law should recognise the role played by negative emissions to reach carbon neutrality. For instance concrete – which is cement’s main product – absorbs CO2 over its lifetime, turning European cities into carbon sinks.
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Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

5 Feb 2020 · European cement industry in transition, role of cement in economy. Decarbonization possibilities in cement industry, CCS and CCU Technologies. Circular economy in cement industry.

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

30 Jan 2020 · BCG report on carbon leakage risks,

Response to EU 2030 Biodiversity Strategy

20 Jan 2020

CEMBUREAU, the European Cement Association, welcomes the European Commission’s initiative for the Biodiversity Strategy to 2030 and the intention of the European Union to lead the world at the 2020 Conference of the Parties to the Convention on Biological Diversity in China. A key priority for the European cement industry is to protect and preserve the ecosystems living in and around our quarries. Whilst these sites are the source of our products, nature conservation is at the heart of our activities. Furthermore, new habitats created during the rehabilitation process ensures animal and plant life, including rare and threatened species, can further prosper and flourish, thus contributing to the United Nations Sustainable Development Goal 15 “Life on lands”. The cement industry’s ambition is to contribute halting biodiversity loss through the lifecycle of a quarry. This can be achieved through projects related to habitat management and restoration, which enhance the conservation value of quarried areas. In turn, this provides an educational resource for academic institutions, non-governmental organisations and the general public. CEMBUREAU fully supports the commitment of the European Commission to address the main causes of biodiversity loss in the EU and endorses the in-depth analysis of the EU protected areas on the need for improvements taking always into account that meeting the provisions of the legislation could go together with meeting the demand for raw materials and the sustainable development of an extractive sector such as the cement industry. Moreover, CEMBUREAU would endorse policies which stress the important role of education to raise awareness on biodiversity, an area where our sectors’ quarries would be a central point since they regularly provide a vivid example of fruitful collaboration between universities and companies aiming at the preservation and enhancement of biodiversity in the sites. CEMBUREAU remains available for continuing working with other stakeholders and we are ready to be a key partner for the European Union in delivering its Green Deal and Biodiversity Strategy for 2030.
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Response to A new Circular Economy Action Plan

20 Jan 2020

CEMBUREAU welcomes the New Circular Economy Action Plan (AP) and the ambitious vision of the European Green Deal. The European cement sector substitutes today an average 46% of its fossil fuel needs for cement manufacturing with alternative sources (e.g. non-recyclable waste or biomass) and has ambitions to reduce the use of fossil fuel further. CEMBUREAU supports the review of EU waste policy to ensure greater circularity throughout EU economy: • Landfilling should be either banned across the EU or highly taxed at Member States; • An EU model for separate waste collection could simplify waste management, improve efficiency of resource flows and ensure better access to secondary materials for business; • Export of waste outside the EU should stop. A review of the Waste Shipment Regulation should simplify waste movements within the EU and avoid unnecessary bureaucratic delays; • When waste is used in the cement kiln to produce clinker (the intermediate product of cement) its organic component provides heat inside the kiln and the non-combustible elements become part of the clinker, thanks to what is called “co-processing”. The potential of co-processing should be enhanced further through legislative & regulatory measures that recognise this form of material recycling and its contribution towards EU recycling targets. The AP should boost circularity of construction materials, thus contributing towards a carbon-neutral built environment by ensuring appropriate use of resources to fulfil society’s needs in the most efficient manner with the least environmental impact: • Cement is mainly used to produce concrete. Thanks to its thermal mass, concrete lowers the need for heating & cooling of buildings – reducing both energy needs and peak power demand; • Concrete also absorbs CO2 from the atmosphere through a process called recarbonation, resulting in it being permanently bound; • Concrete is 100% recyclable as aggregates. Concrete structures can be repurposed. Concrete elements in buildings can be reused in new buildings; • Selective demolition from construction and renovation sites could improve quality and availability of recycled aggregates from Construction & Demolition Waste. However, it should be pointed out that recycled content does not always lead to the best outcome from an LCA perspective (ECRA study). • Also a mandatory recycled content would not work for concrete as the supply does not match the demand. If all concrete C&D waste in Europe were recycled, this could supply 10% of total demand for aggregates for all applications. It would also not be always technically & environmentally effective. Recycled aggregates are limited in reinforced concrete standards for performance reasons, whereas for non-structural concrete products a minimum recycled content could probably be more acceptable. CEMBUREAU recommends a performance-based policy for the use of recycled material from C&DW instead. • The AP should include a policy goal of ‘design for disassembly’ to maximise reusability of construction elements in new projects. Focus should be on maintenance, repair and reuse of structures; • CEMBUREAU agrees with the vision along the lifecycle of products. To determine the full environmental impacts of construction products, these must be considered as part of a whole system, i.e. the building itself. The features of concrete described above can only be taken up entirely at the level of the construction work and over the whole life-cycle, as opposed to product level; • CEMBUREAU advocates the use of CEN/TC350 standards which provide appropriate rules for LCA of buildings, through Environmental Product Declarations (both cement & concrete provide reliable sustainability features in EPDs); • Any new initiative on construction, e.g. Level(s) framework, should be based on LCA; • CEMBUREAU welcomes an open platform bringing together the buildings & construction sector, architects, engineers and local authorities.
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European cement industry urges linear approach for carbon allocations.

9 Jul 2019
Topic — Update of EU rules for determining free carbon emission allocations to industrial installations.
Message — CEMBUREAU advocates for a linear approach to reflect actual activity levels and avoid competition distortions. They request reduced reporting requirements and equal treatment for capacity increases and new entrants.123
Why — This ensures they receive full financial value for production changes and reduces administrative costs.45
Impact — Market integrity suffers when arbitrary thresholds cause competition distortions and unfair over-allocation of credits.67
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Meeting with Dominique Ristori (Director-General Energy)

4 Jun 2019 · Les défis et les opportunités ouverts par la transition énergétique pour les industries du ciment

Response to Revision of the ETS State aid Guidelines

16 Jan 2019

The cement industry is not eligible for indirect compensation under the current Indirect Compensation State Aid Guidelines, despite the fact that the sector fullfils all conditions based on the currently available data. The cement industry was informed that, for the current trading period, the list is closed and sectors would not be added. With this note, the European Cement Association, CEMBUREAU declares its interest to be considered as a stakeholder in the upcoming revision process and wishes to be consulted on the data and methodology that the Commission will use in carrying out its impact assessment. The cement industry is confident that it qualifies for indirect compensation for the next trading period (Phase IV) and is ready to provide the Commission with the necessary data. In the attached note, CEMBUREAU sets out its reasoning in more detail, highlighting that decarbonisation of the industry will mean a shift from direct to indirect costs which makes the exposure to carbon leakage strong for both types of cost. Main points in CEMBUREAU's position: - As the risk of carbon leakage affects both direct and indirect costs in an equally relevant manner, CEMBUREAU strongly endorses one of the options suggested by the European Commission in its Roadmap which suggests to “align eligibility for compensation of indirect costs with the eligibility for free allowances, which is determined by the so-called Carbon Leakage list established by the European Commission as a delegated act.” - CEMBUREAU also insists that any consultation on options should be accompanied by a detailed impact assessment that shows how the different options suggested and the level of compensation will fully protect energy-intensive sectors from carbon leakage to outside the European Union. - Finally, the revision of the Guidelines should also consider the disaggregation at PRODCOM levels to ensure that the EU ETS regulated activities are appropriately captured by the assessment.
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Response to Commission Delegated Regulation establishing the Innovation Fund

11 Jan 2019

Please refer to CEMBUREAU comments in the attached document.
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Response to Evaluation of the Industrial Emissions Directive

4 Dec 2018

CEMBUREAU, the European Cement Association, took note of the initiative by the European Commission to evaluate how the Industrial Emissions Directive (IED) is working. This Directive specifies how to control emissions from industrial sources other than CO2, through the application of Best Available Techniques (BAT) which are defined in BAT Reference Documents (BREFs). Cement plants operate in accordance with a permit granted by the authorities in the Member States following the principles and provisions of the IED. The reference for setting the permit conditions is the BREF and its BAT conclusions, which describe, in particular, applied techniques, present emissions and consumption levels. CEMBUREAU believes that the IED and the BREFs are delivering environmental performance across Europe because their approach is flexible, focuses on continuous improvements and addresses local environmental issues holistically. As cement sector we have some concerns regarding the timing of the evaluation of the Industrial Emissions Directive. Given the long-term process of establishing and implementing the BREF documents and the BAT conclusions across the different Member States, we believe that more time is needed to test and gather experience about the application of the IED before starting an efficient evaluation of the environmental impact. CEMBUREAU remains available for further discussion on this position.
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Cement industry urges fairer calculations for free carbon allowances

23 Nov 2018
Topic — The consultation addresses rules for the free allocation of carbon emission allowances.
Message — CEMBUREAU requests using median values instead of arithmetic means for historical activity levels. They argue technical capacity increases should be treated as new entrants to prevent delays.12
Why — The industry would avoid losing significant carbon credits during the long wait for adjustments.3
Impact — Public budgets lose revenue because the proposal reduces the volume of permits auctioned.4
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Meeting with Elżbieta Bieńkowska (Commissioner) and

4 Sept 2018 · Alliance of Energy Intensive Industries - 2050 strategy

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and European Chemical Industry Council and

31 Aug 2018 · Energy Strategy

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

3 Jul 2018 · EU 2050 strategy

CEMBUREAU urges simpler and more dynamic ETS free allocation rules

17 Apr 2018
Topic — Revision of rules for determining free emission permit allocations for industrial installations.
Message — The association calls for merging activity level and emissions reporting to reduce administrative burdens. They advocate for dynamic allocation adjustments without time lags to accurately reflect production changes. CEMBUREAU stresses that rules must be finalized quickly to ensure market predictability.123
Why — This approach would lower operational costs while ensuring quicker access to carbon allowances.45
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Response to Carbon Leakage List 2021 - 2030

10 Nov 2017

CEMBUREAU has read with attention the European Commission inception impact assessment for the Carbon Leakage List 2021-2030. CEMBUREAU calls for a regulatory environment which provides legal certainty and stability for long-term investments, innovation, growth and jobs. Within a competitive environment, the cement industry can bring a unique contribution to increased energy- and resource efficiency through constant improvement of its manufacturing processes and increased use of alternative fuels and raw materials. The durability, resilience and strength of its downstream product, concrete, allows the sector to respond to society's challenges by providing energy-efficient, affordable housing and infrastructure for a growing population. Since 2005, the EU28 cement industry has continuously reduced its CO2 emissions per tonne product. In addition, the cement industry has replaced part of its traditional fuel sources with biomass and waste, with alternative fuels accounting for 41% of its fuel requirements. The cement sector is a capital-intensive industry with long-term investment cycles. As a result, it needs a predictable legal framework in order to ensure continued investment and job creation in Europe, as well as a high environmental performance. Carbon leakage is a broader concept than production relocation as it also relates to decisions for new investments or capacity increases that are taking place outside Europe (investment leakage). The risks identified for the current phase risk to be amplified in Phase IV as the possible reduction in free allowances triggered by the cross-sectoral correction factor will virtually bring allocation to the cement industry well below what can be achieved by the best performers in terms of the benchmark. Also our carbon leakage exposure has increased over the last years because of a drop in GVA. We also suggest that there is harmonisation between the tests for carbon leakage exposure resulting from direct and indirect carbon costs because any potential competitiveness impact is a function of the cumulative effect of both the direct CO2 costs and the indirect CO2 costs. The proposed Phase IV design for the evaluation of sectors at risk of carbon leakage from direct costs uses a ‘carbon leakage factor’ which contains emissions intensity (direct and indirect) and trade intensity, in preference to the cost calculation used in Phase III. Sectors eligible for compensation for indirect costs should be determined using the carbon leakage factor in a fair and predictable way which should avoid any unnecessary or unfair differentiation between EU sectors As a key player in the EU ETS and as a sector highly exposed to carbon leakage, CEMBUREAU wishes to be involved and participate in the stakeholders debate. We are also prepared to provide the European Commission with substantiating data and evidence.
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Response to Commission Delegated Regulation establishing the Innovation Fund

14 Jul 2017

We wish to highlight the ECRA (https://ecra-online.org/about/) project for an Industrial-scale oxyfuel kiln as that project particularly fits the purpose of the Innovation Fund and should be considered with the highest priority. ECRA has been working on carbon capture research since 2007. Today ECRA is in the position to build an industrial-scale oxyfuel kiln and wants to initiate a project in order to demonstrate and test this kiln for carbon capture in the cement industry. Different phases of ECRA’s CCS project have been successfully completed and certain parts of it have been investigated within HORIZON2020 (“Cemcap”). The project has now advanced to the stage where definitive steps towards establishing an oxy-fuel kiln can be taken. Such kilns are intended to provide insight into the industrial-scale operation of a technology which provides a high CO2 concentration exhaust gas stream for carbon capture. It is also planned to process a small part of the CO2 to test its further utilisation. An important outcome of the ECRA project is, that the oxyfuel technology not only can be implemented at new installations but also as a modification to existing plants. Based on opportunity studies and in-depth technical feasibility studies, the investment and operation costs for the test phase will amount to around 80 M EUR. However, the high costs of the project cannot be covered by ECRA or its members alone. The cement industry has commit-ted itself to contributing 25 M EUR. To cover the remaining part of the project’s budget of around 55 M EUR, ECRA is now seeking substantial funding from European institutions and national governments. Over the past months ECRA has examined the suitability of sites which could potentially be locations for oxyfuel kilns. From the five sites which were examined in depth, two were identified as the most suitable to host the project from a technical standpoint: the Colleferro plant of HeidelbergCement in Italy and the Retznei plant of LafargeHolcim in Austria. Both companies are committed to hosting their part of the project and to dedicating their respective resources to it. The Colleferro plant has a kiln in a standby position and operates it with petcoke only as fuel. The Retznei plant operates with up to 100% alternative fuels. However, since the project should definitely be carried out under the “easiest“ conditions (Colleferro), but at the same time also under conditions which are as representative for the cement industry as possible (Retznei), the project will be comprised of two phases, namely a first phase at the Colleferro plant and a second phase at the Retznei plant. At the end of the project this would enable the cement industry to demonstrate that oxyfuel operation is possible under different local and plant-specific conditions. ThyssenKrupp Industrial Solutions has completed opportunity studies for both sites. The studies underline the technical feasibility of the project but also the challenges which it will face. The capital expenditure which has been calculated is at this time still subject to an uncertainty of +/- 20%, which implies a corresponding uncertainty in the overall budget of 80 M Euro. It is clear that the project is aimed at the capture of CO2 for subsequent sequestration or utilisation. However, the project has limited itself at this time to the oxyfuel kiln, which is clearly the necessary prerequisite for any kind of further CO2 handling. Nevertheless, ECRA is now in the process of identifying how a certain fraction of the CO2 gas flow can be used for further processing. Preferably this will be done in cooperation with partners who are experts in their respective fields. The timeline of the project depends on how and when external funding can be made available. The project will require two years for each phase. The start of the project could already be in 2017. The final results are expected to be reported four years later.
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Meeting with Jos Delbeke (Director-General Climate Action)

21 Dec 2016 · ETS revision, carbon leakage classification

Meeting with Denis Cajo (Cabinet of Vice-President Neven Mimica), Maria-Myrto Kanellopoulou (Cabinet of Vice-President Neven Mimica)

14 Sept 2015 · Meeting requested to present Energy Intensive Industries Alliance position on ETS post 2020 and COP21

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

14 Jul 2015 · European Minerals Days

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

22 Jun 2015 · The position of the European Cement industry vis-à-vis European decarbonisation policy; challenges to the sector.

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology) and American Chamber of Commerce to the European Union and

3 Jun 2015 · New College and Better Regulation

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

2 Jun 2015 · Circular Economy

Meeting with Emma Udwin (Cabinet of Vice-President Johannes Hahn)

1 Jun 2015 · ETS post 2020

Meeting with Maria Da Graca Carvalho (Cabinet of Commissioner Carlos Moedas)

28 Apr 2015 · Meeting with Mr Koppenholle

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu)

30 Mar 2015 · Presentation of the cement industry, the Concrete Initiative and links with Cohesion Policy

Meeting with Inge Bernaerts (Cabinet of Commissioner Marianne Thyssen)

19 Mar 2015 · Employment and labour law issues

Meeting with Miguel Arias Cañete (Commissioner) and

19 Feb 2015 · Competitiviness, Energy Union and ETS review