Cem'In'Eu

Cem’In’Eu est une start-up industrielle qui développe un tout nouveau concept de production et de commercialisation de ciment en Europe.

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ID: 506912037725-23

Lobbying Activity

Response to Carbon Border Adjustment Mechanism

27 Sept 2021

Cem’In’EU welcomes the opportunity given by the European Commission to comment its proposal regarding the creation of a CBAM. Cem’In’Eu supports the long-term objective of climate neutrality in the EU and its Member States by 2050. The EU’s 2030 climate target should be in line with the objectives of the Paris agreement. In this perspective, we welcome the development of an effective carbon border adjustment as a tool for the transition to carbon neutrality. As a part of the cement sector, we are convinced that the CBAM expected in June must foster innovation in the cement industry, as cement is responsible for 5% of global CO2 emissions. We believe that the proposal has been successfully designed to meet its dual target: (i) incentivise investments in low-carbon technologies in and outside of the EU; and (ii) reduce the risk of carbon leakage in Europe, while respecting a fair competition between the market players. Incentivise investments in low-carbon technologies We are strongly convinced that, to incentivise investment in low-carbon technologies, an ambitious sectors coverage from “simple” goods such as cement to more complex ones such as semi-manufactured goods (aluminium or steel-based) is needed. Moreover, the proposed mirrored system to the EU ETS (certificates price will be based on the average trading price of EU ETS allowances) allow not to jeopardize a stable system. With a current price of 60€/t, the carbon market is working and sends a strong decarbonisation signal. In its proposed scheme, the CBAM allows operators to record verified emissions intensity data in database, usable by importers. The proposed CBAM is put forward as an alternative to free allocation of EU ETS allowances in the covered sectors and would therefore replace free allocation over time. Maintaining free allocation, at any level, while introducing CBAM would mean protecting industries twice against a risk which has never materialised, and which is unlikely to materialise in the foreseeable future. It would discriminate against foreign and sustainable imports while continuing to hand out massive subsidies to large European polluters. The CBAM would prevent innovation if it acts like a protectionist duty and would be consider as subsidies under WTO rules. Implement the CBAM as an alternative to the current carbon leakage protection measures, such as free allowances, is the only way to bring drastic changes, by incentivizing cement producers to reduce in a sustainable way the clinker ratio in the cement production or invest into kiln modernization. However, we believe that the 10-year transition period before free allocation is fully phased-out is too long. We are convinced that a quicker transition period is possible and needed due to the emergency to cut CO2 emissions from heavy polluters. The free allowances should disappear in a 5 years period (-20% per year between 2016 and 2030). It’s time for ambitious decisions! Ensure a fair competition The proposed CBAM is also well designed to ensure the respect of a fair competition as it will only apply to the proportion of emissions that do not benefit from free allowances under the EU ETS. Moreover, the transitional phase proposed by the European Commission is highly welcomed to collect information and anticipate the cost variation for the producers and the importers. Finally, we strongly support the proposal of the European Commission as an efficient game changer for large emitters to take responsibility and commit to sustainability. You will find, attached to this contribution, a Facts and Figures document focusing on cement sector explaining our views about the right design of a truly efficient CBAM. Cem’in’EU stays at the disposal of policy makers to share its expertise about cement sector as fruits for thoughts to contribute for a well design regulatory framework for a more sustainable future.

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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

Cem’In’Eu supports the long-term objective of climate neutrality in the EU and its Member States by 2050. We welcome the opportunity to provide feedback on the Carbon Border Adjustment Mechanism and thus participate in the building of a successful measure to foster innovation in the cement industry. Indeed, this structural measure must be built on the right design to be a cornerstone of the European Green Deal. In our view, the carbon adjustment mechanism should: - Be designed to be compatible with the EU ETS - Include provision to secure free allowances to new entrants, even importers, based on the similar benchmark used for the ETS, to support the most modern actors which made investments to reduce their carbon footprint - Be compliant with WTO rules and thus ensure a level playing field among importers and EU industries - Be a tool to promote innovative low-carbon investments. But this mechanism should not be designed as a way to protect European polluting industries which already benefit from the wrongly calculated free allowances linked with the inefficiency of the EU ETS III. Industrial start-up, Cem’In’Eu developed a completely new concept for the production and sale of cement in Europe. Our approach to the market is based on the principle of « small is beautiful» with small, compact and standardised production units located as close as possible to regional economic areas. We developed a completely new and fully optimised business model allowing for the reduction of the environmental impact of each activity along the entire value chain. Our activity is audited by the "Carbone 4" which calculated the carbon footprint of our company and of our products. In one year, we decrease our carbon footprint by 25% thanks to the optimisation of all levers (Clinker selection, logistics, cement recipes and packaging). Based on our experience, we are convinced that the new carbon border adjustment mechanism would be a powerful tool to thrive for greener products. Regarding the type of policy instrument, Cem’In’Eu supports the extension of the EU ETS to imports. But we are convinced that a new carbon customs duty or tax on imports will not provide the right signal to the industry. This is a matter of efficiency, as such a design will not incentivize old European cement industries to invest in low carbon solutions. Cem’In’Eu supports the carbon border adjustment mechanism but calls the European Commission to define the right design in order to ensure that it will not be a protectionist barrier that will benefit to less innovative or more polluting factories. Regarding the methodological approach to evaluating the carbon content and carbon pricing of the imported products, Cem’In’Eu urges the Commission to adopt a comprehensive view that encompasses all aspects of the value chain and not just the final product. The methodological choices will be key to foster investments for the most efficient industries. To be efficient and fair, the tax must apply the same CO2 benchmark per ton of clincker as that in force for ETS 4. Moreover, new entrants, including importers should benefit from free ETS quotas, for a fair measure. Cem’In’Eu is convinced that the carbon border adjustment mechanism in the EU is the right tool to foster innovation in the cement industry. It could create a momentum for a behavioural change that was missing in the cement industry for years.

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