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Concrete Europe

Concrete Europe

The Concrete Europe ASBL, is a European association incorporated as a non-profit association under Belgian law.

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

Concrete Europe does not support the inclusion of the activity "Use of Concrete in Civil Engineering" in Annex II of the Climate Change Delegated Act, as proposed by the Platform on Sustainable Finance (PSF) recommendation. Our position is that the focus should remain on implementing the existing Environment Delegated Act, which already includes the "Use of Concrete in Civil Engineering" activity, recognising it as contributing to the Circular Economy. The current Act sets challenging technical screening criteria for secondary raw materials, aligning with national regulations for many concrete applications. Including this activity in the proposed Annex would lead to unnecessary administrative burdens for all stakeholders involved. If the Commission supports this inclusion, Concrete Europe believes the Do Not Significant Harm (DNSH) Criteria for Circular Economy regarding secondary raw materials should be lowered to 5% for the following reasons: 1. Availability and cost of secondary aggregates: Secondary aggregates (derived from recycled concrete and C&D waste) that meet the EN 12620 standard for concrete aggregates are scarce, costly, and often located far from production sites, as noted by our members in the industry. 2. High processing costs: The required quality of secondary aggregates for concrete makes the processing of demolition waste expensive, particularly when concrete is mixed with other materials and substances. This impacts the cost-effectiveness of using recycled materials. 3. REACH requirements: Should secondary aggregates be classified under REACH as "substances", their availability will become even more restricted, further increasing costs and reducing supply. 4. Durability of engineered structures: If adaptation is the objective in including the activity in the Annex, durability requirements for engineered structures such as bridges and viaducts, which often require a service life of up to 100 years, might be compromised by an increased share of secondary raw materials. 5. Risk of misapplication in other EU legislation: There is a risk that the DNSH criteria for secondary raw materials (intended not to be mainstream but to apply to exceptional projects, according to the Commission) may be used in other EU pieces of legislation, which could lead to issues with the supply of recycled aggregates.
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Response to Circular Economy Act

6 Nov 2025

Please find attached Concrete Europe's response to the Commissions call for evidence for the upcoming Circular Economy Act.
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Response to New European Bauhaus

17 Oct 2025

Please find attached Concrete Europe's input to the call for evidence.
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Response to European strategy for housing construction

18 Sept 2025

Please find attached Concrete Europe's input to the call for evidence.
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Response to European climate resilience and risk management law

4 Sept 2025

Please find attached Concrete Europe's feedback to the call for evidence.
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Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen) and CEMBUREAU - The European Cement Association

12 Jun 2025 · Housing

Meeting with Katharina Knapton-Vierlich (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and CEMBUREAU - The European Cement Association 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

Response to Report on the evaluation of the LULUCF Regulation

11 Jul 2024

Concrete Europe thanks the Commission for allowing us to provide feedback to the evaluation of LULUCF. We've noted in the evaluation report on LULUCF that the EU carbon sink has been in decline for the last decade and that the EU is not on track to meet the 2030 net removal target, falling short of 50 Mt CO2-eq. We've also found that EU countries advanced in the manufacturing of wood-based construction products like Sweden, Finland, Estonia see their carbon sink decreasing or even becoming a source of emissions due to the logging increase: - Swedish forests suddenly decrease the amount of carbon dioxide they can absorb (source: https://www.fern.org/publications-insight/swedish-forests-suddenly-decrease-the-amount-of-carbon-dioxide-they-can-absorb-2572/) - Based on final 2021 inventory data, Finland reported net emissions of 0.49 MtCO2-eq in the land use, land use change, and forestry sector (LULUCF) (source: https://climate.ec.europa.eu/document/download/45cac3d0-a9b5-4e95-80dc-c7944136b7e0_en?filename=fi_2023_factsheet_en.pdf) - Based on final 2021 inventory data, Estonia reported net emissions of 2.88 MtCO2-eq in the land use, land use change, and forestry sector (LULUCF) (source: https://climate.ec.europa.eu/document/download/142ca98f-9857-4155-91b2-e2e142d617dd_en?filename=ee_2023_factsheet_en.pdf) Additional links below provide with other impacts of unsustainable logging on CO2 emissions and on biodiversity: https://theecologist.org/2015/feb/11/swedish-wildlife-extinction-threat-loggers-clear-cut-old-growth-forests https://worldrainforests.com/deforestation/2000/Sweden.htm https://www.nateko.lu.se/article/clear-cut-forest-areas-emit-greenhouse-gases https://www.slu.se/en/ew-news/2022/2/clear-cutting-leads-to-changed-functionality-of-fungal-communities/ https://skyddaskogen.se/birdlife-sweden-announces-many-of-sweden-s-woodland-bird-species-endangered-by-forestry/?lang=en We would thus like to underline as an input to the relevance criteria, that policy coordination is of uttermost importance to ensure that the carbon sink is increased or maintained. Different EU policies points towards an increase of temporary carbon storage in bio-based products, notably construction products, which: 1) only postpones emissions (incineration, landfilling, natural decay) & 2) might lead to a decrease of the carbon sink if the balance between logging and development of forests is not properly managed. Especially at a moment in time when external factors stress forests across Europe. Finally, in product-specific legislation we would point out not to assume CO2 balance between uptake and emissions in sustainable managed forests. The main schemes (FSC, PEFC) focus on the sustainable management of forests but do not address their carbon neutrality. In addition, carbon neutrality of biobased products should only be considered when 100% of the raw material comes from forests certified as carbon neutral. This carbon neutrality shall also account for CO2 losses (soil, trunk, branches, leaves, and the whole forest system) to incentivise a more responsible use of biobased products and avoid overexploitation. In case a dynamic approach is considered for temporary storage, the dynamic of the forest shall also be included. The replacement of an original forest with a new one does not immediately balance the net carbon emissions. Depending on the harvesting method used, the payback period can vary from several years to several decades, during which the net balance between the product and the forest results in a net emission. LULUCF targets would thus not be reached. We would like to share with you and the consultants for the evidence gathering, the report of the study Carbon Accounting for Building Materials, an assessment of Global Warming Potential of biobased construction products carried out by LBP/Sight and peer-reviewed by Norsus: https://www.ca4bm.org/; https://www.lbpsight.nl/wp-content/uploads/2022/11/CA4BM_Final_Report.pdf
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Response to Initiative on EU taxonomy - environmental objective

3 May 2023

Please find enclosed Concrete Europe's feedback to the Commission draft Delegated Act on Taxo4.
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