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European Expanded Clay Association

EXCA

- To represent the interests of its Members (as defined hereinafter); - To act as a spokesman for the Expanded Clay Aggregate industry at a European level, and particularly vis-à-vis the institutions of the European Union (hereinafter referred to as the "EU"); - To communicate the views of the Expanded Clay Aggregate industry on all relevant developments in relation to technical, environmental, energy and promotional issues; - To maintain a permanent dialogue with other industry associations in Europe

Lobbying Activity

Response to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines

5 Sept 2025

The European Expanded Clay Association (EXCA) considers indirect cost compensation an essential part of the EUs carbon leakage protection framework. It must remain available beyond 2030 and should cover all sectors at risk of carbon leakage under Article 10b of the ETS Directive. Additional restrictive criteria should be avoided, as they contradict the objectives of the EU Clean Industrial Deal. please read the attached position for further details
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Response to EU emissions trading system - update of Activity Level Changes Regulation

9 Jan 2025

Please find attached the position of the European Expanded Clay Association (EXCA)
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Response to Amendment of the free allocation rules in response to the ETS revision/Fit For 55

25 Dec 2023

Please find attached EXCA response to the draft Delegated Act on free allocation rules.
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Response to Ecodesign for Sustainable Products - Product priorities

11 May 2023

Please find attached the European Expanded Clay Association (EXCA)'s feedback on the new product priorities for Eco-design for Sustainable Products
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Meeting with Michal Wiezik (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

11 Oct 2022 · Industrial Emissions Directive

Response to Review of the Construction Products Regulation

12 Jul 2022

The European Expanded Clay Association (EXCA) welcomes the European Commission’s initiative to review the Construction Products Regulation (CPR) to improve the functioning of the single market for construction products. Detailed feedback on the proposal is provided in the attached position paper.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

The European Expanded Clay Association (EXCA) welcomes the opportunity to provide feedback on the revision of the EU Carbon Border Adjustment mechanism. Please find attached our submlssion.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

The European Expanded Clay Association (EXCA) welcomes the opportunity to provide feedback on the revision of the EU Energy Taxation Directive. Please find attached our submlssion
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Response to Updating the EU Emissions Trading System

8 Nov 2021

The European Expanded Clay Association (EXCA) welcomes the opportunity to provide feedback on the legislative Proposal for the revision of the EU ETS Directive. EXCA represents the major expanded clay producers throughout Europe. Expanded clay is a natural, light and durable material, widely used in construction and as a growing media all over Europe. EXCA represents 90% of the European expanded clay industry. The expanded clay industry fully supports the European Commission’s objective to achieve a neutral impact on climate change by 2050, and protect the health and well-being of citizens from environment-related risks and impacts. However, it is essential that climate ambition coexists with a stable and predictable regulatory and financial framework, that it harnesses investments in innovative technologies and maintains the competitiveness of the energy intensive sector, which is exposed to strong global competition. We would like to highlight the following elements: • Re-basing of the cap (i.e. one-off cancellation of allowances) should be avoided as it would artificially increase the costs of allocations for the same level of climate ambition. • Free allocations should be maintained without the application of the Cross Sectoral Correction Factor (CSCF), considering also the possible extension of free allocation rules to additional installations. • The proposed increase of the upper value for the benchmarks update should be avoided. Such increase would result in a 50% reduction of the benchmark values, strongly penalising energy intensive industries, as the fuel fallback benchmark would then artificially be reduced as well. • Interventions in allowances availability regarding the Market Stability Reserve (MSR) should be avoided. Adjusting the MSR would render the market for allowances in Europe unpredictable, and risk attracting speculative trading. • Benchmarks should remain at the current level, taking into account the real availability of alternative energy sources. Biomass in particular is often unavailable at local level and will be the object of intense competition among sectors in the years to come. • The new provision introducing conditionality of free allocation undermines the carbon leakage protection measure and remains unclear in its scope of application. It would also penalise smaller companies, where requirements for energy efficiency audits, as proposed in the revision of the energy efficiency Directive, would also be modified. Futhermore, we welcome the fact the EC didn’t include the “tiered approach” to free allocation in its proposal. Such concept was studied in the Impact Assessment of the Commission. It grants only certain proportion of free allowances to different industrial sectors depending on the value of their carbon leakage indicator. We believe, it would defeat its purpose when Prodcom codes are more fully representative than NACE codes for a particular sector, such as expanded clay.
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Response to Technical amendments to the annexes to the Fertilising Products Regulation

15 Mar 2021

Please see the attachment for our full opinion on the Proposal for a Delegated Act Amending Regulation (EU) 2019/1009
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Response to Commission Decision determining the benchmarks values for free allocation in the period 2021-2025

20 Dec 2020

EXCA welcomes the publication by the European Commission of the draft implementing regulation determining the values of benchmarks for the ETS phase 4 (2021-2030). However, we are concerned that the new methodology used for the benchmark determination may end up establishing biomass as the reference fuel by overrepresenting the weight of installations currently using biomass. Biomass is clearly an excellent choice to reduce GHG emissions: however, its availability varies widely among Member States, for a variety of locally relevant reasons including: regulation; market conditions; population densities and the relative sizes of agriculture, forestry, marine and waste-based sectors. Moreover, national/regional rules may prevent industrial biomass combustion in some European regions (for ex. some parts of Italy). The value for the fuel fallback benchmark in phase 4 is set at 42.6 t CO2/TJ: however, we believe the correct value should be 42.64 t CO2/TJ. In phase 3, the fuel fallback benchmark was set at 56.1 t CO2/TJ, based on the emission factor of natural gas. 56.1 t CO2/TJ was the exact value, not requiring any rounding up. In phase 4, the value corresponding to the stated 24% reduction over a period of 15 years is 42.64 t CO2/TJ. This value does not require rounding up for three reasons: 1) No rounding up was done in Phase 3 (56.1 t CO2/TJ was the exact value at the time); 2) The NIMs template for fallback installations already refers to a value of 42.64 t CO2/TJ. Any inconsistency between the NIMs and the benchmark regulation would be misleading. 3) All product benchmarks contain three decimals on average, or a minimum of two (e.g. carbon black -1, 485 and hydrogen 6,73). No rounding up is done there.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

The European Expanded Clay Association, EXCA (www.exca.eu) and its members welcome the opportunity to comment on the Commission Roadmap on Substantiating Green Claims. Expanded clay is a well-proven, high quality, efficient and durable lightweight aggregate suitable for a wide range of applications in the construction sector. EXCA is in favour of adopting harmonized European method of making green claims and is pleased to offer its contribution to the debate. We believe that the most appropriate method for construction products, should be the CEN/TC350 suite of standards (EN 15804, EN 15978 etc.). We support the position of Construction Products Europe (CPE) in this respect, also uploaded on this website. In addition, we would like to add the following considerations: • construction products and the final building as the end-user product present methodological specificities, which were recognised by CEN when it modified its EN 15804 standard to comply with the EC mandate to include PEF requirements in 2018. The current text of EN 15804 is therefore already aligned with PEF rules, as recognised by the EC Joint Research Center (JRC) and PEF experts; • the European Industry has already developed more than 5000 Environmental Product Declarations (EPD) based on EN 15804. In addition, a substantial number of national and regional administrations are involved in the development of these EPDs and there are economic operators who offer services related to the implementation of EN 15804. EXCA members have been providing EPDs for several years now, and are currently updating their EPDs to comply with the newly modified standard requirements. Considering the previous arguments, EXCA believes that there is no need to establish any new legal framework on green claims for construction products.
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Response to Evaluation of the Industrial Emissions Directive

4 Dec 2018

EXCA welcomes the opportunity to provide its feedback to the European Commission on the Evaluation of the Industrial Emissions Directive. The ceramic BREF, which covers expanded clay plants, was first published in August 2007, and has not yet been reviewed since. Therefore, the expanded clay industry is not in a position to comment without a clear understanding of how the IED provisions would operate in practice. At this stage, we would like to offer our thoughts on the appropriateness of a revision at this point in time and also on the impact that the IED Directive has had on industrial emissions so far. Our comments are as follows: • The IED is a product of better regulation efforts in that it merged, streamlined and simplified several pieces of legislation. The system has worked successfully so far, greatly contributing to reducing industrial emissions and harmonizing methodologies EU-wide. This was confirmed by the EC in its 2017 Implementation Report . • Since the entry into force of the IED Directive, no major compliance issues have come to light. Most issues reported by the Member States related to implementation (frequency of reporting; update of permits in line with BAT conclusions etc.). Again, the 2017 Report confirms this. • As more information will be gathered in the next reporting period (covering the period 2014-2016), it stands to reason that a review of the IED Directive will be most effective only after Member States’ data is compiled and analysed, i.e. by 2020. This would be a more appropriate time to consider the launch of a full evaluation of the IED.
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Response to Carbon Leakage List 2021 - 2030

10 Nov 2017

EXCA welcomes the Inception Impact Assessment on the Carbon Leakage List 2021 - 2030 published by the European Commission (Ref.: Ares (2017)5046070) and expresses its interest to be involved as a stakeholder during the consulting process. EXCA is the European expanded clay association and represents the interests of all major expanded clay producers throughout Europe. Expanded clay is a well-proven, high quality, efficient and durable lightweight aggregate suitable for a wide range of applicants in the construction sector. It is a sustainable construction material packed with properties that improve the economic, social and environmental performance of a building or infrastructure over its whole lifetime With its 12 member companies in 11 countries operating some 19 plants throughout Europe, EXCA represents more than 90% of the European industry. Our industry is under direct impact of the EU ETS system. In the EU ETS phase 3, all expanded clay installations, several of which are SMEs, were within the scope of the EU ETS Directive. Despite representing a very small percentage of ETS emissions, the impact of the EU ETS system on the expanded clay manufacturers is very significant. Currently available text for the revised EU Emissions Trading Directive seem to suggest that the final list of carbon-leakage-exposed activities, when determined at the end of 2019, will include sectors or sub-sectors assessed at a 6-digit or an 8-digit level (Prodcom) as listed in the Annex to the Commission Decision 2014/746/EU. As expanded clay only represents 1% of its NACE, but over 70% of the corresponding Prodcom, maintaining the possibility to be assessed at disaggregated level according to this Annex is crucial to preserve the fairness of the Carbon Leakage list. In addition to this, the timing, verification, and coherence of data sets and related administrative and procedural rules are essential to preserve the equity of the carbon leakage list. In particular, the timing and administrative requirements applicable to the disaggregated assessment should be aligned with those applicable at NACE level. ​
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