OpenLobby.EU
Explore

European Lime Association

EuLA

The European Lime Association represents the European lime industry on sustainable development, climate change, energy, environmental protection, and health and safety issues.

Lobbying Activity

Lime Industry Demands Cheaper Electricity to Reach Net Zero

9 Oct 2025
Topic — The European Commission is consulting on a plan to promote the electrification of demand.
Message — The association requests removing non-energy costs from power bills and speeding up grid connections. They also seek funding for R&D and pilots for electric kilns.123
Why — This would prevent production and emissions from shifting to regions with lower energy costs.4
Impact — National treasuries would lose revenue if taxes are removed from industrial electricity bills.5
Read full response

Lime industry urges EU to credit carbon-absorbing materials

22 Sept 2025
Topic — This consultation establishes certification methodologies for activities that permanently remove carbon from the atmosphere.
Message — EuLA requests that the EU recognize enhanced carbonation of lime products as a carbon removal pathway. They also want biogenic carbon capture integrated into compliance regimes rather than voluntary markets.123
Why — This would prevent the overestimation of the industry's net emissions and unlock new investments.45
Impact — Alternative material producers may lose their competitive advantage if lime receives these carbon credits.6
Read full response

European Lime Association urges recognition of carbon-absorbing products

15 Sept 2025
Topic — The initiative proposes amending the European Climate Law to establish a 2040 target.
Message — The association requests that the EU recognizes how lime naturally re-absorbs carbon dioxide. They also seek earlier access to international carbon credits and equal removal rights for sectors.123
Why — This would ensure lower compliance costs and a more accurate carbon profile.45
Read full response

European Lime Association urges fair access to CO2 transport networks

11 Sept 2025
Topic — This initiative establishes a legislative framework for competitive EU-wide CO2 transportation infrastructure.
Message — EuLA calls for regulated third-party access and fair tariffs for small emitters. They propose EU-wide infrastructure planning and financial de-risking tools like CCfDs. The group seeks fast-track permitting and limited liability after CO2 custody transfer.12
Why — Regulated access prevents high costs and ensures smaller lime plants can decarbonize.3
Impact — Infrastructure operators lose the power to charge discriminatory prices to smaller emitters.4
Read full response

European Lime Association seeks inclusion in ETS aid list

5 Sept 2025
Topic — This consultation reviews which industries can receive state compensation for indirect carbon costs.
Message — EuLA requests including lime production and quarrying as eligible sectors. They claim these industries face high costs and risks of relocation.12
Why — Being listed would allow these sectors to receive state-funded relief from high electricity prices.34
Read full response

Lime industry urges trade measures to protect EU steelmaking

18 Aug 2025
Topic — The Commission is exploring trade measures to address global excess steel capacity.
Message — The association supports trade measures to safeguard the EU industrial base and steel sector. They emphasize that steel is the largest market for European lime production.12
Why — These measures would secure domestic lime demand and protect regional industrial jobs.3
Impact — Foreign producers using unfair practices would lose access to the EU market.4
Read full response

European Lime Association urges extended allowances for process emissions

8 Jul 2025
Topic — Review of the European Union’s Emissions Trading System for industrial and maritime sectors.
Message — EuLA requests extending free allowance allocations for unavoidable process emissions until 2050. They propose accelerating the phase-out of combustion-related credits to maintain the overall carbon budget. Additionally, the group wants recognition for carbon reabsorbed by lime products.123
Why — These changes would protect lime producers from high costs while technology matures.4
Impact — Other industrial sectors might face faster allowance cuts to balance the budget.56
Read full response

Meeting with Kurt Vandenberghe (Director-General Climate Action)

16 May 2025 · Competitiveness, decarbonisation, ETS, CCUS etc...

Meeting with Kitti Nyitrai (Head of Unit Energy)

13 Mar 2025 · EU objectives

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

20 Feb 2025

EuLA, the European Lime Association, represents European non-captive lime production through its 24 covered Member States (companies & national associations). Lime is one of the essential building blocks of modern industry. It is used in many essential processes, such as making construction buildings, producing iron and steel, treating contaminated land, purifying drinking water, making sugar and even cleaning gases from powers stations. Lime and its derivatives are also important additives for making paper, glass, and agricultural products. Please find our feedback attached.
Read full response

Meeting with Giorgio Gori (Member of the European Parliament, Rapporteur) and The European Steel Association and

5 Feb 2025 · Exchange of views on resolution on energy intensive industries with the Alliance of energy-intensive industries

European lime industry demands emissions accountability at point of release

29 Jul 2024
Topic — The European Commission is updating rules for monitoring and reporting greenhouse gas emissions.
Message — EuLA wants emissions accounted for at the point of atmospheric release. They also seek a link between the carbon market and removal certifications.12
Why — The industry would avoid financial penalties for carbon that is captured, purified, and transported.3
Impact — End-users would lose because they must cover the costs of managing their generated pollution.4
Read full response

Meeting with Kadri Simson (Commissioner) and

9 Jan 2024 · Meeting with CCS Europe members on CCS strategy.

European Lime Association seeks flexibility in emission allowance rules

2 Jan 2024
Topic — This consultation updates rules for free emission allowances under the revised EU ETS.
Message — EuLA recommends that installations are not penalized when following multi-year audit implementation schedules. They also propose including CO2 savings as an alternative criterion for compliance.12
Why — It allows companies to keep their free allowances despite missing specific energy-saving targets.3
Read full response

European Lime Association seeks sub-installation climate plan application

1 Sept 2023
Topic — New rules defining the content and format of mandatory climate-neutrality plans.
Message — EuLA requests that climate neutrality plans apply at the sub-installation level rather than for whole installations. They believe targets should reflect specific investment measures instead of absolute emission metrics.12
Why — This change prevents entire complexes from losing free allowances due to one underperforming unit.3
Impact — Climate groups may see weakened accountability if absolute emission reduction targets are replaced by investments.45
Read full response

European lime industry urges infrastructure investment and mineralisation recognition

31 Aug 2023
Topic — The consultation explores strategies for deploying carbon capture, utilization, and storage infrastructure.
Message — The association requests the development of shared CO2 infrastructure with fair access. They call for streamlined permitting across the value chain and faster approvals. They want lime mineralisation recognized as permanent carbon storage in EU regulations.123
Why — Recognizing mineralisation allows the industry to lower its carbon liability and remain competitive.45
Impact — Local communities and environmental groups would have fewer opportunities to challenge infrastructure projects.6
Read full response

European Lime Association urges inclusion of carbon utilization in NZIA

27 Jun 2023
Topic — The consultation addresses the proposed Net Zero Industry Act for European decarbonization.
Message — The organization requests expanding the list of strategic technologies to include carbon capture and utilization. They also seek streamlined permitting processes across the entire industrial value chain.123
Why — The industry would secure the necessary infrastructure to remain competitive while reaching decarbonisation goals.4
Impact — Local communities and environmental groups lose influence due to shorter assessments and simplified appeals.5
Read full response

European Lime Association backs 80% emission cuts by 2040

23 Jun 2023
Topic — The European Commission is establishing a climate target for 2040 to reach neutrality.
Message — EuLA supports a 2040 climate target of -75% to -80% reduction. They request priority access to biomass-derived fuels and expanded carbon capture infrastructure. The industry wants recognition for carbon permanently stored in lime-based products.123
Why — This approach helps the industry remain viable by offsetting unavoidable chemical process emissions.4
Impact — Other industrial sectors might face fuel shortages if biomass is prioritized for lime.5
Read full response

European lime industry seeks recognition for carbon-capturing products

23 Mar 2023
Topic — The European Commission is developing a regulatory framework to certify and monitor industrial and ecosystem-based carbon removals.
Message — The European Lime Association argues that carbonation in lime products and soil liming should be formally recognized as permanent carbon removal solutions. They request clear rules for certifying these processes to support industrial sectors with unavoidable process emissions.12
Why — This would allow the industry to certify its products as carbon sinks and offset significant process-related emissions.34
Read full response

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

15 Feb 2023 · CCS

Response to Fitness check of how the Polluter Pays Principle is applied to the environment

11 Dec 2022

The polluter pays principle (PPP) is a key principle underlying EU environment legislation and policies. It is enshrined in the Treaty on the Functioning of the EU ETS. Therefore, it is crucial that the eventual accounting methodology used for carbon capture and utilisation (CCU) applications is aligned with this principle. CCU applications will have some role to play in reaching climate neutrality, in particular for hard-to-abate sectors. Therefore, the accounting rules under the EU ETS need to be adapted so that they incentivize the environmentally responsible uptake and use of such technologies. To achieve this aim, the rules should be aligned with the IPCC guidelines, safeguard the environmental integrity of the EU ETS, be aligned with the polluter pays principle, provide effective support to the CCU value chain, and be practically feasible to implement. It can be discussed who is the polluter in the case of CCU technologies: the entity that generates but captures the CO2, therefore avoiding its release into the atmosphere? Or the entity that consumes the CCU product, in which case the CO2 might be released into the atmosphere? In the strict sense of the word, the polluter is the entity that causes harm to an environment by releasing harmful substances into that environment. Based on this definition, the entity consuming a CCU product and thereby causing CO2 (= the harmful substance) to be released into the atmosphere (= the environment) would be the polluter. Such an interpretation is also consistent with the Directive on Environmental liability and with the broader MRV and accounting rules under the EU climate policy framework and the EU ETS in particular. It is an overall practice under the EU climate policy framework to regulate and account for emissions where they are released into the atmosphere. As a result, the PPP is not properly implemented in climate policy when the CO2 generated in an installation must be declared at the generation source, even if it is captured and processed to form an e-fuel. The PPP would be better implemented if the installation burning e-fuel and emitting CO2 into the atmosphere would have the obligation to report those emissions.
Read full response

European lime industry urges removal of 2035 carbon capture limit

17 Jun 2022
Topic — Methodology for assessing greenhouse gas savings from recycled and non-biological renewable fuels.
Message — The European Lime Association requests removing the 2035 industrial carbon capture deadline. They argue lime manufacturing produces unavoidable emissions requiring long-term reuse options. The group suggests distinguishing between process emissions and burning fossil fuels.12
Why — This would provide regulatory certainty and protect investments in essential carbon capture technologies.3
Read full response

Response to Carbon Removal Certification

2 May 2022

SEE attached document
Read full response

Response to Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

The EU ETS Directive would require mandatory energy audits to ETS installations based on the current Article 8(4) of Directive 2012/27/EU. Not implementing the recommendations proposed by the auditors could lead to a “penalty” i.e., the reduction of 25% of free allocation quotas. EuLA is supportive of measures to encourage energy savings but needs to alert the EU legislator when measures can have non-desirable and counterproductive effects. This is the case for sectors where most of the carbon emissions are not related to energy use but originate from an inevitable chemical reactions in the manufacturing process, for example, decarbonation of limestone during the manufacture of lime products. The benchmark values are already taking into consideration the best performers only, in most of the sectors. Article 10a of the EU ETS Directive states that the benchmarks values shall provide “incentives for reductions in greenhouse gas emissions and energy efficient techniques, by taking account of the most efficient techniques, substitutes, alternative production processes, high efficiency cogeneration, efficient energy recovery of waste gases, use of biomass and capture and storage of CO2, where such facilities are available”. EuLA calls for: • Maintaining the current level of flexibility. Lime companies are already part of voluntary agreements which provide commitments to reduce CO2 emissions and to improve energy efficiency. While action plans and implementation schedules are indicative, the commitments are binding. This way of working incentives companies rather than setting recommendations in many cases not achievable due to the pure nature of the production process. • Should the proposed provision on audit be maintained, setting a process of appeal at administrative level so unrealistic recommendations can be appealed by the audited company before the conclusion are implemented. This will further increase the chance that the feedback provided by the auditor is useful in terms of output. In many cases, we notice that some of the recommendations formulated by energy auditors are not achievable due to a lack of specific knowledge of lime installations, its functioning and the quality requirements that influence the production process. • To guarantee a minimum level of competence for auditor´s in charge of the energy audit. Auditors who declare the performance of an energy audit should demonstrate a basic knowledge of the technological processes carried out in companies for which they undertake the energy audit. • Should the proposed provision on audit be maintained, to incorporate climate mitigation measures as a condition to define the auditors’ recommendations. i.e., certain energy savings measures should not be implemented if they would increase the installation’s emissions or global emissions in the value chain (scope 1, 2 or 3). Attached EuLA position paper with further explanation.
Read full response

Response to Revision of the Energy Tax Directive

2 Nov 2021

The European Lime Association (EuLA) is concerned about the current orientation of energy taxation at European level. EuLA recognises the convenience of an up-to-date Energy Taxation Directive (ETD) as a pillar of the new legislative setting the European Climate & Energy Policy. Nonetheless, the proposed removal of the “mineralogical processes” exemption by the EC raises major concerns for the competitiveness of the lime industry, especially given that we are facing additional costs from several other EU Fit for 55 regulations as well and in light of the soaring energy prices. Furthermore, the justification for the proposal to remove the current exemption is not at all clear. Considering that: 1. Removing the mineralogical process exemption will increase EU energy cost and carbon leakage. 2. Removing the mineralogical process exemption will also increase lime operation cost. 3. Removing the mineralogical process exemption will reduce our investment capacity. 4. Removing the mineralogical process exemption will negatively impact our society. An EU-based and mandatory mineralogical process exemption as it exists today and across the EU contributes to avoid an additional drastic cost increase of energy for our sector. We therefore ask the EU-commission to explicitly exclude 'mineralogical processes' from the scope of the Directive by keeping them into Article 3 (b) of the 'Revision of the Energy Taxation Directive'. Attached EuLA position paper with further explanation.
Read full response

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 Carbon Border Adjustment Mechanism

1 Oct 2021

The European Lime Association (EuLA) welcomes the opportunity to provide feedback on the EC proposal establishing a Carbon Border Adjustment Mechanism (CBAM). IMPLICATIONS FOR THE LIME INDUSTRY As CBAM is interconnected with EU ETS, its implications on the lime industry will depend on the success and development of a complex and not yet tested instrument. The results of the pilot phase are extremely relevant. Considering the following points, and notably that: • Lime is essential for a vast majority of industrial sectors in EU and the EU lime industry strongly support measures to prevent the displacement of its customer’s production outside Europe due to a lack of international competitiveness. • For lime it is key to ensure their customers remain in Europe. EuLA Position: Thus, the following four major principles should be considered when designing a CBAM, particularly: 1. CBAM should be presented as a complementary instrument (Art 1 (3)) for sectors at risk of carbon leakage rather than as an alternative to the current system of free allocation. EU exporters risk losing markets outside Europe because they can no longer compete with non-EU competitors that do not face similar constraints, and this will contribute to carbon leakage. Until trade partners adopt strictly comparable policies and carbon pricing, EU producers should continue to receive free allowances. It is a fact that there is significant complexity and uncertainty associated with setting a CBAM that is both (a) fully efficient and (b) compliant with WTO rules. For this reason, EuLA supports the idea that CBAM should start with an initial period which only large emitters of GHG already exposed to carbon leakage from countries without similar carbon burden to their competitors. Due to the complexity, the EU should also allow sectors to volunteer to participate in the CBAM in the future and support the EU Commission in setting the detailed rules. 2. CBAM shall ensure that lime customers remain in the EU (i.e: steel) by not encouraging them to delocalise outside of the EU and provide alternative measures to address unfair competition at the EU border for sectors not currently covered by CBAM. 3. The current CBAM proposal only addresses imports. CBAM shall also provide a solution to EU exporters to avoid exported products from efficient EU producers being replaced outside Europe by products with lower carbon constraints not subjected to equivalent carbon measures, which thereby undermine European competitiveness. The CBAM shall reconsider an equal treatment for the products coming from the list of countries exempted from this tool (Annex III), thus including those ETS system which are fully aligned and have co-existed with the EU ETS, and for which the cost of integration should be minimal. This for instance, is the case of the United Kingdom. 4. CBAM shall consider Life Cycle Assessment (LCA) when assessing the CO2 carbon content of any imported or exported product. That is, targeting the carbon content of the product based on an LCA approach and transparency, rather than the country of origin. The quantification of emissions from extra-EU production because recourse to the LCA is not easy and the perimeters on which to evaluate them should be agreed.
Read full response

Response to Updating the EU Emissions Trading System

1 Oct 2021

EuLA Position on the European Commission (EC) Proposal amending Directive 2003/87/EC establishing a system for greenhouse gas emission allowance trading: • Under the current framework, it is essential for hard to abate sectors with a high share of irreducible process CO2 to have large and affordable access to a global infrastructure to collect the CO2 and transport it with the view to utilise or store the captured CO2. • Recognition of CCU and the role of carbon removals is essential to support the decarbonisation of the lime sector under the ‘fit for 55’ package. • A feasible benchmark update should not go beyond of what is technically feasible. Attached EuLA position paper with further explanation.
Read full response

Response to Revision of EU rules on Gas

10 Mar 2021

The European Lime Association (EuLA) welcomes the initiative of the European Commission (EC) to receive feedback on the inception impact assessment on the Hydrogen and Gas markets Decarbonisation Package, revising Directive 2009/73/EC and Regulation (EC) No 715/2009. Ensuring common rules for the internal market in natural gas and enabling conditions for access to the natural gas transmission networks is key to ensure the decarbonisation of the lime sector. This reform shall be an opportunity to consolidate & develop Carbon Capture and Storage (CCS) and Carbon Capture and Utilisation (CCU) structures. OUR CALLS • The EC roadmap mentions that “Direct electrification is for most uses the most cos-effective and energy-efficient way to decarbonise final energy demand”. In cases where “alternative mitigation options are not available ”, we call the policymakers to strengthen the role of capturing CO2 via CCS & CCU, by supporting those sectors wishing to contribute to the decarbonisation objective. • Taking into account this request, EuLA supports key elements of the inception paper, notably: o The reform should enable fair competition between smart electrification, energy efficiency, and renewable and low-carbon gases like hydrogen and bio-methane, of CCU technologies in achieving decarbonisation targets. o The necessity to create cross-border infrastructure ready for decarbonised gases and CO2 transportation. o The need to take into account structural changes in the consumption of gaseous fuels as expected under any decarbonisation scenario. o Policy coherence with the different pieces of legislations adopted to reach the EU Green Deal objectives, including the role of ETS as a positive price signal to encourage valorisation and use of CO2. o A more integrated approach to infrastructure network planning supported by the right legislation, aiming to reduce electricity oligopolies within the EU internal market. Renewable and low-carbon hydrogen are part of the EU’s decarbonisation efforts. o The need to include hydrogen pipeline transportation in the current regulatory framework. It should be the same for the transportation of CO2. o Ensuring the emergence of cost-effective hydrogen infrastructure. o Facilitation of local and decentralised production of renewable and low carbon gases including synthetic-methane and e-fuel in general. o Ensuring more holistic and inclusive infrastructure planning, in particular for the gas, hydrogen and electricity markets. o Requirement of a cost-effective development including through repurposing of existing natural gas infrastructure. Against that background, EuLA considers that the base line scenario (no policy change) is not an option. To achieve carbon neutrality, the transport and infrastructure of not only hydrogen, but e-fuel in general and CO2 should be considered in a very coordinated manner. These gases equally participate to pave the way for a CO2 neutral industrialisation of Europe. Access to transport infrastructures for hydrogen, e-gaseous fuels and CO2 should be affordable for all industries, not only the major emitters or consumers. Access should be geographically largely spread at a cost reflecting the “public service” nature of these networks.
Read full response

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

28 Dec 2020

EuLA acknowledges the opening by the European Commission on 7th December 2020, of the public consultation on the draft Commission Decision determining the benchmarks values for free allocation in the period 2021-2025. As earlier noticed, the product benchmark value for lime is announced to be 0,725 (allowances/t), being this the maximum reduction possible (24%) applied between 2007-2008 and 2023. As also discussed during the bilateral meeting EuLA hold with DG CLIMA (Unit B.2 ETS Implementation & IT), on the 8th May this updated valued is not feasible to be reached. During this meeting, the European Commission recognised that they wish to elaborate the benchmarks in a way that the best performing installations will receive 100% of free allocation at their benchmark level. Under the current DG CLIMA approach based on the full consideration of biomass for the calculation of the benchmarks update within the IV Phase of the EU ETS (2021-2030), the 10% best lime sub-installations will not cover their portfolio of free allocation fully. • Our call: The values presented within the draft were expected considering the EC is willing to include full biomass in the benchmark calculation, something that not only EuLA but also other European Federations have been strongly advocating against as: 1. Sub-installations burning biomass are not the most energy efficient sub-installations, 2. Biomass fuel availability is geographically limited due to very specific local conditions, and 3. Biomass burning does not provide the right incentives to achieve the EU climate neutrality goal (air pollutant emissions and negative impact on biodiversity are among others). Even if these solid arguments have not been considered by the policy maker, we are still optimistic that the European Commission aims to respect the basic principles of the EU ETS Directive and free allocation. In a nutshell: 1. Determining the benchmark on biomass is artificial to a certain extend due to lack of availability and future conflict on biomass preservation. The main long-term source of biomass will be biomass waste and the capacity will never exist to cover all industries’ needs. 2. The artificial extension of the improvement factor is inappropriate in a sector with very high proportion of process & irreducible emissions. As a dramatic consequence, the level of free allowances determined by this methodology will not be sufficient even for the 10% best sub-installation. Mutatis mutandis, applying the provision of art 16e to the process emission’s share could be a fair way to address this very particular case. 3. The proposal of the commission is disproportionate as in the case of lime, the benchmark value will not be sufficient to cover the emissions of the best in class while in other sectors the proposed benchmarks values are much higher than the actual 10% best emitters. Within this paper, we call the European Commission to consider the issue of the lime sector having a huge proportion of (irreducible) process emissions and the consequences of the proposed reduction: If the proposed values are adopted, the 10% best lime sub-installations will not receive full free allocation at benchmark level so delocalisation or carbon leakage and other negative consequences of this decision will be visible in the short term. A further and more detailed explanation is presented in the attached paper.
Read full response

Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

The members of the European Lime Association (EuLA), aknowledge the European Commission's review of the guidelines on State aid for environmental protection and energy 2014-2020 (EEAG). This new document represents a unique opportunity to improve and update the current regime to reflect the latest EU regulatory and policy developments stemming from the low carbon transition affecting the competitiveness of the lime sector, ranging from EU energy, climate and environmental legislation to global trade and competition law developments over the last decade. For the lime industry, the state aid rules related to energy and environment are fundamental to ensure that the installations investing in energy efficiency as well as in low-carbon and sustainable manufacturing solutions can benefit from state aids.
Read full response

Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

EuLA acknowledges the publication of the European Commission (EC) roadmap for the potential revision of the ESR to be aligned with a GHGs emission reduction target of at least 55% of 1990 levels by 2030. Through the upcoming assessment, we call the EC to consider the impact, not only for ESR sectors but also on the EU ETS System, that due to the revision of the ESR an extension of the current EU ETS framework will undoubtably have on our daily activities. OUR CALLS • ETS must stay a very solid, robust, predictable financial instrument to provide appropriate signals for investing and operation in a more climate friendly mode. The risk of extending ETS to some additional versatile installations ought to be analysed in detail. • We call the EC to consider a fair contribution among sectors contributing to the climate neutrality goal. The reinforced GHG emissions target in 2030 should be declined in a fair and equitable way between all emitters in the society. ETS sectors have demonstrated a significant reduction up to now while other sectors like transports and housings has merely increase their carbon footprint. The effort sharing between ETS sectors and other sources of emissions should also take into consideration the way that some sectors have already be reached. Some sectors, like the renovation of energy-intensive constructions should be asked to catch-up their delay together with their fair contribution to neutral long-term objectives • If any extension of the current EU ETS system from current ESR sectors, we call the EC to ensure the minimum distortion possible of the carbon market.
Read full response

Response to Updating the EU Emissions Trading System

25 Nov 2020

OUR CALLS Priority 1: inclusion of CCU into the EU ETS The EU ETS directive must equally encourage CCU, which is indispensable to liaise climate objectives and circularity. The European Court of Justice has already two times (Case C-460/15 and Case C-561/18) decided that the EC should not include CO2 that is subsequently chemically bound and not emitted to the atmosphere in the CO2 emissions reporting in the ETS. The impact assessment should dedicate one important part of its analysis on the contribution of CCU to determine the real net balance situation of GHG in Europe and to strongly promote any type of innovation to reuse CO2 as a raw material or alternative energy replacing fossil fuels. Taking permanent carbon removals as lime applications in account in ETS would constitute an indispensable and powerful leverage to mitigate the impact of Hard to Abbate sectors. CCU was already mentioned in recital 14 of the DIRECTIVE 2018/410 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 14 March 2018 amending Directive 2003/87/EC . With accelerated ambitions, Europe must complement its current instruments to adequately consider the Utilisation of CO2 and widely deploy circularity practices. As part of its contribution EuLA is producing a scientific review conducted by POLIMI , which clearly evidences that usage of lime in certain applications absorbs ambient CO2 to store permanently in materials. This underpins on a scientific basic our view that carbonation should be taken into account in ETS reporting. Priority 2: Infrastructure Infrastructure plays a key role in the CCS/CCU deployment: the impact assessment should consider the extent to which collecting CO2 for various sources is feasible in Europe, for large, medium or small sources. The impact assessment should consider technical constraints, permitting constraints, public acceptance, economical costs, with the option to consider collecting CO2 as a public service accessible at fair and reasonable cost. The location and connection of CO2 pipes might constitute a key parameter for industrial development in Europe in the future decades. Transportation networks in general, and the possibility to develop these close to the industry sites, will determine where industries of the 21st century will be located! Different transportation methods besides pipelines should be taken into account in the ETS. Costs, availability and public services requirements of these processes should also be addressed by the impact assessment. Priority 3: Burden sharing The impact assessment should not limit its scope to the analysis of transposing the -55% target as such in the ETS sectors. The assessment should revisit the elements that initially determined the share of the global target to impose to industries (the ETS and the non ETS sectors), transport, agriculture, household consumption etc. Industries have already reduced a lot compared to the evolution of other emitters . The global costs of the marginal additional effort should be re-evaluated taking additional accessible potential into account. Priority 4: Functioning of the EU ETS After already 15 years of functioning, the EU ETS still faces difficulties: prices are still volatile, long term predictability is far from being reached and discourage investment, carbon leakage risk, etc. Against that background, including maritime transports (internal or international), buildings and potentially importers in the EU ETS, should be carefully analysed, while aiming to guarantee stability, transparency, and confidence in the system. The impact assessment should dedicate appropriate resources to deeply look for available alternatives to provide a price signal and just contribution of these sectors without necessary including them in a system which is yet not stable.
Read full response

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

26 Oct 2020

The European Lime Association (EuLA) welcomes the opportunity to provide its feedback to the European Commission on the inception impact assessment, Regulation EC 166/2006. It is only through these assessments that regulations, such as the European Pollutant Release and Transfer Register, can be designed fit-for-purpose. Therefore, it is a priority for the lime sector to engage in a constructive dialogue with policymakers to ensure its successful review. We would like to share several recommendations on the way forward (see attached document).
Read full response

Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

24 Aug 2020

The European Lime Association (EuLA) welcomes the opportunity to contribute to the Refit evaluation of the Sewage Sludge Directive, henceforth the SSD or the Directive (86/278/EEC). The SSD complements the EU waste legislation by encouraging the safe use of sludge (moving it up the waste hierarchy), by promoting health and environmental protection (by placing limits on heavy metals), and by contributing to resource efficiency (through the recovery of useful nutrients such as phosphorus). EuLA calls for: 1. The role of the Directive is to prohibits the use of untreated sludge on agricultural land unless it is injected or incorporated into the soil. The Directive also requires that sludge be used in such a way that account is taken of the nutrient requirements of plants and that the quality of the soil and of surface and groundwater is not impaired. The two major treatments of sewage sludge to guaranty stability and safety use in agriculture that have been developing around Europe are: 1. The composting and 2. The liming. Liming is the simplest, cost-effective, and most reliable technique. It allows short time treatment and lime participate to enhance the dewatering process. 2. Lime is recognized to be a biocide active substance for the treatment of sewage sludge against bacteria, virus and mould and it then guaranties the stability and safe use of the treated sludge. Liming then guaranties the stability and safe use of treated sludge. Liming finally brings also valuable additional features to the treated sludge with calcium and/or magnesium and neutralizing value to be used as fertilizer. Special lime products and associated processes have been developed in the last 10 to 20 years enhancing the efficiency and reliability of such treatment for valorization. 3. The SSD was adopted to encourage the correct use of sewage sludge in agriculture and to regulate its use to prevent harmful effects on soil, vegetation, animals, and humans. The principal benefit of the SSD is its role in the protection of human health and the environment against the harmful effects of contaminated sludge in agriculture. These principles are fully aligned with the New Circular economy action Plan (2020) as well as the Green Deal (Dec. 2019). Lime has demonstrated that can support the recovery of critical raw materials and nutrients such as phosphorus. 4. The SSD directive is fit for purpose and recognising liming process as a direct contributor to the scope of the SSD directive should remain unchanged.
Read full response

Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

23 Jul 2020

Introduction EuLA welcomes the possibility to comment and voice its concerns regarding the opening of a public consultation of the second revision of the Monitoring and Reporting Regulation (MRR) as announced by the European Commission (EC) on 29th May. Lime is a hard to abate sector, mainly due to the large amount of process CO2 and the intensity of its energy requirements. Considering that background the MRR revision represents an opportunity to: • Help to improve a wider availability of biomass in Europe. • Represent a significant trigger to avoid CO2 emission that can be captured in the making of new products where CO2 will be permanently embodied. • Provide clarity as per the compliance provisions of sustainability and GHG emissions savings criteria. EuLA calls for: 1. Recognition of Carbon Capture and Utilisation (CCU) through mineral carbonation as a carbon removal technology. By doing so, business will be incentivised to close the CO2 loop by optimising mineral carbonation and re-using CO2 in various applications. Mineral carbonation sequestrates CO2 in a permanent, stable form to make sustainable building materials (analogous to geological storage as the CO2 is not released again). It is essential that the role of CCU is correctly recognised, in such a way as to ensure that the integrity of the EU ETS and its fundamental concept of reducing cumulative CO2 by limiting availability of EUAs is maintained. CO2 from an ETS installation which is permanently stored through mineral carbonation shall be recognised as not having been emitted according to ETS and discounted from the installation’s allowance obligations. Thus, if CO2 from an ETS installation is ultimately not released in the atmosphere, that amount should be subtracted from the emissions of the originating ETS installation. We encourage the EC to consider the proposed list of amendments (in annex) to strengthen the role of mineral carbonation under the MRR. 2. Clarification is required as per the application to industrial installations, other than those producing electricity, heating & cooling and transport, of the criteria provided by Article 29 (2) to (7) and (10) of Directive 2018/2001 associated with annex VI and the exemptions contained in art. 29 (1); including how the percentages set as default values for GHG emissions savings (annex VI of RED II) should be utilised for industrial sectors. Considering that the criteria of compliance are designed to define requirements for sectors producing power, heating & cooling and the transport sectors; it is not clear if and how these criteria apply for ETS industrial installations. Given the lack of reference to art. 29 (1) of RED II in the MRR revision, it is not clear whether the exemption contained in that paragraph applies. The same goes for the criteria contained in art. 29 (10). Consequently, a robust cross check and guidance for ‘fit for purpose’ are required. 3. Consistent application of the rules as per the sustainability and GHG emissions savings criteria during the entire phase IV. EuLA is concerned about the discrepancy of rules applied between the emissions from solid biomass for setting the benchmark 2021-2025 (all type of biomass = zero) and the emissions reporting rules for the reporting period starting 2022 (in a very restrictive interpretation, see under heading 2) only sustainable and GHG savings solid biomass = zero). It seems logical that the criteria should apply in such a way that the biomass having determined the benchmark should keep the same status in the relevant reporting periods. EC should consider the potential impact on the benchmark update of setting different conditions for biomass across sub-periods and establish harmonised, comprehensive, and unambiguous criteria. This will provide certainty and predictability to concerned sectors allowing them to better assess the potential consequences and anticipate accordingly.
Read full response

Response to Climate Law

30 Apr 2020

A 2050 framework based on a Climate Law for everybody General EuLA acknowledges the European Commission proposal for a first European Climate Law to enshrine the 2050 climate-neutrality target. It will contribute to ensuring the predictability and security that not only investors -but also the European lime sector- requires to remain a key enabling player in a competitive economic environment. This legislation will ensure that negotiated targets and actions are fulfilled and that no step back is taken that could undermine the credibility of the climate objective, not only at European level but also within the international context. Our approach: • Climate Law should set realistic targets and avoid Carbon Leakage: EuLA welcomes the fact that the law introduces the climate neutrality objective for all sectors and all GHGs. Equally important, is the recognition of sectors where decarbonation is more challenging, as it is the case for the lime sector. Any revision of the current targets should be based on robust Impact Assessments including Best Available Technologies and maturity for new ones. Setting more stringent targets to the recently agreed climate legislation, without ensuring sufficient protection of the energy-intensive sectors, which are at the basis of the economy, will undoubtedly provoke a negative impact on the economic activities of many value chains. As far as the risk of carbon leakage is still present, additional measures supporting this increase in the climate target shall be set in parallel. Also, the European Commission, while leading by example, should encourage all international partners to establish similar tools globally. Climate change is a global challenge and cannot be tackled only by Europe. • Climate law should be the “leading trigger” for a ‘forward-thinking’ manner while providing the necessary means. The challenge of transformation to deliver on climate objectives for the lime sector requires important investments in modernisation and innovation. If any increase of the target, public investment shall be increased accordingly. For the lime industry, due to the high share of CO2 emissions coming from the decarbonisation of the raw material (68% on average), the most important CO2 mitigation measures are “end of pipe” solutions: CCS, CCU and carbonation. Climate Law should be an enabler of these technologies through their legal recognition that will trigger additional private investments deployment in the real economy. Furthermore, provided that CCUS becomes a norm, transport of CO2 and related infrastructures still remain an issue for the lime industry. • Mineralisation/Carbonation should be acknowledged as a carbon removal technology. Scientific evidence shows that carbonation of lime occurs during the lifetime of different applications thus making lime a carbon sink. Part of the CO2 emitted during the production process of lime is absorbed during the utilisation phase i.e. mortars, steel etc. A commonly agreed methodology in coordination with the concerned industries could enable a correct quantification of the CO2 absorbed and a certification scheme could be established as a monitoring tool. • Climate Law should bring predictability and clarity: It must provide answers to the different key actors and society. The industry needs to know how climate neutrality is calculated and how the carbon offset will be addressed within future impact assessments. In this sense, the Climate Law shall include a harmonised European definition of carbon neutrality. This will allow not only the lime sector but the energy-intensive industries as a whole, to measure the potential impact of the Law and to identify areas for action to enable the transformation challenge. EuLA and its members continue their efforts on the decarbonisation pathway including carbonation and aiming for a carbon neutrality target by 2050.
Read full response

Response to EU rules on industrial emissions - revision

21 Apr 2020

Please, find attached the EuLA (European Lime Association) comments on the Inception Impact Assessment for the revision of the Industrial Emission Directive.
Read full response

Response to 2030 Climate Target Plan

15 Apr 2020

EuLA acknowledges the Green Deal announcement and manifests his willingness to contribute to the debate on the intermediate targets enabling to achieve climate neutrality by 2050. EuLA acknowledges the European Commission proposal for the 2030 Climate Target Plan under the first European Climate Law. This legislation will set the intermediate pathway to achieve the 2050 climate neutrality ambition to reach the objectives of the Paris Agreement and ensure that once the 2030 target is implemented in the European Climate Law, no step back is taken to undermine the credibility of the climate objective, not only at European level but also within the international context. EuLA recognises the importance of the current discussion and wishes to participate actively as a notorious contributor. OUR CALLS A robust Impact Assessment (IA) is necessary to evaluate the effect of the new climate target on the energy intensive industry. Moreover, the Impact Assessment should cover and investigate the potential for further reduction of GHG emissions of all economic sectors (non-ETS sectors) contributing to the global European objective. The current European climate policy is based on a GHGs reduction target of 40% (compared with 1990 levels) by 2030. If an increase of this target to 50% - 55% GHGs by 2030 is considered necessary to achieve climate neutrality by 2050, it has to be proposed after a detailed and robust analysis demonstrating that the European Industries are technically and financially capable to adapt under short notice without losing their competitiveness. Moreover, the current deep global COVID-19 crisis is far from being behind and the IA cannot ignore in its analysis, the different impacts of the crisis on the social and economic strengths in short and medium terms. The 2030 Climate Target Plan must ensure carbon leakage protection for exposed sectors. An increased level of ambition on the GHG emission reduction target shall be accompanied by a similar increased level of industry protection. Increasing the risk of carbon leakage should be accompanied by additional measures on top of free allocation. The European Commission, while leading by example, should encourage other countries to introduce similar GHG mitigation measures. The Impact Assessment on the 2030 Climate Target Plan must also recognise the potential impact of increasing the climate ambition on other European policies. It is extremely important to mitigate the consequences that increasing the GHGs target could trigger on other EU policies, such as “use of biomass as energy source and its impact on land use, food production and biodiversity”. The 2030 Climate Target Plan must be an enabler for technological development for carbon removal. It is also important to consider that the innovative technologies necessary to contribute to the 2030 challenge, have not reached a sufficient level of maturity yet. Indeed, the challenge of transformation to deliver on climate objectives for the lime sector requires important investments on innovation. For the lime industry, due to the high share of CO2 emissions coming from the decarbonisation of the raw material (68% on average [1]), the most important CO2 mitigation measures are “end of pipe” solutions, notably CCS, CCU and carbonation. We call the EC to strength the support of these instruments to enable decarbonation. Thus, EuLA is also supportive of the joint statement of the Alliance of Energy Intensive industries; accessible through the following link: https://www.eula.eu/eula-2020-position-paper-on-2030-climate-target-plan-roadmap/ [1] CLM BREF (2010), p.254
Read full response

Response to Carbon Border Adjustment Mechanism

31 Mar 2020

Please find below a summary of the EuLA position for a future Carbon Border Adjustment (CBA). Further information is provided in the attached EuLA position paper: Lime is a key enabling material, active in a number of important industrial sectors, such as steel, cement, non-ferrous metals, paper, glass, etc. Ensuring the competitiveness of these lime consumers and the continuity of their operations in Europe is absolutely essential for our sector. That being said, the lime industry is a strong supporter of and invests continuously in carbon footprint reduction technologies; these investments and the viability of our industry should be protected. • Context The Paris Agreement is the cornerstone of an ambitious global program to address climate change mitigation. Avoiding carbon leakage is, in this context, essential from an environmental point of view: it ensures that companies financially contribute to the low-carbon transition without running the risk of being unfairly competed out. Against that background, the lime industry supports efficient mechanisms that protect EU major industrial sectors from unfair competition from outside of the EU (where competitors do not bear the cost of CO2). The following insights aim to support the efficiency of a future Carbon Border Adjustment (CBA). • Problem the initiative aims to tackle A CBA should be introduced in a fair manner: as such, it is essential to identify the drivers of production displacement, and the CBA should be applied down at the product level. It is equally essential to ensure that any CBA considers the global context of carbon leakage and production displacement. To avoid any long-term effect on the structure of EU imports, the CBA mechanism should take into account the full GHG-related content of imported goods across value chain (from the creation to the importation of the product, including transport). • Likely economic impacts EuLA supports the necessity to analyse the situation with regards to the overall value chain. Some sectors are crucial to be maintained in Europe because they create prosperity upwards and downwards. The IA should define these sectors and suggest specific protective measures, due to the key impact they have in the whole EU industry (steel might be a good example). The CBA shall also provide legal certainty, i.e. the carbon leakage list and the free allowances as a consequence, should remain intact for its intended duration. • Likely impacts on simplification and/or administrative burden The IA must analyse in detail the different elements of the administrative system to protect against import and equally, not to penalise export. International standards (e.g. ISO) should, when they exist, be applied to domestic and external production importing to Europe in order to evaluate the carbon footprint of a product and make them comparable. • Preserving the internal market The CBA mechanism must avoid any distortion of competition or discrimination between domestic production of competing products in the EU market. When evaluating the selection of different sectors that could be subject to the CBA, the IA should closely analyse this risk of distortion of competition. Lime, for example, is a strong competitor of some chemicals, with a relatively similar carbon footprint; if a CBA for lime reduces its level of free allowances, a distortion of competition in the EU domestic market will be generated without appropriate justification.
Read full response

Response to Climate Law

6 Feb 2020

A 2050 framework based on a Climate Law for everybody. EuLA acknowledges the Green Deal announcement and manifests his willingness to contribute to the debate on the European Climate Law. EuLA embraces the European Commission proposal for a first European Climate Law to enshrine the 2050 climate-neutrality target. It will contribute to ensuring the predictability and security that not only investors -but also the European lime sector- requires to remain a key enabling player in a competitive economic environment. This legislation will ensure that negotiated targets and actions are fulfilled and that no step back is taken that could undermine the credibility of the climate objective, not only at European level but also within the international context. EuLA recognises the need for a European Climate Law as a pillar of the new legislative framework to come. Our calls: • Climate Law must be inclusive and realistic: EuLA supports a net-zero greenhouse gas emission target by 2050. However, Climate Law should include all sectors of activity and preserve their global competitiveness. Any revision of the current targets should be based on robust impact assessments. Setting more stringent targets to the recently agreed climate legislation, without ensuring the correct protection of the energy-intensive sectors, which are at the basis of the economy, will undoubtedly provoke a negative impact on their economic activities. As far as the risk of carbon leakage is still present, additional measures supporting this increase in the climate target shall be set in parallel. Also, the European Commission, while leading by example, should encourage all international partners to establish similar tools globally. Climate change is a global challenge and cannot be tackled only by Europe. • Climate law should be the “leading trigger” for a ‘forward-thinking’ manner while providing the necessary means. The challenge of transformation to deliver on climate objectives for the lime sector requires important investments in modernisation and innovation. For the lime industry, due to the high share of CO2 emissions coming from the decarbonisation of the raw material (68% on average), the most important CO2 mitigation measures are “end of pipe” solutions: CCS, CCU and carbonation. Climate Law should be an enabler of these technologies through their legal recognition that will trigger additional private investments deployment in the real economy. Furthermore, provided that CCUS becomes a norm, transport of CO2 and related infrastructures still remain an issue for the lime industry. • Climate Law should bring predictability and clarity: It must provide answers to the different key actors and society. The industry needs to know how climate neutrality is calculated and how the carbon offset will be addressed within future impact assessments. In this sense, the Climate Law shall include a harmonised European definition of carbon neutrality. This will allow not only the lime sector but the energy-intensive industries as a whole, to measure the potential impact of the law and to identify areas for action to enable the transformation challenge. EuLA is ready and willing to face the climate challenge and will provide an example to other industries to contribute to the decarbonisation pathway set within the Climate Law.
Read full response

Response to Revising the rules for free allocation in the EU Emissions Trading System

8 Jul 2019

The European Lime sector (represented by EuLA) supports allocation changes starting in 2021 based on the average activity level data for the years 2020 and 2019; as the best way to align as close as possible the number of free allowances with the actual level of production. However, EuLA would like to raise the following concerns/ points for consideration as regarding the current ALC Draft (please see attached the EuLA position paper for further explanation of the 8 points): 1. Full linear approach as the most straightforward and simplest option to apply at both operation and administrative level. The full linear approach not only will make the system more dynamic but also will reduce the complexity of the IT system needed for the real calculation of activity level changes. 2. Annual reports on the activity level of each sub-installation starting in 2021, for both new entrants and incumbents. This will ensure the minimum different treatment between both in terms of timing of allocation. 3. No quantitative minimum threshold; in order to respect Article 20 of the ETS Directive. 4. Aligning the deadline for reporting verified activity level data with the deadline for submitting the verified emissions report (March 31st). It would also be convenient to set in Article 3 of the draft implementing act, the 28th February as the earliest day that national competent authorities can request the reporting verified activity level data. 5. The time-lag between measuring activity levels and receiving an updated allocation following an activity level change should be as short as possible, to prevent competitive distortions. 6. While the ALC draft appears to ensure equal treatment between new entrants and new sub-installations at incumbent sites, not all investments at incumbent sites will necessarily result in a new sub-installation. The lack of allocation from the start of normal operation of the kiln at an incumbent site, because it is not a new sub-installation, could prevent investment in the latest most energy and carbon efficient technology at existing sites. Such a large investment at an incumbent site must be treated in the same way as at a new entrant site and EuLA suggest that it is labelled as a new sub-installation to get around these issues. 7. As regarding article 5 (4) of the ALC draft, “if the activity level of a sub-installation is reported as zero, the free allocation of this sub-installation shall be set to zero in the following year”. In order to respect the ETS Directive, we ask for a clarification considering that even if the activity level is zero in any of the two years of the rolling average, those two years are still considered as the main triggering a potential allocation change. 8. Current Art.5 (4) wording has no legal basis for applying the principle of no free allocation to installations that despite no emission during a year, are not fulfilling the condition of a cessation of operation. Moreover, this provision constitutes an exception of the principle of the adaptation of allocation based on the rolling average of the two preceding years.
Read full response

Meeting with Alexandra Marten (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

19 Mar 2019 · Clean Mobility

Response to Commission Delegated Regulation establishing the Innovation Fund

11 Jan 2019

EuLA, the European Lime association welcomes the possibility to answer to the public consultation on the Commission Delegated Regulation establishing the Innovation Fund and makes the following suggestions: Comment 1. Considering that inter-operability of EU with national and regional funding schemes is essential to reach a high level of cooperation, thus, more clarity is needed on the way the innovation fund will operate with the national programmes as far as priorities and budgets are concerned. Comment 2. In the table 1 on illustrative examples of potential projects, EuLA wishes to add the following for Lime: Carbonation acceleration, a key area for research mainly for the build sector Carbonation improvement and impact on durability In CCU : qualifying CO2 gas qualities in function of the applications On energy storage : quarry environment to generate and manage renewable energy Comment 3. Regarding art. 5 on the relevant costs, we believe that the Regulation doesn’t provide the incentives to the concerned sectors to innovate as it doesn’t address adequately the risks associated to innovation. Therefore, we suggest amending article 5 (1) as follows: For the purposes of the fourth sentence of the third subparagraph of Article 10a(8) of Directive 2003/87/EC, the relevant costs shall be the costs that are borne by the project proponent as a result of the application of the innovative technology related to the reduction or avoidance of the greenhouse gas emissions. The relevant costs shall be the sum of the best estimate of the total capital expenditure and the net present value of operating costs and benefits arising during 10 years after the entry into operation of the project.
Read full response

Meeting with Miguel Arias Cañete (Commissioner) and

19 Feb 2015 · Comptetitiviness, Energy Union and ETS review