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Fels-Werke

Gewinnung und Veredelung von Kalk- und Kalksteinprodukten.

Lobbying Activity

Meeting with Oliver Schenk (Member of the European Parliament) and Dow Europe GmbH and CEMEX, S.A.B. de C.V.

3 Mar 2025 · Chemical industry in the EU

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

17 Dec 2020

We agree with the statements made by our association. 1. Determining the lime/dolime 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. In addition, very high investments are required for the use of biomass. 2. The artificial extension of the improvement factor is inappropriate in the lime 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 installation. Mutatis mutandis, applying the provision of art 16 FAR 2e to the process emission’s share could be a fair way to address this very particular case. 3. EC proposal 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.
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