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Verein Deutscher Zementwerke e.V.

VDZ

Verein Deutscher Zementwerke e.V. is a German trade association representing the interests of the cement industry.

Lobbying Activity

German cement industry demands strict parity between CBAM and ETS

25 Sept 2025
Topic — Rules for adjusting carbon border tax obligations to reflect phasing out free emissions allowances.
Message — The VDZ demands CBAM obligations be based on verified real embedded emissions. They argue deductions should strictly reflect the benchmark-based free allocation given to European producers. This ensures imported products do not receive more favorable treatment than domestic goods.12
Why — This protects European manufacturers by preventing high-carbon imports from undermining their market competitiveness.3
Impact — Non-EU importers lose financial advantages if their carbon cost deductions are strictly capped.4
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German cement association demands conservative default values for carbon imports

25 Sept 2025
Topic — Defining the methodology for calculating embedded emissions during the CBAM definitive period.
Message — The association proposes setting default values at the 80th percentile of international emissions. They also demand an additional 30% mark-up to encourage reporting of real data.12
Why — High defaults would protect European producers' competitiveness and prevent carbon leakage.3
Impact — High-emission foreign producers lose the ability to hide their carbon footprint behind low averages.4
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Response to Legislative initiative on CO2 transportation infrastructure and markets

22 Aug 2025

VDZ thanks for the opportunity to provide additional input on the development of a robust European CO infrastructure and welcomes the EU Commissions intention to establish, if necessary, a new legislative initiative with rules for an EU CO2 market and a CO2 infrastructure. This shall also consider, that time is of essence. Appropriate measures should at best speed-up, not hinder nor delay a fast built-up. We want to seize this call for evidence to provide additional comments: Integrated Networks: Combining hydrogen and CO infrastructure development, as seen in the French regulatory framework, allows resource sharing and reduces redundancy. Shared technical standards and synchronized timelines enhance efficiency and avoid duplication of efforts. Avoiding Lock-In Effects: Emphasizing pipeline planning and development from the outset is crucial to prevent lock-in to more costly and less efficient transport methods like rail and truck. Synchronized European Planning: A coordinated effort with EU-wide strategies for industrial clusters en-sures that transport and storage infrastructure timelines align seamlessly. Addressing the entire problem: Completeness of the entire CCS chain requires effective and powerful CO2 transport connections. Without this, costly large-scale CO buffering solutions would become necessary to manage operational disruptions, increasing costs and risks. De-risking Strategies: Introduce hybrid regulatory frameworks combining Third-Party Access with CfDs to provide financial security for early investments. Especially, large initial infrastructure investments with a multi-decadal scale for refinancing require to mitigate a risk of future policy or target changes. A dedicated de-risking strategy for CO2 infrastructure investments can in return establish trust for the joint effort and EU policy. Transparent Funding Mechanisms: A centralized EU funding portal can streamline stakeholder access to resources, ensuring equitable support across Member States and attracting private capital. Public Risk-Taking: Public-private partnerships and co-funding models can provide a balanced approach to sharing risks and rewards. Support for Demand Aggregation Platforms: Facilitate a European-wide platform to align capture, transport, and storage timelines. Accelerated Approvals: Simplified permitting processes under frameworks like the NZIA can ensure timely project execution. Introducing overarching EU guidelines for cross-border projects will further mitigate delays. Alignment with Existing Frameworks: Incorporate CO transport into the Ten-Year Network Development Plan (TYNDP) to ensure compatibility with hydrogen and natural gas network planning and efficient repurposing of gas pipeline infrastructure for CO or hydrogen. Integrated Logistics: While pipelines should be prioritized, multimodal solutions including rail and barge transport can serve as interim and complementing measures. Planning should prioritize pipelines while ensuring that interim multimodal solutions complement long-term goals. Regional Collaboration: Partnerships with non-EU countries, such as Norway and the UK, will be crucial for accessing additional storage capacity and achieving economies of scale. Flexibility in Cross-Border Regulations: Ensure mutual recognition of ETS systems and develop bilat-eral agreements to address legal and technical gaps for CO transport and storage between the EU and neighboring countries. VDZ explains the key requirements for a CO infrastructure in a detailed study on Germany highlighting the need for connections neighbouring countries. The English-language executive summary is attached. The full study (in German) is available here: https://www.vdz-online.de/zementindustrie/klimaschutz/co2-infrastruktur VDZ looks forward to continued collaboration and welcome any further opportunities to contribute to the development of a resilient and efficient CO infrastructure.
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German cement industry demands competitiveness safeguards for 2040 climate targets

25 Jul 2025
Topic — The initiative establishes a 2040 climate target to ensure European climate neutrality.
Message — The sector calls for the full implementation of the Clean Industrial Deal to ensure competitiveness. They request lower electricity costs and stronger anti-circumvention measures within the carbon border tax. Additionally, they advocate for significant simplifications of EU regulation, especially regarding environmental law.1234
Why — These proposals would lower operational expenses and shield domestic producers from low-cost international competition.56
Impact — Foreign exporters face tougher entry requirements and higher costs to prevent bypassing carbon taxes.7
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German cement association urges recognition of biogenic CO2 capture

7 Jul 2025
Topic — Review of the EU emissions trading system and its market stability reserve rules.
Message — The association seeks the recognition of biogenic CO2 capture under the EU ETS. Current legal uncertainty prevents final investment decisions for industrial carbon capture projects. They want accounting to cover total emissions generated by an installation.12
Why — Clear rules provide the economic incentives needed to scale up industrial carbon capture.34
Impact — Companies using sustainable biogenic fuels face unfair treatment and significant legal uncertainty.56
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Meeting with Jens Gieseke (Member of the European Parliament)

15 Apr 2025 · Austausch zu EU Politik

Meeting with Peter Liese (Member of the European Parliament) and Fertilizers Europe

6 Mar 2025 · Austausch

Meeting with Andrea Wechsler (Member of the European Parliament) and FIA European Principal Traders Association, part of FIA, Inc. and Raízen SA

25 Feb 2025 · EU Energy and industry policy

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

Meeting with Christian Ehler (Member of the European Parliament)

23 Jan 2025 · European Industrial Policy

German cement industry warns of barriers to carbon capture

26 Jul 2024
Topic — The European Commission is updating greenhouse gas monitoring rules for emissions trading.
Message — VDZ requests removing proportionality requirements that hinder reaching installation-level carbon neutrality. They also seek realistic measurement standards and broader recognition of carbon reuse.12
Why — Flexible rules would lower compliance costs and encourage investments in decarbonisation.3
Impact — Climate targets could be compromised if measurement accuracy requirements are lowered.4
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Meeting with Peter Liese (Member of the European Parliament) and Pharma Deutschland e.V

12 Jan 2024 · Austausch

German cement industry seeks ETS inclusion for carbon removals

23 Mar 2023
Topic — The European Commission proposal aims to certify sustainable carbon removals through robust accounting.
Message — The industry calls for separating technical sinks from natural ones to ensure accounting reliability. They want carbon removal units integrated into the carbon market to provide investment certainty. Additionally, only permanent storage solutions should be acknowledged.123
Why — This would provide financial incentives and legal certainty for expensive carbon capture investments.4
Impact — Environmental groups may see weakened safeguards if sustainability criteria are relaxed for industrial projects.5
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and Germanwatch and

11 Jan 2023 · ETS

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

21 Oct 2022 · ETS

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

14 Oct 2022 · ETS

German cement association demands removal of 2035 carbon reuse deadline

17 Jun 2022
Topic — EU methodology for calculating greenhouse gas savings from renewable and recycled carbon fuels.
Message — VDZ requests removing the 2035 end date for synthetic fuels using captured industrial carbon. They want the Commission to differentiate between avoidable and unavoidable industrial emissions sources.12
Why — This would provide the long-term legal certainty needed for expensive carbon capture investments.34
Impact — Environmental interests are harmed as blocking carbon reuse leads to higher atmospheric emissions.56
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and Bund für Umwelt und Naturschutz Deutschland e. V.

24 May 2022 · ETS

Meeting with Jens Geier (Member of the European Parliament) and Industriegewerkschaft Bergbau, Chemie, Energie

28 Apr 2022 · ETS, CBAM

Meeting with Delara Burkhardt (Member of the European Parliament) and Industriegewerkschaft Bergbau, Chemie, Energie

28 Apr 2022 · CBAM

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

12 Apr 2022 · ETS Revision

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Siehe beigefügte Stellungnahme.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

Siehe beigefügte Stellungnahme.
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German cement industry urges dual carbon protection and export help

18 Nov 2021
Topic — The European Union is establishing a mechanism to price carbon on imported goods.
Message — VDZ wants the border tax to complement, not replace, existing free allowances. They demand strict emission verification for imports and compensation for indirect power costs.123
Why — This dual protection shielding ensures domestic producers maintain market share while receiving subsidies.45
Impact — Foreign exporters from neighboring countries face increased tariffs and complex verification requirements.67
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German cement industry demands support for carbon capture tech

8 Nov 2021
Topic — This consultation reviews the EU Emissions Trading System to achieve 2030 climate goals.
Message — VDZ demands the directive fully enables carbon capture and synthetic fuel production. They also argue against linking free allowances to mandatory energy audit recommendations.12
Why — The proposals would shield German cement manufacturers from steep operational costs and foreign competition.3
Impact — Consumers in the building and transport sectors might see prices rise to fund industrial relief.4
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German cement association VDZ urges linear approach for emission allocations

9 Jul 2019
Topic — The consultation revises EU Emissions Trading System rules for determining free carbon allowance allocations.
Message — VDZ advocates for a linear approach to ensure allocation precisely reflects actual activity levels. They request that data requirements for reports be drastically reduced to avoid excessive administrative burden.12
Why — This would prevent significant financial losses from under-allocation and minimize administrative compliance costs.34
Impact — Market participants face competition distortions if production changes within fixed intervals trigger unfair allocation levels.5
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German cement industry seeks flexible Innovation Fund rules

11 Jan 2019
Topic — Regulation establishing the Innovation Fund to support breakthrough low-carbon technology projects.
Message — VDZ requests more flexible selection criteria that recognize the potential for future emission avoidance. They advocate for a gradual approach to carbon capture instead of requiring immediate full-chain implementation.123
Why — This allows individual capture projects to secure funding without needing immediate, expensive transport infrastructure.4
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German cement industry seeks streamlined EU emission allocation rules

17 Apr 2018
Topic — Revision of rules for determining free emission allocations in the EU ETS.
Message — The association proposes using the median for production data and combining reporting tasks. They also suggest delaying deadlines to ensure allocations are based on verified data.123
Why — Streamlined reporting and delayed deadlines would lower administrative costs and compliance complexity.4
Impact — Transparency advocates lose insight into industrial performance as data remains confidential.5
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