CEMBUREAU

CEMBUREAU, the European Cement Association, welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment on a legislative proposal on substantiating green claims. Please find attached a position paper which sets out our views. We hope this can serve as a basis for future exchanges and will be very happy to engage.

Carbon border adjustment mechanism (CBAM) methodology for the definitive period starting on 1 January 2026 1. Direct embedded emissions based For the cement sector the Monitoring and Reporting Regulation for the EU ETS and its implementation documents must be the basis for the determination of these emissions.

Cement Europe welcomes the draft implementation act for the Digital Product Passport Registry. We would like to suggest using a simpler, easier to understand English as some sentences/paragraphs are hard to understand.

POSITION PAPER Ref. Ares(2025)7611054 - 11/09/2025 CEMBUREAU’S FEEDBACK TO THE EC CALL FOR EVIDENCE FOR THE CO2 MARKET AND INFRASTRUCTURE IN THE EU Brussels 11-09-2025 CEMBUREAU, the European Cement Association (www.cembureau.eu), welcomes the opportunity to comment on the EC’s call for evidence for the CO2 market and infrastructure in the EU.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Tackling the objectives of accelerating the development of harmonised standards. Case of Construction Products. The overall process is based on two pillars, conducted successively: - legal process with CPR Acquis to prepare a Standardisation Request (SReq) - technical process with the European Standardisation Organisations (ESOs), including legal control (HAS consultant), to prepare product standards 1.

In view of simplicity and consistency of the legislation, Cement Europe firmly suggests that the clarification described in the EC Guidance Document Biomass and other zero-rating under the EU ETS version 3, will also be included to the Annexes V and VI of the Renewable Energy Directive (RED). Please find more details in the attached Cement Europes position paper.

The Free Allocations to the cement sector in the EU ETS are from January 2026 based on the binder benchmark, covering both clinker and 4 alternative hydraulic binders. For the period 2026 2034, the free allocations are reduced by the CBAM reduction factor and the Cross Sectoral Correction factor. The EU ETS allocations and benchmark are per 1 January 2026 based on the binder benchmark.

The EU ETS implementation rules are becoming more challenging and complex with every revision of the directive. One example is the CO2 that is not emitted, and which is now part of the EU ETS coverage and needs to be reported on. Similarly, smaller emissions that are allocated for free on basis of a high benchmark that is covering products that have never been part of the carbon leakage assessment.