CEMBUREAU

With regard to the Commission’s IIA, CEMBUREAU has the following comments: • Regardless of the level of ambition for 2030, it is absolutely essential that a thorough impact assessment is conducted by the European Commission to determine the different policy options to reach these targets and their consequences.

CEMBUREAU, the association of the European cement industry, welcomes the opportunity to provide feedback on the Commission’s inception impact assessment on the revision of the Energy Performance of Buildings Directive. CEMBUREAU’s 2050 Carbon Neutrality Roadmap, which was published in May 2020, sets out the cement industry’s ambition to reach net zero emissions along the cement and concrete value chain by 2050.

Position Paper CEMENT EUROPE FEEDBACK ON THE REVISED EUROPEAN SUSTAINABILITY REPORTING STANDARDS 3 June 2026 Cement Europe welcomes the opportunity to provide comments on the revised European sustainability reporting standards, based on the input received from its members.

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

CEMBUREAU’S RESPONSE TO THE ROADMAP ON THE “EUROPEAN CLIMATE LAW – ACHIEVING CLIMATE NEUTRALITY BY 2050” CEMBUREAU, the European Cement Association, is determined to contribute strongly to the EU’s vision for a carbon neutral society by 2050 and supports the objectives of the European Green Deal.

CEMBUREAU’S RESPONSE TO THE ROADMAP ON THE “EUROPEAN CLIMATE LAW – ACHIEVING CLIMATE NEUTRALITY BY 2050” CEMBUREAU, the European Cement Association, is determined to contribute strongly to the EU’s vision for a carbon neutral society by 2050 and supports the objectives of the European Green Deal.

Carbon removals in the cement and concrete value chain offer significant potential to support the EUs transition to carbon neutrality. In CEMBUREAUs view, it is essential that the EU carbon removal framework is based on a science-based approach and clear definitions.

CEMBUREAU and the cement industry CEMBUREAU (www.cembureau.eu), the European Cement Association, is the representative organisation of the cement industry in Europe. Our 2050 Net Zero Roadmap published in May 2020, and revised in 2024, aligns the cement industrys decarbonisation pathway with the EU Green Deal and Clean Industrial Deal objectives and spans the full value chain, from production of clinker and cement…

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.

CEMBUREAU, the European Cement Association, welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment (IIA) on the Sustainable Products Initiative. The European Green Deal explicitly recognises the cement industry as essential to the EU economy as it supplies several key value chains.

CEMBUREAU welcomes the Commission’s draft Regulation on CBAM as a key opportunity to drive deeper CO2 emissions globally while equalising carbon costs between EU and non-EU suppliers. The European cement industry is exposed to carbon leakage, a trend that will be exacerbated as the EU increases its climate ambition.

CEMBUREAU, the European Cement Association (www.cembureau.eu), welcomes the idea of a carbon border mechanism as a key opportunity to enable the industry to help deliver the EU’s carbon neutrality objectives, and drive deeper CO2 emissions’ cut in the EU and beyond: • The European cement industry already faces a strong risk of carbon leakage despite the partial free allocation provided under the EU Emission Trading…

CEMBUREAU supports the review of the Emission Trading Scheme (ETS) to align it with an increased climate ambition. The reform is important to provide the right market signals to enable the industrial transition, which will require significant investments from the European industry. With this in mind, we highlight in this paper a number of key aspects that are essential to strengthen the draft ETS Directive.

The European cement industry is committed to achieve carbon neutrality by 2050 as set out in CEMBUREAU Carbon Neutrality Roadmap outlining the CO2 reduction pathways in clinker/cement manufacturing and in production/use/end-of-life of its end-product, concrete. Concrete is a key building material for tomorrow’s sustainable built environment thanks to its durability, strength, recyclability and carbonation potential.

The European Cement Association CEMBUREAU welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment on the review of the CPR. CEMBUREAU ranks the revision of the Construction Products Regulation (CPR) high on its priorities, given the importance of this file for our sector.

We welcome the possibility to provide views on the revision of the CLP regulation published on 19 December and embrace the main objectives of the revision. CEMBUREAU would like to share the following preliminary comments from members related to the minimum requirements for labels. This also appears to be a view from several stakeholders. 1.

20.04.2020 CEMBUREAU’s feedback to the Industrial Emissions EU rules update CEMBUREAU, the European Cement Association (www.cembureau.eu), takes note of the Inception Impact Assessment and the opportunity to provide feedback to the industrial emissions rules update.

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

CEMBUREAU welcomes the possibility to give feedback on the ideas for the roadmap towards nature credits. Our main points are: 1. Strong ambition is conveyed in the tools presented in the note, but few guarantees or encouraging studies on the actual market potential are provided. 2. The ambition is described in vague terms, with little reassurance offered to issuers, buyers, or certifiers.

CEMBUREAU welcomes the possibility to give feedback on the roadmap towards nature credits. In general we agree to the concept, but still we have some remarks. 1. The strong ambition is conveyed in the tools presented in the note, but few guarantees or encouraging studies on the actual market potential are provided. 2.

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.

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.

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)

CEMBUREAU, the European Cement Association (www.cembureau.eu), welcomes the Inception Impact Assessment and the opportunity to provide feedback to the Waste Shipment rules revision. The European cement industry is a large user of waste and by-products utilizing approximately 35 million tonnes per year.

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 European Cement Association CEMBUREAU welcomes the opportunity to provide feedback on the Commission inception impact assessment on empowering the consumer for the green transition. CEMBUREAU agrees with the consumer law initiative announced in the Green Deal to provide consumers the ability to make sustainable choices based on trustful environmental information and green claims.

CEMBUREAU POSITION PAPER ON INCEPTION IMPACT ASSESSMENT ON POP LIMIT VALUES IN WASTE Brussels,04/08/2020 The European cement industry is a large user of waste and by-products utilizing approximately 35 million tonnes per year to replace fuels and raw materials. In the EU, the sector substitutes on average 46% of its fossil fuel consumption with secondary materials such as non-recyclable waste or biomass waste.

CEMBUREAU welcomes the proposed revision of the rules for monitoring and reporting emissions (MRR) for the EU ETS. The European cement industry has laid out its decarbonisation ambition in its 2050 Carbon Neutrality Roadmap published in May 2020. A significant lever for the emissions reductions in the cement industry in the EU27 will come from the use of materials with biogenic sources.

CEMBUREAU, the European Cement Association (www.cembureau.eu), takes note of the Inception Impact Assessment and the opportunity to provide feedback to the European Pollutant Release and Transfer Register (E-PRTR) rules update. CEMBUREAU firmly supports the objectives of the European Green Deal and is determined to contribute strongly to the EU’s vision for a carbon neutral society by 2050.

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.