Verein Deutscher Zementwerke (VDZ)

Regarding the proposed 5 % tolerance for systematic differences between emissions covered by third-country carbon pricing systems and CBAM boundaries, the current wording lacks clarity concerning its practical application (Recital 7; Annex I, Section 4.2). It remains unclear whether this flexibility would favour or disadvantage non-EU installations compared to EU ETS installations.

A central principle of CBAM must be to establish a strong incentive for importers to report their verified real embedded CO2 emissions by defining highly conservative default values. If standard values are set low or average, importers of highly emission intensive products will simply rely on these defaults rather than disclosing verified data.

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.

The German Cement Works Association (VDZ) fully supports the Carbon Border Adjustment Mechanism (CBAM) as a cornerstone of EU climate and industrial policy and prerequisite for deployment of climate-neutral technologies.