Cembureau calls for amendments EC draft Act

Cembureau, the European cement association, has commented on the European Commission’s draft Delegated Act on permanent emissions storage through carbon capture and utilisation (CCU).

Significant research has been carried out into the topic of mineralisation as a permanent form of CO₂ storage and an increasing number of companies are planning to store CO₂ in concrete or aggregates, sometimes even offering carbon removals through the use of biogenic CO₂.  But Cembureau would welcome recognition in the draft Delegated Act that mineralisation, through construction products, is a permanent form of storage. When it comes to the annex, Cembureau would however suggest the following changes:

• Cembureau would include carbonated constituents of other construction products than cement and concrete as part of the list.
• “Carbonated constituents of hydraulic binder (such as masonry cement, hydraulic road binder) used in construction products” should be added to the list, to ensure that it includes carbonated constituents, such as recycled concrete fines.
• Similarly, “carbonated constituents of lime with hydraulic properties used in construction products” should also be added. 

While today, the majority of carbon capture projects in the EU cement sector aims at capturing the CO₂ and storing it geologically (CCS), the sector is also looking at the utilisation of CO₂ in products (CCU). CCU is indeed vital for many EU cement kilns which are landlocked and not located next to CO₂ storage sites, claims Cembureau. 

Cembureau claims that the Delegated Act is overly prescriptive on other forms of ‘permanent’ CCU. However, Cembureau says the draft Delegated Act is overly restrictive in setting a requirement that “CO₂ should remain permanently chemically bound in a product for at least a period of several centuries or longer”, which prohibits any other type of long-term storage in other types of products (eg chemical products), even when these would be part of a recycling loop. Cembureau considers that, provided chemical products are part of a recycling loop, the putting of CO₂ in chemicals should be considered as permanent storage.

Cembureau notes that the ETS Directive foresees a review clause to ‘assess the accounting’ of CO₂ used in non-permanent CCU applications. Cembureau believes it is very important that this clause is taken up in the future review of the ETS, in light of the expansion of the ETS to other sectors (full aviation coverage, waste incineration, etc), which should allow to account emissions at the point of release. 

Furthermore, Cembureau wishes to highlight the urgency of reviewing provisions of the Draft Regulation setting out a methodology for GHG emission savings from renewable fuels of nonbiological origin (RFNBOs) and recycled carbon fuels (RCFs). The act, in its current form, considers that CO₂ emissions from industrial sources will no longer be considered as avoided for RFNBOs production past 2040. This has halted CCU projects in the European cement industry.