Emissions and Raw Materials

Raw Materials 

In brief 

Cement manufacturing is regulated under the Industrial Emissions Directive (IED), which sets out how to control emissions from industrial sources other than CO₂. It requires the use of Best Available Techniques (BAT), defined in BAT Reference Documents (BREFs).

Cement plants operate under permits granted by national authorities, based on the IED’s principles and provisions. These permits are guided by the BREF and its BAT conclusions, which describe applied techniques, current emission and consumption levels, and performance benchmarks.

Cement Europe takes part in the formal exchange of information expert group organised by the European Commission, contributing technical input to the regular review and update of the BREFs.

Our view

Cement Europe believes that the IED and BREFs have been instrumental in driving continuous environmental improvement across Europe. Their approach works because it is:

• Flexible, adapting to technological progress and local contexts;
• Focused on continuous improvement, encouraging innovation;
• Holistic, addressing environmental issues at plant level rather than in isolation.

Over the past decades, industrial emissions such as NOₓ and SO₂ from the European cement sector have fallen substantially. This progress has been achieved through major investments and the deployment of advanced technologies — including modern dust filters, closed material-handling systems, on-line emissions analysers, process optimisation tools, selective non-catalytic and catalytic reduction (SNCR/SCR) systems, wet scrubbers, lime injection systems, and chlorine by-pass installations.

Cement Europe considers that no policy should go beyond Best Available Techniques as defined in the IED. The industry’s performance gains have been achieved through the efficient implementation of existing EU legislation by Member States and their competent authorities. We welcome the integrated approach of the IED, which ensures that permits reflect local circumstances and assess the overall environmental performance of each plant.

Raw Materials 

In brief

The use of secondary materials is crucial to the cement and concrete industry and a key driver of circularity and decarbonisation, as outlined in the Cement Europe Net Zero Roadmap.

Secondary materials include: 

• Alternative raw materials (ARMs): Waste or by-products from other industrial processes that substitute natural raw materials in clinker production. Typical ARMs include fly ash, used foundry sand, and iron and steel residues.
• Supplementary cementitious materials (SCMs): Natural materials (e.g. limestone, pozzolans, calcined clay) or industrial by-products (e.g. blast-furnace slag, fly ash, silica fume, recycled concrete fines) that replace part of the clinker in cement or enhance the performance of concrete.
• Recycled aggregates: Secondary materials used to replace virgin aggregates in concrete, bringing significant circular economy benefits.

Key requirements for using secondary materials 

• Availability: Secure sufficient volumes of secondary materials as traditional sources (fly ash, slag) decline with the decarbonisation of steel and power sectors.
• Pre-treatment: Adapt materials to make them suitable for cement and concrete use.
• Compatibility: Ensure chemical consistency between secondary materials and clinker/cement composition.

Unlocking further potential

• Recovering resources from historic landfills for cement and concrete production.
• Reusing construction and demolition waste as suitable ARMs and SCMs.
• Promoting industrial symbiosis to identify new sources of secondary materials.

Our view

The cement industry’s goal is to increase the share of ARMs and SCMs in clinker and cement production in Europe. EU policy can support this by:

• Restricting or taxing landfill to encourage resource recovery;
• Improving separate waste collection systems to ensure quality feedstock;
• Financing the infrastructure and investment needed to enable continuous ARM supply and substitution.