Concrete Europe welcomes the Commission proposal for a regulation establishing the EU-wide voluntary framework that would certify high-quality carbon removals (CRCF). It will provide the necessary rules to assess which carbon removals will be eligible for certification.

Concrete is a versatile product which allows promoters, architects, engineers and builders to build for public and private owners sustainable, durable and resilient buildings and infrastructures.

Concrete also has the ability to take up CO2 through mineralisation of the cement it contains. That process, called carbonation, happens naturally throughout the lifetime of buildings or infrastructures, and the IPCC qualified it as a carbon sink in 2021¹. This chemical reaction can also be enhanced at two different stages of the concrete life-cycle:

1. when concrete is being made via injecting CO2 during the manufacturing process (e.g. curing) and
2. at the end-of-life phase of concrete, when absorption of CO2 into the crushed concrete can be enhanced for the production of aggregates.

Concrete Europe believes that concrete carbonation activities qualify as carbon removal activities when the source is not industrial, due to the fact that aggregates and concrete producers can permanently store carbon in their products through mineralisation².

The enhanced carbonation of concrete is a new field of research at EU and national level and start-ups are already developing carbon removal activities in the EU and outside of Europe. We provide a non-exhaustive list of those projects and companies in Annex (see below).

These new activities have a great potential of CO2 removal, as some of these companies put forward the number of 500 Mt of CO₂ per year³. But in order to reach their full potential, they need to be supported by a clear legal framework, a sufficient supply of biogenic and direct air carbon at reasonable price and the recognition of permanent storage as the only viable solution for their access to captured CO2.

Concrete Europe also wants to underline that, according to our reading of the Commission proposal, temporary carbon storage does not qualify as a carbon removal activity since the carbon is emitted at the end of life.

We are ready to continue contributing to the development of carbon removals certification in months to come through our participation to the Commission expert group on Carbon removals.

ANNEX

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