Cement, glass and ceramics · Checklist

CBAM Regulation Regulation (EU) 2023/956 In force Key date:2026-01-01

• Obtain the status of authorised CBAM declarant Registration as an authorised CBAM declarant with the competent authority of a Member State is required before import. Trigger:Importing goods covered by CBAM (steel, aluminium, cement, fertilisers, hydrogen, electricity) · Evidence:Authorised declarant decision, registration details · Timing:Before import
• Submit the annual CBAM declaration Declare the quantity of imported goods, embedded emissions and carbon price paid. Trigger:Each quarter/year in which goods are imported as an authorised declarant · Evidence:CBAM declaration, supplier emissions data, verification documents · Timing:After each quarter; annual declaration by 30 September
• Purchase and surrender CBAM certificates Purchase and surrender CBAM certificates according to embedded emissions; the price is linked to the weekly average EUA price. Trigger:Embedded emissions confirmed in the annual declaration · Evidence:Certificate holding and surrender records, cancellation certificate · Timing:Surrendered after the annual declaration
• Use actual emissions data rather than default values Use of default values is restricted; verified actual emissions data from the production installation must be obtained. Trigger:Importers wishing to reduce certificate costs · Evidence:Verified emissions data provided by the producer, production route description · Timing:From the definitive period starting in 2026

CBAM Simplification Amendment Regulation (EU) 2025/2083 In force Key date:2025-10

• Apply the 50 t de minimis exemption An exemption applies where the total net weight of CBAM goods imported by a single importer in a calendar year does not exceed 50 t. Trigger:Imports of steel, aluminium, cement and fertilisers (aggregated) · Evidence:Import ledger, annual total net weight · Timing:After the 2024/2025 simplification enters into force
• Declare under the simplified rules and use default values The delegated act relaxes certain declaration fields and the use of default values. Trigger:CBAM declarants · Evidence:Simplified declaration records · Timing:After 2025/2083 enters into force

EU ETS Directive Directive 2003/87/EC In force Key date:2003

• Obtain a greenhouse gas emissions permit Before operating an installation covered by the ETS, obtain a GHG emissions permit from the competent authority of the Member State and draw up a monitoring plan. Trigger:Operating an activity listed in Annex I to the ETS Directive (power generation, energy-intensive industry, aviation, etc.) · Evidence:GHG emissions permit, monitoring plan · Timing:Obtained before operation; valid on a continuing basis
• Monitor and report annual emissions Calculate in accordance with the MRR and submit an annual emissions report after verification by an accredited verifier. Trigger:Each operating year in which an emissions permit is held · Evidence:Monitoring methodology document, verified annual emissions report (AVR) · Timing:Submitted by 31 March of the following year
• Surrender a sufficient number of allowances Surrender EUAs equal to annual emissions; in case of a shortfall, a penalty of €100/t applies and the allowances must still be surrendered. Trigger:Annual emissions verified and confirmed · Evidence:Allowance account surrender records, cancellation certificate · Timing:By 30 September of the following year

ETS Transitional Rules for Free Allocation Delegated Reg (EU) 2019/331 (as amended by 2024/873) In force Key date:2019 / 2024

• Submit activity level data and an allocation application Apply for free allocation under the benchmark method and submit a verified baseline-year activity level report (HAR). Trigger:Installations eligible for free allocation · Evidence:Verified activity level report, monitoring methodology documents · Timing:Each year of the allocation period (free allocation until 2030)
• Comply with the monitoring and reporting requirements as amended by 2024/873 The free allocation rules are simplified, but product benchmarks must be monitored under the latest methodology. Trigger:Installations receiving free allocation · Evidence:Updated monitoring methodology documents · Timing:After 2024/873 enters into force

Industrial Emissions Directive IED 2.0 Directive (EU) 2024/1785 In force Key date:2026-07-01 transposition

• Obtain an IED integrated permit and comply with BAT Operate in accordance with best available techniques (BAT/BREF) and apply an environmental management system. Trigger:Industrial activities listed in Annex I to the IED · Evidence:IED permit, BAT compliance assessment, environmental management system · Timing:After transposition of 2024/1785
• Submit a transformation plan The new IED requires high-emission installations to provide a decarbonisation transformation plan. Trigger:Energy-intensive installations subject to the IED · Evidence:Decarbonisation transformation plan · Timing:After transposition of 2024/1785

State Aid Guidelines on Indirect Cost Compensation (EEI) Guidelines on EEI compensation In force Key date:continuous

• Design indirect cost compensation in line with the EEI Guidelines Member State compensation for indirect electricity costs must comply with the State aid guidelines. Trigger:A Member State establishes an electricity indirect cost compensation scheme · Evidence:Member State aid notification, European Commission approval · Timing:2025–2030

Landfill Directive Directive 1999/31/EC In force Key date:1999 (as amended by 2018/850)

• Only treated waste may be landfilled Except for inert waste that cannot technically be treated, waste must be treated before landfilling. Trigger:Operating a landfill · Evidence:Pre-treatment records, acceptance inspections and ledger · Timing:Ongoing
• Reduce landfilling of biodegradable municipal waste Reduce in stages to 75%, 50% and 35% against the 1995 baseline. Trigger:Landfilling biodegradable municipal waste · Evidence:Landfill volume statistics, compliance evidence · Timing:Phased (1995 baseline)
• Obtain a landfill permit and control leachate and landfill gas Meet technical operating requirements for siting, lining, leachate and landfill gas collection. Trigger:Constructing or operating a landfill · Evidence:Operating permit, leachate and landfill gas management records · Timing:Before operation and on a continuing basis

Mining Waste Directive Directive 2006/21/EC In force Key date:2006

• Prepare an extractive waste management plan Prevent or minimise waste generation and ensure its safe disposal. Trigger:Generating or managing extractive waste · Evidence:Waste management plan, waste classification and ledger · Timing:Before operation and on a continuing basis
• Apply major accident prevention measures at Category A facilities Waste facilities classified as Category A by the competent authority must establish a major accident prevention policy and emergency procedures. Trigger:Facility classified as Category A · Evidence:Major accident prevention policy, emergency plan and drill records · Timing:Before operation

Construction Products Regulation (CPR) Regulation (EU) 2024/3110 In force Key date:2024 (phased application from 2026-01-08)

• Draw up a declaration of performance and conformity (DoPC) Construction products placed on the market must be accompanied by a declaration and technical documentation. Trigger:Placing construction products on the EU market · Evidence:DoPC, technical documentation and test reports · Timing:Phased from 2026-01-08
• Disclose life-cycle environmental performance Disclose life-cycle environmental sustainability performance for declared environmental basic characteristics. Trigger:Declaring environmental basic characteristics · Evidence:LCA results, results from the Commission's free software · Timing:Phased 2026 / 2030 / 2032
• Meet environmental, functional and safety product requirements Products must meet the prescribed environmental, functional and safety requirements and complete the corresponding conformity assessment. Trigger:Product placed on the market · Evidence:Performance testing, conformity assessment records · Timing:Ongoing