Next steps and recommendations
3. Manufacture of the following products (with thresholds where appropriate) for energy efficient equipment for buildings and their key
3.6 Manufacture of other inorganic basic chemicals
Sector classification and activity Macro-Sector C – Manufacturing
NACE Level 4
Code C20.1.3
Description • Manufacture of carbon black
• Manufacture of disodium carbonate (soda ash)
• Manufacture of chlorine CPA codes:
• Carbon black: 20.13.21.30
• Disodium carbonate (soda ash): 20.13.43.10
• Chlorine: 20.13.21.11 Mitigation criteria
Principle Reducing the emissions from the manufacturing of carbon black and soda ash and improving energy efficiency and switching to low carbon electricity210 in the manufacturing of chlorine can positively contribute to the climate change mitigation objective.
Mitigation measures are eligible provided they are incorporated into a single investment plan within a determined time frame (5 or 10 years) that outlines how each of the measures in combination with others will in combination enable the activity to meet the threshold defined below actions
Threshold Manufacturing of carbon black and soda ash are eligible if the GHG emissions (calculated according to the methodology used for EU-ETS benchmarks) associated to the production processes are lower than the values of the related EU-ETS benchmarks.
As of February 2020, the EU-ETS benchmarks values are:
• For carbon black: 1.954 tCO2e/t
• For soda ash: 0.843 tCO2e/t
Manufacturing of chlorine is eligible if the two following thresholds are met:
• Electricity use for chlorine manufacturing is at or lower than 2.45 MWh/t Chlorine (includes both electrolysis and chlorine treatment, threshold subject to periodical update) 211
210 See page 40
https://dechema.de/dechema_media/Downloads/Positionspapiere/Technology_study_Low_carbon_energy_and_feedstock_for_the_
European_chemical_industry-p-20002750.pdf
211 https://www.eurochlor.org/wp-content/uploads/2019/04/12-electrolysis_production_costs.pdf
• Average carbon intensity of the electricity that is used for chlorine manufacturing is at or below 100 gCO2e/kWh (Taxonomy threshold for electricity production, subject to periodical update).
Rationale
The manufacturing process of carbon black accounts for approximately 3.4% of the GHG emissions from the chemical sector, while the manufacturing of soda ash accounts for 1.5% of the emissions.212
The manufacturing process of chlorine is extremely energy-intensive, with chlor-alkali process accounting for 17% of total electrical consumption of the European chemical and petrochemical industry.213
Reducing the manufacturing emissions for carbon black and soda ash and improving energy efficiency in the manufacturing of chlorine can positively contribute to the mitigation objective. Moreover it is recognised that soda ash used in double glazing can enhance building efficiency gains.
The absolute performance approach has been proposed in order to identify the maximum acceptable carbon intensities of the manufacturing processes of carbon black and soda ash that the activities should comply with in order to be able to substantially contribute to the mitigation objective.
For the manufacturing of chlorine, a process that uses electricity to fuel the electrolysis process, the absolute performance approach has been proposed in order to identify the energy intensity threshold. In addition to complying with the energy efficiency threshold, the process shall be based on low carbon electricity.
ETS product benchmarks have been selected as thresholds for the manufacturing of carbon black and soda ash. They reflect the average performance of the 10% most efficient installations in a sector.
Emissions covered:
− Scope 1: All direct emissions related to the production (the process direct emissions and the emissions due to fuel use for energy production).
− Note on the electricity:
According to the methodology to calculate ETS benchmarks, emissions from electricity are considered where direct emissions and indirect emissions from electricity are to a certain level interchangeable (as is the case for carbon black but not for soda ash).214
For chlorine, the value corresponding to an efficient level of electricity consumption was selected as the threshold given that the main source of energy used for the production of chlorine is electricity and by improving the energy efficiency of the process, as well as using low carbon electricity sources, the activity can substantially contribute to the climate change mitigation objective.
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2012:387:0005:0013:EN:PDF https://epub.wupperinst.org/frontdoor/deliver/index/docId/6478/file/6478_Lechtenboehmer.pdf
212 Page 14 http://publications.jrc.ec.europa.eu/repository/bitstream/JRC105767/kj-na-28471-enn.pdf 213 page 11 http://eippcb.jrc.ec.europa.eu/reference/BREF/CAK_BREF_102014.pdf
214 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32011D0278&from=EN https://ec.europa.eu/clima/sites/clima/files/ets/allowances/docs/gd9_sector_specific_guidance_en.pdf
EU average data reported in a CEPS desk study. (CEPS, Ares(2014) 174266-27/01/2014) BREF:
http://eippcb.jrc.ec.europa.eu/reference/BREF/lvic-s_bref_0907.pdf http://eippcb.jrc.ec.europa.eu/reference/BREF/CAK_BREF_102014.pdf
Provisions to determine the benchmarks in the period from 2021 to 2025 and for the period from 2026 to 2030 are included in Art. 10a, paragraphs 2(a) and 2(c) of the Directive 2003/87/EC.
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02003L0087-20180408&qid=1547917622180&from=EN
The DNSH assessment is split across the three chemicals:
• Manufacture of carbon black
• Manufacture of disodium carbonate (soda ash)
• Manufacture of chlorine
Do no significant harm assessment Manufacture of carbon black
The main potential significant harm to other environmental objectives from the manufacture of carbon black is associated with:
• polluting emissions to air, especially volatile organic compounds (VOC) and dust;
• the use of water in water stressed areas for cooling purposes; and
• the generation of wastes.
(2) Adaptation • Refer to the screening criteria for DNSH to climate change adaptation.
(3) Water • Identify and manage risks related to water quality and/or water consumption at the appropriate level. Ensure that water use/conservation management plans, developed in consultation with relevant stakeholders, have been developed and implemented.
• In the EU, fulfil the requirements of EU water legislation.
(4) Circular Economy
Wastes and by-products, especially hazardous manufacturing wastes, are managed in line with the Waste Treatment BREF and the requirements set out in BREF LVIC- S (Large Volumes Inorganic Chemicals- Solids and others Industry).
(5) Pollution Ensure polluting emissions to air are within BAT-AEL ranges set in the BREF LVIC- S (Large Volumes Inorganic Chemicals- Solids and others Industry).
A stringent level of BAT-AEL is required if an activity materially contributes to local air pollution levels, exceeding air quality standards
(6) Ecosystems Ensure an Environmental Impact Assessment (EIA) has been completed in accordance with the EU Directives on Environmental Impact Assessment (2014/52/EU) and Strategic Environmental Assessment (2001/42/EC) (or other equivalent national provisions or international standards (e.g. IFC Performance
Standard 1: Assessment and Management of Environmental and Social Risks) – whichever is stricter - in the case of sites/operations in non-EU countries) for the site/operation (including ancillary services, e.g. transport infrastructure and operations, waste disposal facilities, etc.) and any required mitigation measures for protecting biodiversity/eco-systems, particularly UNESCO World Heritage sites and Key Biodiversity Areas (KBAs), have been implemented.
Do no significant harm assessment
Manufacture of disodium carbonate (soda ash)
The main potential significant harm to other environmental objectives from the manufacture of soda ash is associated with:
• the generation of process effluents (e.g. calcium chloride in aqueous solution), by products and wastes with the potential to pollute groundwater and surface water bodies as well as soils;
• polluting air emissions;
• the use of water in water scarce areas for cooling purposes; and
• impacts on ecosystems and biodiversity from the disposal of wastes and by-products (primarily calcium carbonate, gypsum, sodium chloride and calcium chloride, although there can be trace amounts of toxic materials such as mercury, cadmium, arsenic and zinc depending on the source of the raw materials (e.g. limestone) for the production process) which create ‘waste beds’.
(2) Adaptation • Refer to the screening criteria for DNSH to climate change adaptation.
(3) Water • Identify and manage risks related to water quality and/or water consumption at the appropriate level. Ensure that water use/conservation management plans, developed in consultation with relevant stakeholders, have been developed and implemented.
• In the EU, fulfil the requirements of EU water legislation.
(4) Circular Economy
Wastes and by-products, especially hazardous wastes, are managed in line with the BREF for Waste Treatment and the requirements set out in BREF LVIC- S (Large Volumes Inorganic Chemicals- Solids and others Industry).
(5) Pollution Ensure polluting emissions to air and water are within BAT-AEL ranges set in the BREF LVIC- S (Large Volumes Inorganic Chemicals- Solids and others Industry).
The most stringent level of BAT-AEL is required if an activity materially contributes to local air pollution levels, exceeding air quality standards (6) Ecosystems Ensure an Environmental Impact Assessment (EIA) has been completed in
accordance with the EU Directives on Environmental Impact Assessment (2014/52/EU) and Strategic Environmental Assessment (2001/42/EC) (or other equivalent national provisions or international standards (e.g. IFC Performance Standard 1: Assessment and Management of Environmental and Social Risks) – whichever is stricter - in the case of sites/operations in non-EU countries) for the
site/operation (including ancillary services, e.g. transport infrastructure and operations, waste disposal facilities, etc.) and any required mitigation measures for protecting biodiversity/eco-systems, in particular UNESCO World Heritage and Key Biodiversity Areas (KBAs), have been implemented.
For sites/operations located in or near to biodiversity-sensitive areas (including the Natura 2000 network of protected areas as well as other protected areas), ensure that an appropriate assessment has been conducted in compliance with the provisions of the EU Biodiversity Strategy (COM (2011) 244), the Birds (2009/147/EC) and Habitats (92/43/EEC) Directives (or other equivalent national provisions or international standards (e.g. IFC Performance Standard 6) – whichever is stricter - in case of sites/operations in non-EU countries) based on the conservation objectives of the protected area. For such sites/operations, ensure that:
• a site-level biodiversity management plan exists and is implemented in alignment with the IFC Performance Standard 6: Biodiversity
Conservation and Sustainable Management of Living Natural Resources;
• all necessary mitigation measures are in place to reduce the impacts on species and habitats; and
• a robust, appropriately designed and long-term biodiversity monitoring and evaluation programme exists and is implemented.
Do no significant harm assessment Manufacture of chlorine
The main potential significant harm to other environmental objectives from the manufacture of chlorine is associated with:
• polluting emissions to air (e.g. chlorine);
• process water effluents which can contain oxidizing agents (e.g. chlorine)
• the use of water in water stressed areas; and
• the generation of wastes
Due to the intrinsic hazard properties of chlorine it is recommended to further assess when Chlorine could be considered part of the solution to achieving zero pollution (toxic free environment) and therefore should not excluded from the taxonomy due to DNSH implications.
(2) Adaptation • Refer to the screening criteria for DNSH to climate change adaptation.
(3) Water • Identify and manage risks related to water quality and/or water consumption at the appropriate level. Ensure that water use/conservation management plans, developed in consultation with relevant stakeholders, have been developed and implemented.
• In the EU, fulfil the requirements of EU water legislation.
(4) Circular Economy
Wastes and by-products, especially hazardous process wastes, are managed in line with the Waste Treatment BREF and the requirements set out in the BREF for the Production of Chlor-Alkali.
(5) Pollution Ensure polluting emissions to air and water are within the BAT-AEL ranges set in the BREF for the Production of Chlor-Alkali.
(6) Ecosystems Ensure an Environmental Impact Assessment (EIA) has been completed in accordance with the EU Directives on Environmental Impact Assessment (2014/52/EU) and Strategic Environmental Assessment (2001/42/EC) (or other equivalent national provisions or international standards (e.g. IFC Performance Standard 1: Assessment and Management of Environmental and Social Risks) – whichever is stricter - in the case of sites/operations in non-EU countries) for the site/operation (including ancillary services, e.g. transport infrastructure and operations, waste disposal facilities, etc.) and any required mitigation measures for protecting biodiversity/eco-systems, in particular UNESCO World Heritage and Key Biodiversity Areas (KBAs), have been implemented.
For sites/operations located in or near to biodiversity-sensitive areas (including the Natura 2000 network of protected areas as well as other protected areas), ensure that an appropriate assessment has been conducted in compliance with the provisions of the EU Biodiversity Strategy (COM (2011) 244), the Birds (2009/147/EC) and Habitats (92/43/EEC) Directives (or other equivalent national provisions or international standards (e.g. IFC Performance Standard 6) – whichever is stricter - in case of sites/operations in non-EU countries) based on the conservation objectives of the protected area. For such sites/operations, ensure that:
• a site-level biodiversity management plan exists and is implemented in alignment with the IFC Performance Standard 6: Biodiversity
Conservation and Sustainable Management of Living Natural Resources;
• all necessary mitigation measures are in place to reduce the impacts on species and habitats; and
• a robust, appropriately designed and long-term biodiversity monitoring and evaluation programme exists and is implemented.