1. CO 2 -Monitoring in the Ceramic Industry in the scope of EU ETS Katharina Liepach, German Brick and Tile Association Member of TBE, Member of Cerame Unie Köln, 12 th May 05

2. Specifics of the ceramic industry rough estimation: across the EU Member States: ceramic installations cover 10% of all installations and emitt less then 1% of the CO 2 => many installations, only little emissions many SMEs

3. Ceramic Annex: Annex X First, all possible sources are listed: calcination of limestone/dolomite in the raw material limestone for reducing air pollutants conventional fossil kiln fuels alternative fossil-based kiln fuels and raw materials biomass kiln fuels (biomass wastes)

4. Ceramic Annex: Annex X other fuels organic material in the clay raw material additives used to induce porosity, e.g. sawdust or polystyrol waste gas scrubbing

5. Ceramic Annex: Annex X In the following paragraphs only the calcination process is covered in depths. The rest is missing.

6. Ceramic Annex: Annex X How should the emissions coming form organic material in the clay raw material and pore forming agents be determined is not dealt with.

7. Ceramic Annex: Annex X The maximum permissible uncertainty of 2.5 % when determining the CO 2 emissions coming form the calcination process is is too low. MRG, page 21, table 3: Informative table with typical overall uncertainties associated to the determination of CO 2 emissions from an installation or activity in an installation for individual fuel or material streams of different magnitudes

8. Ceramic Annex: Annex X MRG, page 21, table 3: process emissions from solid raw materials, (limestone, dolomite) Installations with less than 100 ktonns CO 2 per year: 10%

9. Ceramic Annex: Annex X Why 2,5% in Annex X? Most installations emitt less than 50 ktonns per year, so an overall uncertainty of 12,5% for the emissions coming from the raw material is resonable.

10. Ceramic Annex: Annex X Conclusion: 1.In general the MRG focus on large installations. 2.Many information are missing for the ceramic industry. 3.The uncertainty is too low.

11. Ceramic Annex: Annex X Thus: There is the risk that the monitoring will be highly expensive for the individual installations across the member states. Cost and effect could be absolutely disproportional.