[China Building Materials Federation] China Building Materials Federation requires: to guide the orderly exit of inefficient production capacity in accordance with laws and regulations to prevent the wrong tendency of "one size fits all" and "sports carbon reduction"

Recently, the State Council issued the "Carbon Peak Action Plan by 2030" (Guo Fa [2021] No. 23), which clearly pointed out that it is necessary to "in-depth tap the potential of stock projects, accelerate the elimination of backward production capacity, and tap the potential of energy conservation and emission reduction through transformation and upgrading." Resolutely curb the blind development of the "two highs" project; the National Development and Reform Commission and other five departments issued the "Several Opinions on Strict Energy Efficiency Constraints to Promote Energy Conservation and Carbon Reduction in Key Areas" (Development and Reform Industry [2021] No. 1464), and issued the "Strict Energy Efficiency Constraints in Key Industries of Metallurgy and Building Materials to Promote Energy Conservation and Carbon Reduction Action Plan (2021-2025)", emphasizing the need to "guide the orderly withdrawal of inefficient production capacity".

In order to fully implement the decision-making and deployment of the Party Central Committee and the State Council, the majority of enterprises in the building materials industry are taking various measures to tap the potential of energy conservation, pollution reduction and carbon reduction, and strive to promote the green, low-carbon, safe and high-quality development of the industry. But at the same time, around the problem of orderly withdrawal of inefficient production capacity in the cement industry, there is a wrong tendency in some places to simply equate inefficient production capacity with small-scale production lines without according to the requirements of relevant national policies, regulations and standards. It is believed that inefficient production capacity is small-scale production lines, and small production scale will inevitably lead to inefficient production capacity. It is even proposed to draw lines based on scale and adopt a "one size fits all" approach, eliminate the production line of cement clinker with a daily output of 2500 tons and below. This kind of wrong working thinking and way is actually the concrete manifestation of "sports carbon reduction". If it is not guided correctly, it will affect the correct and effective implementation of the national "double carbon" strategy and mislead the behavior of enterprises in the industry.

To effectively carry out the work of eliminating backward production capacity and promote the building materials industry to achieve the goal of "double carbon" as soon as possible, we must fully understand the environmental changes of social governance and administrative governance in China, objectively analyze the actual operation of cement enterprises and cement clinker production lines in China, and comprehensively consider how to give full play to the role of "purifier" of cement industry in social and economic cycle, Correctly guide and promote the industry to save energy, reduce pollution and reduce carbon.

First, it is necessary to use comprehensive standards in accordance with laws and regulations to eliminate backward production capacity. On February 25, 2019, General Secretary Xi Jinping pointed out in his speech at the second meeting of the Central Committee for the Comprehensive Rule of Law, "It is necessary to use the rule of law to regulate the boundary between the government and the market, respect the laws of the market economy, and use market-oriented means within the framework of the rule of law. Adjust the interests of various market entities". In the "Notice of the State Council on Further Strengthening the Elimination of Backward Production Capacity" (Guo Fa [2010] No. 7), the "Guiding Opinions of the State Council on Resolving Serious Overcapacity Contradictions" (Guo Fa [2013] No. 41) and other relevant documents, The work idea of focusing on market-oriented means is emphasized and clarified. The "Guiding Opinions on Using Comprehensive Standards to Promote the Exit of Backward Production Capacity in accordance with Laws and Regulations" jointly issued by 16 ministries and commissions including the Ministry of Industry and Information Technology (No. 2017 of the Ministry of Industry and Information Technology) more specifically stated that it is necessary to "realize the transformation of working methods from mainly relying on administrative means to comprehensive use of laws and regulations, economic means and necessary administrative means; to realize the definition of standards by mainly relying on equipment scale, process and technical standards, shift to comprehensive standards for energy consumption, environmental protection, quality, safety, and technology; establish a market-oriented, legalized, and normalized work promotion mechanism."

Therefore, taking standards and regulations as the definition, giving full play to the role of the market, and making comprehensive use of energy consumption, environmental protection, quality, safety, technology and other means to achieve marketization and legalization of the working mechanism of eliminating backward production capacity should be an important principle for carrying out the work of eliminating backward production capacity.

Second, small-scale production lines should not be simply equated with backward production capacity. Although on the whole, the large-scale development of cement kilns is conducive to giving full play to the advantages of scale and reducing the average energy consumption and material consumption level per unit product. At present, China's daily production of 2500 tons and below cement clinker production line accounted for 28% of the total production capacity, of which some production lines can not reach the energy consumption, environmental protection and other standards of advanced access value. Although on the whole, the large-scale development of complete sets of cement kiln equipment is conducive to giving full play to the advantages of scale and reducing the average energy consumption and material consumption level per unit product, many production lines with a daily output of 2500 tons or less in China are no worse than large-scale production lines through technological transformation and management improvement. For example, among the 28 cement companies in the list of energy efficiency "leaders" in the national key energy-using industries jointly organized by the Ministry of Industry and Information Technology and the General Administration of Market Supervision in 2020, 5 have cement clinker production lines of 2500 tons/day and below, while some relatively large production lines are not included. Therefore, it is not sufficient to simply use the scale as the basis for dividing backward production capacity.

From a technical point of view, the energy efficiency level of the production line is not necessarily related to the scale of the kiln line. According to the analysis of current cement clinker production process, the heat consumption generated by cement clinker is necessary for chemical reaction. The heat loss caused by waste gas from kiln head and kiln tail and heat from finished products, rotary kiln, cooler, preheater, decomposition furnace and tertiary air duct are mainly closely related to equipment, technology and management level, and the size of production line is not the decisive factor. Improving the technical level of waste heat utilization, raw fuel substitution, and improving production management capabilities will help improve energy efficiency and reduce energy consumption per unit of product.

Third, the role of small-scale production lines should be considered in accordance with the "carbon footprint" of cement products. Make full use of the existing cement kiln, the surrounding town solid waste and collaborative disposal characteristics, according to local conditions, cement enterprises as the city's functional standard, play the role of "urban purifier", reduce the repeated investment of solid waste projects, is an important way to reduce the energy consumption and carbon emission level of the industry. In general, the cement market consumption and solid waste production depend on the size of the local population and the level of economic and social development. Judging from the current status of my country's resource recycling system and the amount of domestic waste generated, small-scale cement clinker production lines are easier to match the construction of green ecological cities in various places, and can effectively play the role of environmental protection and "urban purifier. At the same time, it should be considered that the economic radius of cement product market sales is small, and the scale of production line can be determined according to the distribution of raw material resources, transportation consumption, market capacity, etc.

Fourth, the size of the scale as the basis for elimination will affect the building materials industry to participate in the "Belt and Road" construction and building materials enterprises, technology, equipment "going out". China's cement enterprises have successfully invested in the construction of a number of foreign local market demand, the use of the most advanced domestic technology and equipment of small-scale production lines, building materials industry "One Belt One Road" and "going out" development of the successful case. If we only measure the technological advancement in terms of scale, and even define small-scale production lines as backward production capacity and inefficient production capacity, it will not only give people a handle in the world, but also seriously affect and restrict advanced production processes, technologies and equipment of similar scale to carry out international production capacity cooperation, and form self-restraint for China's building materials industry to participate in the "Belt and Road Initiative" construction and the "going out" of building materials enterprises, technology and equipment.

Fifth, small-scale production lines have unique advantages in promoting the construction, application and promotion of green energy and zero-carbon demonstration projects. The Central Committee of the Communist Party of China and the State Council clearly stated in the "Opinions on the Complete, Accurate and Comprehensive Implementation of the New Development Concept to Do a Good Job in Carbon Neutralization" that renewable energy substitution actions should be implemented, and priority should be given to the local development and utilization of wind and solar energy. The reasonable distribution of small-scale cement production lines will help promote the exploration, practice and construction of small and medium-sized "carbon neutral" demonstration projects such as "full green energy" and "zero carbon" in green energy-rich areas such as wind energy and solar energy, which is conducive to promoting the promotion and application of distributed green energy from the perspective of demand side.

Therefore, we must resolutely implement the deployment of the Party Central Committee, the State Council, and relevant ministries and commissions on energy conservation and carbon reduction. On the one hand, we must increase our work and unswervingly guide the orderly withdrawal of inefficient production capacity. On the other hand, when formulating policies related to the elimination of backward production capacity in the cement industry, it is necessary to target and effectively implement policies, not only fully consider the characteristics and reality of the development of the industry, but also take laws, regulations and standards as the criterion, and adhere to the use of comprehensive means such as the rule of law and marketization. Carry out the work of eliminating backward production capacity to ensure that the policies and measures for energy conservation, pollution reduction and carbon reduction achieve the optimal results and expected goals. Even if many small-scale production lines are eventually eliminated in accordance with existing regulations, standards, and policies such as the Energy Conservation and Carbon Reduction Action Plan in accordance with laws and regulations, it is also the result of the implementation of comprehensive standards in accordance with laws and regulations. It is impossible to put the cart before the horse and draw a line based on scale. Adopting misdirections and practices such as "one size fits all" and "sports carbon reduction" cannot protect backward and inefficient production lines, otherwise, it will affect the effective promotion and implementation of the national "double carbon" strategy and the "Belt and Road Initiative" initiative.

Source: China Building Materials Federation