Under the requirement of "double carbon" strategy and high-quality development, China's cement industry has been facing the structural contradiction of overcapacity and imbalance between supply and demand for a long time. The State Council issued the Action Plan for Energy Conservation and Carbon Reduction from 2024 to 2025 (Guofa [2024] 12), which proposed to strengthen the monitoring and early warning of the output of building materials industry. By the end of 2025, the national cement clinker production capacity will be controlled at about 1.8 billion tons. Strict adherence to the filing capacity standard is the core measure to achieve this regulatory goal. On October 30,
2024, the opinions of the four ministries and commissions on regulating cement production capacity began to be implemented. Hubei, Hunan, Yunnan and other places actively responded to the call of national policies, and successively demanded strict regulation of the production behavior of cement enterprises. The Notice of Hubei Economic and Credit Department and the Department of Ecology and Environment on Effectively Performing the Normalized Peak-Staggered Production of Cement Industry in 2024 requires that "all cement clinker production lines should organize production in strict accordance with the approved capacity"; Hunan cement enterprises also received a notice requiring "enterprises to strictly implement the cement clinker project filing documents, the actual daily output of cement clinker production line shall not exceed 110% of the daily production capacity of the filing, and the actual annual output shall not exceed the annual production capacity of the filing (annual production capacity = daily production capacity of the filing * production days)"; Yunnan cement enterprises need to report the production and operation situation every month, and carry out the output accounting of cement clinker every month.
From the perspective of carbon market, the process carbon emissions of cement clinker production account for 62% of the total emissions of the industry, and its accounting depends on the data of clinker production, raw material consumption and chemical composition. According to the current carbon market accounting rules, clinker production is the core parameter of carbon emission calculation, which directly affects the fairness of quota allocation and trading. Therefore, precise control of clinker production is of strategic significance to achieve total carbon control and improve the quota management system.
At present, strict control of annual output has basically become the consensus of competent departments at all levels and cement production enterprises. The total annual output is determined by the daily output and the number of production days, and the production days of different types of enterprises are clearly and meticulously limited through the policy of peak staggering production. In this context, the importance of daily output control is becoming more and more prominent. Only by implementing the "double control" mechanism of production days and daily output, can precise control of cement production be achieved and the loophole of "making up for the shortage of days by overproduction per day" be avoided.
To sum up, several suggestions are put forward for cement clinker enterprises to organize production according to the registered production capacity:
1. Strengthen policy guidance and implementation supervision. Local governments should issue special policy documents as soon as possible to clarify the normative requirements for cement enterprises to organize production according to the record capacity, to clarify the rigid requirements of "daily output ≤ record capacity * 110%", and to delimit the implementation timetable and the main body of responsibility. At the same time, a monthly output data reporting and verification mechanism is established to ensure that the requirements of capacity management and control are effective.
2. Speed up the construction of standard system. In the practice of capacity and carbon emission management and control, Ningxia Autonomous Region took the lead in issuing the local specification for cement clinker production verification, providing technical basis for regional capacity supervision; the Market Supervision and Administration Bureau of Hubei Province also approved the establishment of the "Technical Specification for Carbon Measurement of Cement Industry in Hubei Province and Verification Method for Clinker Production", actively exploring the construction of local standard system. In view of this, it is suggested that the Ministry of Industry and Information Technology should take the lead in integrating local practical experience, speeding up the formulation of national industry standards or group standards, and building a more authoritative and universal institutional framework for capacity regulation and carbon emission management in the cement industry through unified technical specifications and verification processes, so as to promote the efficiency of industry supervision to achieve cross-regional synergy.
3. Build a digital supervision system. It is suggested to entrust independent third-party institutions and research institutes with professional qualifications to develop an online monitoring system for cement clinker production and build a digital supervision system based on APP application and software platform access. It is mandatory for the cement production line to complete the system docking within the prescribed time limit, so as to realize the real-time upload and dynamic monitoring of production data. By building an intelligent early warning mechanism, the system automatically triggers early warning when overproduction occurs, and pushes abnormal information to production enterprises, industry associations and regulatory authorities at the first time, so as to ensure that violations can be timely intervened and dealt with, and that repeated offenders can be severely punished in accordance with the law and regulations, so as to effectively improve the accuracy and timeliness of capacity supervision.
4. Strengthen legal publicity and punishment. Strengthen the publicity of laws, regulations and policies for local governments, departments and enterprises to organize production according to the production capacity on record. If the clinker output exceeds 110% of the registered production capacity in violation of the Environmental Impact Assessment Law of the People's Republic of China, the enterprise may be fined according to law, and the relevant responsible persons shall be given administrative sanctions; Falsification of clinker production data directly violates the Provisional Regulations on the Management of Carbon Emission Trading, which can impose fines on enterprises, legal representatives and relevant responsible persons, and reduce their carbon emission quotas for the next year according to the proportion of 50% -100%, and those with serious circumstances will be ordered to stop production and rectify. In addition, for enterprises with excess production capacity, dynamic supervision lists should be established, interviews and warnings should be conducted in time, and illegal evidence should be fixed in an all-round way. For enterprises with bad circumstances and repeated prohibitions, joint punishment should be imposed on the main body, legal representative and direct responsible person of the enterprise in strict accordance with the law and regulations, so as to form a strong legal deterrent and ensure the rigid landing of the capacity supervision policy.
Only by building a strict system guarantee system to ensure that enterprises strictly follow the record capacity to organize production, can we effectively solve the development dilemma of excess capacity and imbalance between supply and demand, and ultimately achieve the coordinated progress and mutual benefit of high-quality development of cement industry and ecological environment protection.
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