Cumulative Cost Assessment (CCA) of the EU Ceramics Industry Summary
Core Content
The Cumulative Cost Assessment (CCA) of the EU ceramics industry evaluates the regulatory costs incurred by EU manufacturers in specific subsectors: bricks and tiles, ceramic tiles, fired refractories, and unfired shaped refractories. The assessment is retrospective, focusing solely on EU legislation and regulatory costs, excluding any benefits or cost-benefit analysis.
The study covers the period 2006–2015, with key findings for 2015 highlighting the most recent impacts of EU rules on the industry.
Key Findings
Regulatory Costs per Tonne of Output (2015)
| Subsector |
Regulatory Costs (€/tonne) |
| Bricks and tiles |
5.00 |
| Ceramic tiles |
12.41 |
| Fired refractories |
28.52 |
| Unfired shaped refractories |
14.77 |
Regulatory Costs as a Share of Production Costs (2015)
| Subsector |
Regulatory Costs (%) |
| Bricks and tiles |
5.4% |
| Ceramic tiles |
2.7% |
| Fired refractories |
2.4% |
| Unfired shaped refractories |
2.2% |
Regulatory Costs as a Share of EBITDA (2015)
| Subsector |
Regulatory Costs (%) |
| Bricks and tiles |
21.9% |
| Ceramic tiles |
10.0% |
| Fired refractories |
18.5% |
| Unfired shaped refractories |
42.5% |
Main Areas of Legislation
The following areas of EU legislation were analyzed:
- Internal Market
- Energy (electricity, gas, energy efficiency)
- Climate (EU ETS, monitoring, reporting)
- Environment (industrial emissions, waste)
- Workers' and Workplace Safety
- Consumers and Health
Breakdown of Regulatory Costs by Category
Bricks and Tiles (2015)
| Category |
Cost (€/tonne) |
Share of Total (%) |
| Administrative Burdens |
0.36 |
7.2% |
| Substantive Compliance Costs |
1.46 |
29.2% |
| Direct Charges |
0.40 |
8.0% |
| Indirect Costs |
2.78 |
56.0% |
Ceramic Tiles (2015)
| Category |
Cost (€/tonne) |
Share of Total (%) |
| Administrative Burdens |
0.61 |
4.9% |
| Substantive Compliance Costs |
4.18 |
33.7% |
| Direct Charges |
0.85 |
6.9% |
| Indirect Costs |
6.77 |
54.4% |
Fired Refractories (2015)
| Category |
Cost (€/tonne) |
Share of Total (%) |
| Administrative Burdens |
3.56 |
12.5% |
| Substantive Compliance Costs |
15.14 |
53.1% |
| Direct Charges |
1.02 |
3.6% |
| Indirect Costs |
7.24 |
25.4% |
Unfired Shaped Refractories (2015)
| Category |
Cost (€/tonne) |
Share of Total (%) |
| Administrative Burdens |
2.96 |
20.0% |
| Substantive Compliance Costs |
4.06 |
27.5% |
| Direct Charges |
0.51 |
3.4% |
| Indirect Costs |
7.24 |
48.9% |
Cost Drivers
Bricks and Tiles
- Electricity legislation was the largest cost driver (€2.25/tonne, 45% of total regulatory costs).
- Environmental legislation (€0.73/tonne, 15% of total regulatory costs).
- General workers' and workplace safety legislation (€0.54/tonne, 11% of total regulatory costs).
- Gas legislation (€0.52/tonne, 10% of total regulatory costs).
Ceramic Tiles
- Electricity legislation was the main cost driver (€5.79/tonne, 47% of total regulatory costs).
- Waste legislation (€1.40/tonne, 11% of total regulatory costs).
- Environmental legislation (€1.25/tonne, 10% of total regulatory costs).
- General workers' and workplace safety legislation (€1.24/tonne, 10% of total regulatory costs).
Fired Refractories
- Environmental legislation was the largest cost driver (€11.17/tonne, 39.1% of total regulatory costs).
- Electricity legislation (€7.07/tonne, 25% of total regulatory costs).
- General workers' and workplace safety legislation (€3.18/tonne, 11.1% of total regulatory costs).
- Internal market chemicals legislation (€2.37/tonne, 8.3% of total regulatory costs).
Unfired Shaped Refractories
- Electricity legislation was the main cost driver (€6.50/tonne, 44.0% of total regulatory costs).
- Chemicals legislation (€2.42/tonne, 16.4% of total regulatory costs).
- Waste legislation (€2.26/tonne, 15.3% of total regulatory costs).
- General workers' and workplace safety legislation (€1.81/tonne, 12.3% of total regulatory costs).
Methodology
- The CCA is retrospective and focuses on EU rules, excluding benefits and cost-benefit analysis.
- The study used a non-statistically representative sample of plants, selected based on:
- Sectors: Bricks and tiles, ceramic tiles, refractories.
- Geographical distribution: Central-Eastern Europe, Northern-Western Europe, Southern Europe.
- Company size/ownership: Large companies and SMEs in the bricks and tiles and ceramic tiles sectors.
- Plant features: Fired and unfired shaped refractories.
- The sample sizes were:
- Bricks and tiles: 23 plants.
- Ceramic tiles: 16 plants.
- Fired refractories: 11 plants.
- Unfired shaped refractories: 4 plants.
- The data is net of business as usual (BAU), i.e., costs are adjusted to exclude those that would be incurred without EU regulations.
Summary of Key Performance Indicators
- Regulatory costs for bricks and tiles represented 5.4% of production costs and 21.9% of EBITDA in 2015.
- Regulatory costs for ceramic tiles were 2.7% of production costs and 10.0% of EBITDA.
- Regulatory costs for fired refractories were 2.4% of production costs and 18.5% of EBITDA.
- Regulatory costs for unfired shaped refractories were 2.2% of production costs and 42.5% of EBITDA.
Limitations
- For unfired shaped refractories, EBIT data could not be presented due to limited sample size and volatility.
- The study does not account for benefits or cost-benefit balance of regulations.
- The sample is not statistically representative, but it is typical and covers significant portions of the industry's output.
