Cement Manufacturers Association (CMA)

70 5. Implementation Challenges The first challenge is measurement complexity. Cement plants vary in technology, product mix, fuel use, kiln efficiency, and clinker substitution levels, so emissions intensity benchmarking must be carefully designed to avoid unfair comparisons. This is particularly relevant for grinding units and blended cement producers, where emissions can differ sharply from clinker- heavy integrated plants. The second challenge is abatement cost dispersion. Some efficiency improvements are relatively low-cost, but deeper reductions require alternative fuels, high clinker substitution, renewable electricity, and eventually CCUS. NITI Aayog's cement decarbonisation roadmap highlights three high-impact levers: refuse-derived fuel, supplementary cementitious materials, and carbon capture, utilisation and storage. The third challenge is infrastructure readiness. RDF supply chains, waste segregation systems, quality control for clinker substitutes, and CCUS pilots are not uniformly developed across India. As a result, compliance pressure under CCTS may be ahead of supply-chain and technology readiness in many regions. This makes phased implementation and policy coordination essential. 6. Decarbonisation Pathways The cement industry can use CCTS as a compliance driver for operational and process change. The most immediate pathway is thermal substitution through RDF and other alternative fuels, which can reduce coal dependence and lower energy emissions. NITI Aayog notes that increasing RDF use to reach a 20 percent thermal substitution rate by 2030 could generate substantial cumulative emission reductions and meaningful socioeconomic benefits. A second pathway is clinker substitution through supplementary cementitious materials such as fly ash, slag, calcined clay, and other low- carbon binders. Since clinker is the main source of process emissions, reducing the clinker-to- cement ratio can materially lower emissions intensity while preserving product performance. NITI Aayog also notes that performance-based standards would support wider adoption of blended cement and alternative formulations. A third pathway is CCUS, which is especially relevant for process emissions that cannot be eliminated through fuel switching alone. For cement, CCUS is the long-term solution for deep decarbonisation, although it remains capital- intensive and depends on transport, storage, and utilisation infrastructure. CCTS can improve the business case for such investments by monetising emissions reductions through credits. Table 2: Major abatement levers 7 Lever Role in cement decarbonisation Implementation horizon RDF / alternative fuels Reduce kiln fuel emissions Near term Clinker substitution Reduce process emissions per tonne Near to medium term Renewable electricity Cut indirect emissions Near term CCUS Address residual process emissions Long term