1. CONTEXT OF THE PROPOSAL Activities storing CO2 from an ETS installation in a storage site permitted under the CCS Directive are explicitly included in the EU ETS Directive and EU ETS allowances must be surrendered in the event of CO2 leakages.
BTI
Brazilian Tree Industry
Industry association · BRA · EU Transparency Register TR ID 706627042924-27not in register snapshot
This register number is the organization’s own declaration on its submission. It is not in the 14 Oct 2026 snapshot of the EU Transparency Register, so we neither link to it nor use it to identify this organization.
5
positions filed
in the 665 files tracked
5
legislative files
of 665 tracked
1
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Brazilian Tree Industry filed 5 positions between 6 Mar 2023 and 17 Apr 2026, across 5 of the 665 legislative files tracked here, attaching a full position paper 1 time.
2023 · 1 filed2025 · 2 filed2026 · 2 filed
What they argued
1. CBAM should not be expanded for downstream goods without technical criterion. We recommend that the possible inclusion of downstream goods in the CBAM be preceded by specific analyses of Technical Capability of Quantification at non-EU origins ", respecting different development realities.
Filed in Portuguese · English published by the European Commission
Integration between technological and nature-based solutions Restricting the concept of permanence only to geological or long-term storage technologies narrows the range of possible solutions, limits scalability, and may delay immediate progress.
The submission argues that the European framework for international carbon credits should be aligned with Article 6 of the Paris Agreement, ensuring regulatory predictability and avoiding excessive barriers that could limit the participation of developing countries.
The submission argues that the European framework for international carbon credits should be aligned with Article 6 of the Paris Agreement, ensuring regulatory predictability and avoiding excessive barriers that could limit the participation of developing countries.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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