CarbonChain, a carbon accounting and CBAM compliance platform working across multi-tier steel, fertiliser and aluminium chains, welcomes the draft and its core design (actual-values gate, recital 5; verification link, recital 25; standard templates; default-price fallback). Our recommendations focus on workability and accuracy. 1. Recognise third-country carbon border adjustments.
CAR
CarbonChain
Company · United Kingdom
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
2
positions filed
in the 665 files tracked
2
legislative files
of 665 tracked
2
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
CarbonChain filed 2 positions between 8 Jun 2026 and 5 Aug 2026, across 2 of the 665 legislative files tracked here, attaching a full position paper 2 times.
What they argued
CarbonChain is a carbon accounting and CBAM compliance platform for authorised declarants in steel, fertiliser and aluminium. We welcome the draft Delegated Regulation and offer five recommendations. On the single annual repurchase request, we ask that partial repurchase be permitted (residue keeping its lot price), that the declarant nominates the lots, that the Article 23(2) cap is shown before commitment, and…
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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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