As CarbonEmit, we actively support companies in fulfilling their CBAM reporting obligations. Based on the challenges observed among our client firms, we would like to highlight the following issues and recommendations. Concerning the recognition of carbon prices paid in third countries, existing uncertainties make it difficult for importers to plan their costs.
CAR
CarbonEmit
Company · Turkey
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.
3
positions filed
in the 665 files tracked
3
legislative files
of 665 tracked
0
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
CarbonEmit filed 3 positions on 10 Sept 2025, across 3 of the 665 legislative files tracked here.
What they argued
On emission methodology, it is crucial that the secondary technical regulations governing the calculation of embedded emissions are finalized without delay. Currently, data from supplier countries is often incomplete or unreliable, undermining the accuracy of reporting.
Regarding the adjustment for EU ETS free allocation, the current practice does not sufficiently encourage low-carbon production. The gradual phase-out of free allocations must be accompanied by new mechanisms that reward clean producers. Otherwise, the EU carbon price signal will be weakened, slowing down the transition to low-emission technologies.
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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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Everything on this page comes from CarbonEmit’s own submissions to the European Commission. We have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.