Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
As companies, we are not covered by the de minimis rule and are already subject to the CBAM obligation today. Already now CBAM generates higher administrative costs than the current CO certificate prices would do in direct costs. These administrative costs are much more easily mitigated by economies of scale for large companies than for small and medium-sized enterprises (SMEs).
Filed in German · English published by the European Commission
As SMEs, we are very concerned about the developments regarding the DPP. The need to involve a service provider for the DPP only contributes to further increased costs, which are ultimately passed on to consumers. Costs will be less important for large companies due to higher volumes and will lead to an increased imbalance.
Filed in German · English published by the European Commission
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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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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.