Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
What each said, in their own words
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
I would like to comment on a necessary adaptation of the ETS system with regards to future CBAM for cement (clinker) import in Europe. In our opinion, Europe should not create a situation where Europe cement companies are given free CO2 allowances, basically letting them pollute, and on the other hand enforce taxes on the same goods that are imported because they are polluting.
•Enel welcomes the approach of the legislative initiative, aimed at strengthening the EU ETS, and the ambitious package of policies and measures to accelerate the just transition to a low-carbon economy. It is critical for the EC to adopt a holistic approach enhancing carbon pricing alongside complementary policies and measures.
Please, find below a synthesis of Enel’s view on EU ETS revision proposal. For further details, please see the attached document. Enel welcomes the EU ETS Directive’s “Fit for 55” proposal of reform as it fits with the increased EU climate ambition and will help provide stable and predictable carbon price signals.
Cemminerals is a Belgian family owned cement company with a production plant in Gent and 10% market share in Belgium. We are implicated by the CBAM as part of our raw materials (cement clinker) are imported from outside Europe. As part of the European SME Cement Association (ESMECA), we strongly support the vision of CBAM: ensure that imported products face carbon costs equivalent to those born by EU producers.
Enel supports the CBAM as a necessary complement to the EU ETS to address carbon leakage, preserve a level playing field between EU and non-EU producers, and safeguard industrial competitiveness, while maintaining a strong and predictable carbon price signal.
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