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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.

CEM
Cemminerals

Company · Belgium

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
ETE
Energy Traders Europe

Industry association · Netherlands

18
files engaged
of 583 tracked
20
positions filed
in those 583 files
6.7
declared FTE
self-declared
6
EP accreditations
as declared to the register

Declared costs: €1.3M+ a year · in the register since 2009

Files both filed on (2)

Monitoring, reporting and verification of greenhouse gas emissions from maritime transport · Sale and repurchase of CBAM certificates

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.

Monitoring, reporting and verification of greenhouse gas emissions from maritime transport

Cemminerals · filed 17 Nov 2020 · 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.

Energy Traders Europe · filed 8 Nov 2021 · source

The European Federation of Energy Traders (EFET) welcomes the opportunity to provide our comments to the Commission consultation on updating the EU emissions trading system (ETS ). Our main messages are: 1. Reinforcing the role of the EU ETS as a key driver of a cost-effective decarbonisation of the EU economy. 2. Creating a pathway for a gradual expansion of the EU ETS. 3.

Sale and repurchase of CBAM certificates

Cemminerals · filed 16 Jul 2026 · source

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.

Energy Traders Europe · filed 5 Aug 2026 · source

Energy Traders Europe (ETE) represents more than 180 members active across European gas, electricity, carbon and associated markets. Our response below focuses on the operational workability of the CBAM platform and aims to ensure a secure, cost-efficient, transparent and predictable framework for the sale and repurchase of CBAM certificates. Key messages: 1.

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