The finalisation of ongoing CBAM legislative acts should take precedence over any scope extension, bringing the existing regulation to an operationally stable state that is clear and practical for all stakeholders.
DIT
Duferco International Trading Holding
Company · Luxembourg
3
positions filed
in the 326 files tracked
3
legislative files
of 326 tracked
3
with a full position paper
attached to a submission
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.
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Their record over time
Duferco International Trading Holding filed 3 positions between 26 Aug 2025 and 6 Aug 2026, across 3 of the 326 legislative files tracked here, attaching a full position paper 3 times.
2025 · 2 filed2026 · 1 filed
What they argued
Duferco International Trading Holding S.A. (DITH) thanks the European Commission for the opportunity to participate in this public consultation on the implementation of CBAM and provides its full comment in the attached file.
DITH welcomes the opportunity to comment on the draft Delegated Regulation. Please find our comments in the attached file. In summary, while this is a well constructed draft, DITH highlights that the mechanisms outlined risk imposing constraints on financial liquidity of businesses, and the rigidity of the rules around certificate repurchase could create instead of remove regulatory burdens.
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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.
- VDMA · 3 files in common
- BMW Group · 3 files in common
- Energy Traders Europe · 3 files in common
- The Japan Iron and Steel Federation · 3 files in common
- Cefic · 2 files in common
Showing 5 of 51.
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