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
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
3
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
Duferco International Trading Holding filed 3 positions between 26 Aug 2025 and 6 Aug 2026, across 3 of the 665 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.
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