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E-ledgers Institute

NGO · United States

2
positions filed
in the 665 files tracked
2
legislative files
of 665 tracked
2
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

E-ledgers Institute filed 2 positions between 26 Aug 2025 and 25 Sept 2025, across 2 of the 665 legislative files tracked here, attaching a full position paper 2 times.

What they argued

Carbon Border Adjustment Mechanism: extension of its scope to downstream goods and anti-circumvention measuresfiled 26 Aug 2025PDFsource

We strongly support the Commissions objectives to extend CBAM to downstream products, close anti-circumvention loopholes, and reform electricity-emissions accounting. We recommend adopting the E-ledgers carbon accounting method as the foundation for these reforms. The method provides auditable, product-specific, invoice-level tracking of embedded emissions across value chains.

Objection pursuant to Rule 115(2) and (3) of the Rules of Procedure on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2023/956 of the European Parliament and the Council as regards the methods for the calculation of emissions embedded in goodsfiled 25 Sept 2025PDFsource

Please refer to the attached letter, which offers our comments on the proposed EU Carbon Border Adjustment Mechanism (CBAM) rules on the methodology for calculating emissions embedded in CBAM goods. Please do not hesitate to contact us if you have questions or seek any clarification on this letter. We remain at your service.

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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.

Showing 5 of 41.

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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.