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.
E-ledgers Institute
NGO · United States
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
E-ledgers Institute filed 2 positions between 26 Aug 2025 and 25 Sept 2025, across 2 of the 326 legislative files tracked here, attaching a full position paper 2 times.
What they argued
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.
- Cefic · 2 files in common
- EDF - Electricité de France · 2 files in common
- ECOS · 2 files in common
- DigitalTrade4.EU · 2 files in common
- German Association of Biotechnology Industries (DIB) within the German Chemical Industry Association - VCI · 2 files in common
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.