EMSTEEL supports a clear, auditable deduction for carbon prices in the country of origin, including proportional credits where domestic pricing covers only part of embedded emissions. To ensure consistency, apply strong anti-double-counting safeguards and standardized CBAM registry templates.
EBM
EMSTEEL Building Materials PJSC
Company · ARE
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
EMSTEEL Building Materials PJSC filed 3 positions on 25 Sept 2025, across 3 of the 326 legislative files tracked here, attaching a full position paper 3 times.
What they argued
The methodology should put measured, site-specific actual data first, with clear, simple quality checks so numbers are reliable. When measured data is not available, it should allow practical fallback values that are published, explain their uncertainty, and do not unfairly punish low-carbon producers.
Maintain parity with the EU ETS by applying a transparent, published formula that aligns CBAM obligations with the share of EU free allocation. For consistency, the European Commission is requested to provide replicable worked examples for iron and steel and clear rules for annual updates to benchmarks and free-allocation shares.
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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 · 3 files in common
- ECOS · 3 files in common
- DigitalTrade4.EU · 3 files in common
- Bellona Europa · 3 files in common
- European Advanced Carbon and Graphite Materials Association · 3 files in common
Showing 5 of 103.
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Everything on this page comes from EMSTEEL Building Materials PJSC’s own submissions to the European Commission — we have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
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.