It is not clear whether the EU approach is based upon the import of goods, and the way to bring CO2-certificates into calculation. One possibility is to import goods and purchase CO2-certificates in the country of origin at the price for CO2-certificate in the country of origin or Second possibility to expect that a price for CO2-certificat shall be the "within-EU-price" for this certificate.
HDA
Heidelberger Druckmaschinen AG
Company · Germany
3
positions filed
in the 326 files tracked
3
legislative files
of 326 tracked
0
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
Heidelberger Druckmaschinen AG filed 3 positions on 25 Sept 2025, across 3 of the 326 legislative files tracked here.
What they argued
The EU-approach to calculate CO2-content for CBAM-relevant goods appears to be a theoretical approach than an feasible way to handle the data. Looking into CO2 footprint calculations it is nearly impossible to perform a calulation on CO2-content for a product in terms of exact determination.
The implementation of the consideration of free allocation of CO2 allowances for CBAM shall be simple and comprehensible. How will free ETS certificates and CBAM certificates be taken into account in the future calculation? It is unclear whether and how free allowances (from ETS) can be taken into account in CBAM. There is no concrete legislative proposal for implementation.
Filed in German · English published by the European Commission
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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
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