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
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.
4
positions filed
in the 665 files tracked
4
legislative files
of 665 tracked
0
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
Heidelberger Druckmaschinen AG filed 4 positions between 25 May 2021 and 25 Sept 2025, across 4 of the 665 legislative files tracked here.
2021 · 1 filed2025 · 3 filed
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
As a leading supplier in offset printing technologies we see "barrier free" accessible and safe product information for all patients as a must to ensure equal health protection for all ages. Printed information ensures that there are no access problems for all groups of users.
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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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