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HOL

Holmen

Company · Sweden

2
positions filed
in the 655 files tracked
2
legislative files
of 655 tracked
1
with a full position paper
attached to a submission

Counts here are a floor, never a total: they cover the 655 consultation files tracked so far (56,999 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.

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Their record over time

Holmen filed 2 positions between 2 Dec 2020 and 8 Jul 2025, across 2 of the 655 legislative files tracked here, attaching a full position paper 1 time.

2020 · 1 filed2025 · 1 filed

What they argued

EU Emissions Trading System and market stability reserve: competitiveness and cost-effective decarbonisationfiled 8 Jul 2025source

The Emission Trading System (ETS) has by and large worked well. In the areas where it has been introduced, it has put a cap on total greenhouse gas emissions, and provided a well-functioning pricing mechanism for efficiency within the limits of that cap. Holmen AB agrees with the submission in the public consultation from the SFIF Swedish Forestry Industries Federation.

Nature restorationfiled 2 Dec 2020PDFsource

Holmen welcomes a discussion of the need for nature restoration. Holmen’s own experience from 400 years of forest management in Sweden is that focus should be on nature conservation management activities rather than on amount of land set a side.

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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 19.

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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.