While it is understood that the proposed implementing regulation aims to ensure that a carbon price is not paid twice on the same emissions, the implementing regulation in its current form imposes severe implications on the developing countries, and is accordingly undermining the principles of equity and Common But Differentiated Responsibilities (CBDR) under the UNFCCC and Paris Agreement.
Integral Consult
Company · EGY
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
Integral Consult filed 3 positions between 25 Sept 2025 and 10 Jun 2026, across 3 of the 326 legislative files tracked here, attaching a full position paper 3 times.
What they argued
Our feedback was classified into the following aspects; namely, default values for emissions, challenges regarding the precursor emissions, reporting on the mix of grid and on-site electricity, and the employment of national electricity grid emission factors. Due to the lengthy content, we opted to provide it in the attached document.
1. Implementing act on free allocation • • • • Benchmarking Methodology: The plan to derive CBAM benchmarks from EU ETS benchmarks is a specific point of concern. EU benchmarks are based on the performance of the top 10% of EU installations, which often use advanced, low-carbon technologies. For many developing countries, these benchmarks are not a realistic or achievable target.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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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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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.