Integral Consult

Company · EGY

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.

positions filed

in the 665 files tracked

legislative files

of 665 tracked

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

Integral Consult filed 3 positions between 25 Sept 2025 and 10 Jun 2026, across 3 of the 665 legislative files tracked here, attaching a full position paper 3 times.

2025 · 2 filed2026 · 1 filed

What they argued

Carbon price paid in a third country under the carbon border adjustment mechanism (CBAM)filed 10 Jun 2026PDFsource

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.

Objection pursuant to Rule 115(2) and (3) of the Rules of Procedure on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2023/956 of the European Parliament and the Council as regards the methods for the calculation of emissions embedded in goodsfiled 25 Sept 2025PDFsource

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.

Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances phase-outfiled 25 Sept 2025PDFsource

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.

Showing 5 of 103.

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Everything on this page comes from Integral Consult’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.

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